RECRUITMENT PRIVACY NOTICE
FOR
CALIFORNIA
Last updated: April 1, 2024
Alvarez & Marsal Holdings, LLC, together with its subsidiaries (together, “A&M”, “we”, “our”, “us”), is providing this Recruitment Privacy Notice for California (“California Recruitment Privacy Notice”) in compliance with California Consumer Privacy Act and its implementing regulations (“CCPA”).
This California Recruitment Privacy Notice applies solely to residents of the State of California (“consumers” or “you”) with respect to the collection, use, storage, transmission, disclosure, and/or disposal of personal information by A&M about you in the context of your role as a job applicant to A&M (collectively, “application-related information”). For purposes of this California Recruitment Privacy Notice, the term “job applicant” includes individuals who (i) apply for a position with A&M, (ii) join the A&M Talent Network without applying for a specific position, (iii) are recruited by A&M, (iv) are presented as candidates to A&M by external parties, such as executive recruiters or staffing agencies, or (v) contact A&M to enquire about potential roles. This California Recruitment Privacy Notice supplements all other privacy notices provided to you by A&M with respect to application-related information.
If you enter into a relationship with us as an employee, officer, manager, director, owner, partner, independent contractor, or other category of worker, then a separate California Workplace Privacy Notice will be provided to you.
This California Recruitment Privacy Notice describes:
- The categories of personal information we have collected in the preceding 12 months.
- The categories of sources from which we collect personal information.
- Business or commercial purposes for collecting, disclosing, selling, or sharing personal information.
- The categories of service providers, contractors and third parties to whom we disclose personal information.
- The categories of personal information we have disclosed for a business purpose in the preceding 12 months.
- The categories of personal information we have sold or shared in the preceding 12 months, if any.
- Your California privacy rights.
- Retention of personal information.
- Changes to this notice.
- How to contact us.
This California Recruitment Privacy Notice does not constitute or form any part of an employment, ownership, directorship, partnership, independent contractor, or any other type of agreement with us, or confer any contractual right on you or place any contractual obligations on us.
1. Categories of Personal Information We Collect
“Personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. A “household” means a group, however identified, of California residents who cohabitate with one another at the same residential address and share use of common devices or services.
Personal information does not include:
- Publicly available information, meaning information that is (i) lawfully made available from federal, state, or local government records; or (ii) information that a business has a reasonable basis to believe is lawfully made available to the general public by the individual or from widely distributed media, or by the individual; or (iii) information made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.
- Deidentified or aggregated consumer
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), or clinical trial data; or
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA) (i.e., criminal background and credit checks conducted by a consumer reporting agency at the request of an employer in accordance with the FCRA), the Gramm- Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) (i.e., non-public financial information), and the Driver’s Privacy Protection Act of 1994.
“Selling” personal information means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information by A&M to a third party for monetary or other valuable consideration. (As we explain in Section 6 (“Categories of Personal Information We Have Sold or Shared”), below, A&M does not sell employment-related information).
“Sharing” personal information means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information by A&M to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. (As we explain in Section 6 (“Categories of Personal Information We Have Sold or Shared”), below, A&M does not share application-related information).
“Third party” means any person or entity who is not: (i) the business with whom consumers intentionally interacts and that collects consumers’ personal information from them as part of their interaction with the business; (ii) a service provider of A&M; or (iii) a contractor of A&M.
Table 1, below, (i) identifies the categories of personal information we have collected in the preceding 12 months, which for purposes of CCPA and this California Recruitment Privacy Notice is considered application-related information (as defined above); and (ii) indicates whether we have (a) disclosed personal information for a business purpose, or (b) sold or shared personal information, each in the preceding 12 months. For additional information, please see Section 3 (“Business or Commercial Purposes for Collecting, Disclosing, Selling, or Sharing Personal Information”), Section 5 (“Categories of Personal Information We Have Disclosed for a Business Purpose”), and Section 6 (“Categories of Personal Information We Have Sold or Shared”), below.
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TABLE 1 |
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Category of Personal Information |
Examples |
Collected |
Disclosed for a Business Purposes in the Preceding 12 Months |
Sold or Shared in the Preceding 12 Months |
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
YES |
YES |
NO |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
YES |
YES |
NO |
|
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
YES |
YES |
NO |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
NO |
NO |
NO |
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TABLE 1 |
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Category of Personal Information |
Examples |
Collected |
Disclosed for a Business Purposes in the Preceding 12 Months |
Sold or Shared in the Preceding 12 Months |
|
E. Biometric information. |
An individual’s physiological, biological or behavioral characteristics, including information pertaining to an individual’s DNA, that can be, is used, or is intended to be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
NO |
NO |
NO |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
YES |
YES |
NO |
|
G. Geolocation data. |
Physical location or movements. |
YES |
YES |
NO |
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TABLE 1 |
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Category of Personal Information |
Examples |
Collected |
Disclosed for a Business Purposes in the Preceding 12 Months |
Sold or Shared in the Preceding 12 Months |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information, such as images and audio, video or call recordings created in connection with our business activities. |
YES |
YES |
NO |
|
I. Professional or employment- related information. |
Resume/CV and any cover letter; professional history; education; qualifications; references; licenses; certifications; language skills; professional affiliations; interview or assessment data; other information you provide as part of your recruitment; employee ID; dates of hire / separation; office (country, city); business unit; job description; category (e.g., full/part-time); reporting lines; travel; relocations; terms and conditions of your employment or other agreement; time, leave, and absence data; performance management data; disciplinary and grievance data; other information you provide or which is collected in connection with your ongoing professional and career development; and, termination and retirement data; each of the foregoing in relation to A&M or your prior employer, as the context requires. |
YES |
YES |
NO |
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TABLE 1 |
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Category of Personal Information |
Examples |
Collected |
Disclosed for a Business Purposes in the Preceding 12 Months |
Sold or Shared in the Preceding 12 Months |
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
YES |
YES |
NO |
|
K. Inferences. |
Inferences drawn from other personal information identified above to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
YES |
YES |
NO |
|
L. Sensitive Personal Information |
Social security, driver’s license, state identification card, or passport number. |
YES |
YES |
NO |
|
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. |
NO |
NO |
NO |
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Precise geolocation. |
YES |
YES |
NO |
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Racial or ethnic origin, religious or philosophical beliefs, or union membership. |
YES |
YES |
NO |
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Contents of mail, email, and text messages unless the business is the intended recipient of the communication. |
YES |
YES |
NO |
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TABLE 1 |
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Category of Personal Information |
Examples |
Collected |
Disclosed for a Business Purposes in the Preceding 12 Months |
Sold or Shared in the Preceding 12 Months |
|
Genetic data. |
NO |
NO |
NO |
|
|
Biometric information that is processed for the purpose of uniquely identifying a person. |
NO |
NO |
NO |
|
|
Personal information collected and analyzed concerning a person’s health. |
YES |
YES |
NO |
|
|
Personal information collected and analyzed concerning a person’s sex life or sexual orientation. |
YES |
YES |
NO |
|
2. Categories of Sources of Personal Information
Except where prohibited by (and subject to the requirements of) applicable laws, we may collect personal information about you from multiple sources, including:
- Directly from you: We collect information directly from you during the recruiting process and throughout the course of your candidacy or application to A&M, including if you (i) apply for a position with A&M, (ii) join the A&M Talent Network without applying for a specific position, (iii) are recruited by A&M, (iv) are presented as a candidate to A&M by external parties, such as executive recruiters or staffing agencies, or (v) contact A&M to enquire about potential roles.
- External parties: We collect information from our suppliers (e.g., recruitment / staffing agencies, qualifications testing consultants, criminal and credit background check providers, clients, former employers, universities, named referees, professional certifications, and If you cause your job application or other personal information to be shared with us through a third-party application (e.g., LinkedIn or a job board), we consider that information as having come from an external party.
- Electronic means: We collect information from logs and security camera footage relating to building, office and restricted zone access.
- Government entities: We collect information from courts, regulators, and other government entities.
3. Business or Commercial Purposes for Collecting, Disclosing, Selling, or Sharing Personal Information
Under CCPA, a permissible “business purpose” means a use of personal information related to a business’ (or its service providers’ or contractors’) operational or other notified purposes.
Except where prohibited by (and subject to the requirements of) applicable laws, we may collect and use your personal information for the following purposes:
- Background and reference checks (pre-hire).
- Recruiting / talent acquisition (including managing our talent network; managing the application, interview, candidate assessment, and job offer processes; maintaining a pool of qualified candidates to consider for future opportunities; and, maintaining a record of our recruitment decisions).
- Diversity and inclusion, including non-discrimination in hiring, equality of opportunity or treatment, promoting and maintaining a diverse workforce, and reporting statistics to government agencies).
- Ensuring compliance with laws and A&M policies, including but not limited to non-discrimination and equal opportunity employment.
- Establishment, exercise, or defense of legal claims.
- Managing and monitoring access to A&M offices and restricted zones.
- In connection with the sale of all or a part of our business, our assets, or a reorganization or combination of our organization with another organization.
- Any other lawful purpose reasonably related to your role as a job applicant to A&M.
4. Categories of Service Providers, Contractors and Third Parties to Whom We Disclose Personal Information
Except where prohibited by (and subject to the requirements of) applicable laws, we may disclose your personal information to the following categories of service providers, contractors and third parties:
- Information technology / operating systems and platforms.
- Background screening providers.
- Government entities, including courts, regulators, law enforcement, or tax authorities, or to other constituents in a litigation, in each case where required or permitted by law. In some cases, in accordance with applicable law, it may not be possible to notify you in advance about the details of such disclosures. A&M will use reasonable efforts to disclose the minimum personal information necessary in such cases.
- Our accountants, lawyers, and other professional advisors.
- Other third parties where reasonably related to your role as a job applicant to A&M.
- Other persons or entities in connection with the sale of all or part of our business, or a reorganization or combination of our business with another organization.
5. Categories of Personal Information We Have Disclosed for a Business Purpose
Please refer to Table 1 in Section 1 ("Categories of Personal Information We Collect") above, which identifies the categories of personal information that we have disclosed for a business purpose in the preceding 12 months.
We do not use or disclose sensitive personal information for purposes other than:
- To perform the services reasonably expected by an average consumer who requests To the extent A&M uses or discloses sensitive personal information about you, it is in relation to a recruitment-related purpose.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
- To ensure the physical safety of natural
- For short term transient
- To perform services on behalf of A&M.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by A&M, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by A&M.
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
6. Categories of Personal Information We Have Sold or Shared
We do not sell or share application-related personal information and have not done so in the preceding 12 months. Without limiting the generality of the foregoing, we do not sell or share personal information about California residents who are under 16 years old.
7. Your California Privacy Rights
Subject to certain exceptions and conditions, you have the following rights:
- The right to know what personal information we have collected about you, including the categories of personal information; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information; and the categories of third parties to whom we disclose personal information. We make this information available to you by providing it within this California Recruitment Privacy Notice.
- The right to access the specific pieces of personal information we have collected about
- The right to delete personal information we have collected from
- The right to correct inaccurate personal information that we maintain about
- If we sell or share personal information, the right to opt-out of the sale or sharing of your personal information. (As we explain in Section 6 (“Categories of Personal Information We Have Sold or Shared”), above, A&M does not sell or share employment-related information).
- If we use or disclose sensitive personal information for reasons other than those set forth under the CCPA, the right to limit such use or disclosure of sensitive personal information. As we indicate in Section 5 (“Categories of Personal Information We Have Disclosed for a Business Purpose”), A&M does not use or disclose sensitive personal information for such other
- The right not to receive discriminatory treatment by A&M for the exercise of privacy rights conferred by the CCPA, including a job applicant’s right not to be retaliated against for exercising any of these CCPA rights.
To exercise any of the above-specified rights, you or your authorized agent can contact us by any of the following methods:
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Email (to A&M Talent Acquisition) |
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Online (Data Subject Access Request form) |
Click here |
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Telephone (toll-free): |
1-888-914-9661; PIN 680187 |
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to or deleting your personal information or otherwise complying with your request. We may require you to provide certain information, including: (a) name, (b) postal address, (c) email address, (d) telephone number, and (e) the nature of your relationship with us. In addition, if you ask us to provide you with specific pieces of personal information or to delete information that we deem to be sensitive, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
If you designate an authorized agent to exercise your CCPA rights on your behalf, we may require proof (your signed permission) demonstrating that you authorized the agent to act on your behalf; and, further, we may require you to verify your own identity and confirm that you authorized the agent to submit the request on your behalf. We may deny any request submitted by an agent that does not meet these requirements.
We may charge you a fee, where permitted by law; however, we will notify you of any fee in advance. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or that we have destroyed, erased, or made anonymous in accordance with our record retention policies and practices. If we cannot honor your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
8. Retention of Personal Information
We may retain your personal information for as long as reasonably necessary to fulfill the purposes for which we collected it. Typically, we will retain your personal information for the duration we are considering your candidacy or application. If your candidacy or application is successful, we will retain and use your personal information in accordance with any employment-related privacy notices we provide to you. If your candidacy or application is unsuccessful for any reason, we will retain your personal information for purposes of maintaining a record of our recruitment decision, and to consider you for future opportunities (provided you may request deletion from our candidate pool at any time by contacting us as specified below).
We will retain your personal information for the longer of the applicable statutes of limitations (to enable us to establish, exercise or defend against legal claims) or any mandatory periods specified by applicable laws (including but not limited to labor and employment laws).
Following these retention periods, we will securely destroy your personal information in accordance with our deletion policies and procedures.
Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
9. Changes
We may update this California Recruitment Privacy Notice from time to time at our discretion.
If we intend to use your previously collected personal information for a new purpose that is incompatible with the business or commercial purposes described in this California Recruitment Privacy Notice or at the time of collection, we will provide you with additional notice and, if legally required, seek your consent.
10. Contact Us
For any questions or concerns about this California Recruitment Privacy Notice, you may contact us by any of the following methods:
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Email (to A&M Talent Acquisition) |
Last updated: April 1, 2024
Be on the alert for Fake Job or Hiring Scams. For information on how to spot and protect yourself against scams, and what you should do if you think you’ve been a victim of a scam, please review the Public Service Announcement issued by the U.S. Federal Bureau of Investigation, available here.
