Privacy Policy

for California Job Applicants

Last Updated: April 22, 2024

This Privacy Policy (“Privacy Policy”) describes how Path2Response, LLC and its subsidiaries and affiliates (collectively, “Path2Response”, “we”, “us,” and “our”) may collect, use, retain, and disclose personal information about California residents who apply or are recruited for a job with us or one of our affiliates (“candidates”), and their rights with respect to their personal information.

This Privacy Policy does not govern the general collection and privacy practices of any job boards or websites or online services where our job openings may be posted, including any third-party job search, recruiting, or career networking websites or online services. For example, when you visit the “Careers” section of the Path2Response website and click to see our open positions, you will be redirected to a third-party recruiting platform. Path2Response does not control how third-party websites or online services collect, use, or share your personal information when you visit those services. We encourage you to read the privacy policies of any websites and online services you engage with to understand how your personal information collected through such website or online service may be processed.

For purposes of this Privacy Policy, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) but excludes information exempted from the CCPA’s scope.

This Privacy Policy does not create or form part of any employment contract.

If you have questions about this Privacy Policy or to exercise your privacy rights under the CCPA, please contact legal@path2response.com.

1. Personal Information We Collect About Candidates

Categories of personal information

The categories of personal information we may collect, or have collected in the 12 months preceding the “Last Updated” date of this Privacy Policy, and process before, during and after the application or recruitment process include:

Qualifications, such as professional history, references, language proficiencies, professional qualifications, references, or information made publicly-available through job search or career networking sites.
Immigration status and other information that would allow us to verify your employment eligibility
Job application materials, such as the responses and other details you submit with your application, resume or CV, cover letter, writing samples, references, work history, whether you are subject to prior employer obligations, information that referrers provide about you, or information necessary to complete background checks, drug and/or alcohol tests, and other screens permitted by law.
Job preferences, such as desired position and compensation, location preferences, or willingness to relocate.
Information from the application process, such as any phone-screens, interviews, evaluations, or outcomes of recruiting exercises.
Other information you provide to us, such as any communications you send to us via email or otherwise when reaching out about our company or open positions.

Audio, electronic, visual, or similar information, such as information about your access to offices and facilities (e.g., security camera footage) or recordings of web-based interviews.
Education information and education records directly related to you and maintained by an educational institution, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Providing personal information is voluntary. However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer, or relocation.

In certain cases we may ask you for additional information for purposes of monitoring equal opportunity or complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

To the extent that we collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to perform HR activities such as payroll and benefits, monitor for security incidents, and for compliance and safety purposes). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California employees.

Sources of personal information

We collect personal information directly from you when you apply for a job and throughout the job application or recruitment process.

We may also collect your personal information from various other sources and combine it with the personal information you provide to us. For example, we may collect your personal information from:

job board websites you may use to apply for a job with us and other service providers involved in the recruitment process;
employment agencies, recruiters, or other individuals who may refer you to us;
prior employers, when they provide us with employment references;
professional references that you authorize us to contact;
pre-employment screening providers, such as providers of background check, credit check, or other screening services (where permitted by law);
your public social media profiles or other publicly available sources;
Path2Response personnel.

2. Purposes of the Collection and Use of Personal Information

We may use the categories of personal information described in this privacy policy for the following business purposes or as otherwise described at the point of collection:

recruiting, interviewing and evaluating candidates;
performing background checks and other pre-employment screening (where permitted by law);
analyzing and improving our application and recruitment process, including improving equity, inclusion, or diversity;
accommodating disabilities or health conditions;
communicating with you regarding your candidacy and opportunities with Path2Response; and
other activities involved in our recruitment and selection processes.

Compliance, safety, and fraud prevention. Complying with legal and other requirements, such as tax, audit, recordkeeping, reporting, verifying identity and eligibility to work, and equal opportunities monitoring requirements; complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities; protecting our, your or others’ rights, safety and property; investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and sharing information with government authorities, law enforcement, courts or private parties for the foregoing purposes.
Research and Development. Creating anonymous, aggregated, or de-identified data that we use and share to analyze our workforce and business and for other lawful business purposes.
With Your Consent. We will use and disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

3. Disclosure of Personal Information

We may disclose, and during the 12 months preceding the “Last Updated” date of this Privacy Policy may have disclosed, each of the categories of personal information described in Section 1 with other parties as necessary for the business purposes described above or as described at the time of collection, including the following persons or entities:

Affiliates. Our corporate parent, subsidiaries, or other affiliates under the control of our corporate parent, for purposes consistent with this Privacy Policy or to operate shared infrastructure, systems, and technology.
Path2Response service providers. Providers of services to the Path2Response that help us manage the recruitment process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety, and fraud prevention section above.
Business transfer participants. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Professional advisors. Accountants, auditors, lawyers, insurers, bankers, or other outside professional advisors who require your information in the course of providing their services.

We do not and, during the 12 months preceding the “Last Updated” date of this Privacy Policy, have not “sold” or “shared” personal information about candidates. Further, we do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

4. Retention of Personal Information

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

5. Your California Privacy Rights

California employees may exercise the rights listed below by contacting us as described at the beginning of this Privacy Policy. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

the categories of personal information that we have collected.
the categories of sources from which we collected personal information.
the business or commercial purpose for collecting, selling, or sharing (if applicable) personal information.
the categories of third parties with whom we disclose personal information.
a copy of the personal information that we have collected about you.

To submit a request, please contact us using the contact information at the top of this Privacy Policy.

We may need to confirm your identity to process your requests to know/access, delete, or correct. In addition, consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

6. Third Party Services

This Privacy Policy does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements.

7. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. The “Last Updated” date at the top of this Privacy Policy indicates when it was last revised. Any changes will become effective when we post the revised Privacy Policy in the respective job posting.

8. Your Obligations

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with Path2Response up to date and inform us of any significant changes to it.