Effective December 26, 2019.
This Privacy Notice for California Residents applies solely to employees, contract employees (“contractors”) and employee applicants who are California residents that meet the definition of Consumer under the California Consumer Privacy Act of 2018 (CCPA) (”consumers” or “you”). We adopt this notice to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this notice.
Overview
The CCPA is a comprehensive new consumer protection law set to take effect on January 1, 2020. It requires companies to inform consumers about the personal information that they collect and share, and gives them a right to access their information, to request deletion of their information, and to opt-out of having their information sold.
Until January 1, 2021, employee personal information is outside of the scope of the CCPA requirements, except for:
- The right to know, at or before the point of collection, the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. Section 798.100(b)
- The right of private action in the event of a negligent data breach. Section 1798.150
This temporary exemption covers information collected in the course of the individual’s acting as a job applicant, employee, officer, director or contractor of Hydrite, to the extent that Hydrite uses such information in the context of the individual’s role (or former role) as an applicant, employee, etc. This includes emergency contact information and information necessary to administer benefits that an applicant, employee, etc. provides (which could include information about another individual who is the emergency contact or benefit recipient), so long as it is only used for that purpose.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:
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Category
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Examples of Data
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Collected
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A. Identifiers.
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A real name, Internet Protocol address, email address, or other similar identifiers.
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YES
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B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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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. Some personal information included in this category may overlap with other categories.
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YES
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C. Protected classification characteristics under California or federal law.
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Age, race, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
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YES
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D. Commercial information.
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Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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NO
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E. Biometric information.
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Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
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NO
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F. Internet or other similar network activity.
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Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
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YES
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G. Geolocation data.
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Physical location or movements.
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YES
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H. Sensory data.
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Audio, electronic, visual, thermal, olfactory, or similar information.
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YES
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I. Professional or employment-related information.
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Current or past job history or performance evaluations.
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YES
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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)).
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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.
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NO
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K. Inferences drawn from other personal information.
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Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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NO
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Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you or your agent. For example, from documents or forms that you may provide to us related to participating in Hydrite’s health or retirement benefit programs or the job position for which you are applying.
- Indirectly from you or your agent. For example, from evaluating your performance in your job position or the job position for which you are applying.
- Directly and indirectly from your activity from your electronic activity on our Site (www.Hydrite.com), on our network or your use of an online application or business system provided by Hydrite. For example, browsing history when you visit a website while on Hydrite’s network or use Hydrite email.
- From third party Service Providers that provide services to us in connection with our business operations. For example, employee drug testing program administrators or employment applicant contact information from our applicant tracking system provider.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- to evaluate an employment application;
- determining eligibility for employment;
- administering pay and benefits;
- processing employee work-related claims;
- establishing training and/or development requirements;
- conducting performance and goal reviews;
- assessing qualifications for a job or task;
- gathering evidence for disciplinary action or termination;
- establishing a contact in the event of an emergency;
- reporting on company metrics;
- compiling directories;
- complying with applicable labor or employment statutes;
- ensuring the security of company-held information; and
- other purposes as are reasonably required by Hydrite.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We do not and will not sell your personal information. So, we do not offer an opt-out to the sale of personal information.
Sharing Personal Information
We may share your personal information solely for a Business Purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category C: Protected classification characteristics under California or federal law
Category F: Internet or other similar network activity.
Category G: Geolocation
Category H: Sensory
Category I: Professional or employment-related information
We disclose your personal information for a Business Purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold or leased any personal information. Hydrite does not sell or lease personal information.
Changes to Our CCPA Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make material changes to this privacy notice, we will post the updated notice in the Hydrite Hub, update the notice’s Effective Date above and request employee acknowledgment by electronic review and sign-off.
Contact Information
If you have any questions or comments about this notice, complete an inquiry form, send an email to Hydrite’s Information Security Council at info@hydrite.com, leave a private voicemail message at 1-844-368-3051, or send a written inquiry to:
Hydrite Chemical Co.
Attn: Information Security Council
17385 Golf Parkway
Brookfield, WI 53045