Carlton Senior Living: CALIFORNIA NOTICE AT COLLECTION TO EMPLOYEES/JOB APPLICANTS
Carlton Senior Living, its affiliates, and related companies (collectively, “Carlton”) (“we” or the “Company”) take your privacy very seriously. If you have any questions or concerns about how we collect or maintain your personal information, please feel free to contact us at info@carltonseniorliving.com or (800) 227-5866.rnrnThe purpose of this Notice at Collection (the “Notice”) is to inform you of the categories of personal information we collect about you and to advise you of your rights under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”). Please note that this Notice applies to you as an employee or job applicant of the Company; if you are also a resident or other consumer of the Company, please refer to our customer-facing Privacy Policy on our website at https://www.carltonseniorliving.com/privacy-policy/ for your rights as a consumer.
Categories of Personal Information We Collect
Below is a chart that lists the categories of information that we have collected about our employees and job applicants over the last 12 months. Please note that categories of “sensitive” personal information, as that term is defined by the CCPA/CPRA, are labeled as such in the individual category. This chart also provides the sources from which we obtained this information, our purpose for obtaining the information, our retention period for that information, and the reasoning behind that retention period.
| Categories of Information | Source(s) | Purpose(s) | Retention Period and Reasoning |
|---|---|---|---|
| Personal identifiers: full name and sensitive personal information such as Social Security number and driver’s license number | The employee/job applicant when completing job application or other employment forms; the employee when logging onto the Company’s medical software/programs | To begin and maintain the employment relationship; to provide care to residents | For employees: seven years from the date of termination, to comply with our obligations under the law; for job applicants: seven years from the date the application was submitted, to comply with our obligations under the law |
| Non-sensitive personal information: telephone number, mailing address, medical insurance information | The employee/job applicant when completing job application or other employment forms; the employee when logging onto the Company’s medical software/programs | To begin and maintain the employment relationship; to provide care to residents | For employees: seven years from the date of termination, to comply with our obligations under the law; for job applicants: seven years from the date the application was submitted, to comply with our obligations under the law |
| Characteristics of protected classes under state or federal law | The employee/job applicant | EEOC Reporting | For employees: seven years from the date of termination, to comply with our obligations under the law; for job applicants: seven years from the date the application was submitted, to comply with our obligations under the law |
| Internet/network activity information (e.g. browsing history) | Company-owned devices, including cell phones and laptops | To monitor employee work activity | Five years from the date of the activity, to support our compliance with legal obligations and security purposes |
| Geolocation data (e.g. device location from usage of our devices) | Company-owned devices, including cell phones and laptops | To prevent theft; to monitor employee work activity | Five years from the date of the activity, to support our compliance with legal obligations and security purposes |
| Biometric information (e.g. from on-location COVID-19 temperature screening) | The employee, when utilizing the Company’s time clock or temperature screening | Time and attendance tracking; COVID-19 screening | Five years from the date of the activity, to support our compliance with legal obligations and security purposes |
| Audio or visual information | The employee/job applicant when completing the Company’s employment forms or in an area of the facility under A/V surveillance | To facilitate the employment relationship; to maintain resident safety | For employees: seven years from the date of termination, to comply with our obligations under the law; for job applicants: seven years from the date the application was submitted, to comply with our obligations under the law |
| Professional or employment information (e.g. employment history | The employee/job applicant | For hiring/human resources purposes | For employees: seven years from the date of termination, to comply with our obligations under the law; for job applicants: seven years from the date the application was submitted, to comply with our obligations under the law |
| Non-public education information | The employee/job applicant | For hiring/human resources purposes | For employees: seven years from the date of termination, to comply with our obligations under the law; for job applicants: seven years from the date the application was submitted, to comply with our obligations under the law |
Disclosure of Personal Information to Third Parties
The following chart lists the categories of information that we have collected about our employees and job applicants over the last 12 months that we have shared with third parties. We do not sell your personal information.
| Categories of Information | Categories of Third Parties with Whom Information is Shared | Purpose(s) for Sharing the Informatio |
|---|---|---|
| Personal identifiers | Payroll provider; third-party software used to provide resident care; benefits broker | To facilitate payment of wages to employees and comply with the Labor Code; to provide care to residents; to facilitate enrollment in benefits |
| Non-sensitive personal information | Third-party employee engagement app | To facilitate communication and engagement with employees |
Your Rights Under the CCPA and CPRA
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- The right to know what personal information we have collected about you, including categories and specific pieces of personal information;
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- The right to correct any inaccurate personal information we may have about you;
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- The right to request deletion of your personal information, subject to a number of exceptions that may restrict our ability to delete the information;
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- The right to opt-out of the sale or sharing of your personal information;
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- The right to limit the use and disclosure of your sensitive personal information;
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- The right to opt-out of automated decision-making technology; and
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- The right to not be discriminated or retaliated against for exercising any of these rights.
How to Submit a Request Under the CCPA and CPRA
If you would like to submit a request to exercise any of the above-listed rights, you may do so by emailing info@carltonseniorliving.com or calling (800) 227-5866. If you have any questions or concerns about this policy or the CCPA/CPRA, please contact us at info@carltonseniorliving.com or (800) 227-5866.rnrn