Privacy Notice for California Residents – Employees

Privacy Notice for California Residents-Employees

Effective Date: January 1, 2020 (although certain rights granted by the CCPA will not be effective until a later date as defined in the CCPA).

Last Reviewed on: May 21, 2020

360 Behavioral Health (which for purpose of this Notice includes California Psychcare, Inc., Behavior Respite in Action, Inc., Respite Works Inc., Z & S Management Corporation, and all other affiliates that may be acquired from time to time) and its affiliates and subsidiaries (“Company,” “we,” “us,” or “our”) provides this Privacy Notice for California Residents-Employees (also referred to as the “CCPA Employee Privacy Notice”) to supplement the information contained in the 360 Behavioral Health Privacy Policy (available at www.360behavioralhealth.com). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

The CCPA Employee Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). We provide you this notice because under the CCPA, California Residents who are employees, employee applicants, or contractors qualify as Consumers. For purposes of this CCPA Employee Privacy Notice, when we refer to Consumers, we mean you to the extent you are a California employee, employee applicant, or contractor.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). We may collect personal information from you in a variety of different situations, including, but not limited to, on our website or third-party websites, your mobile device, through email, through company property, in physical locations, through the mail, and/or over the telephone. Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • 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;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

Category

Examples

Collected

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

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.
Some personal information included in this category may overlap with other categories.

YES

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

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

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.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

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

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from our interactions, forms you complete, or services we provide you.
  • Indirectly from you. For example, from observing your actions on our Website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
  • Third parties. For example, staffing and recruiting agencies with whom we contract for services, training or healthcare providers, and consumer reporting agencies when we perform employee background screenings or exclusion checks.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, apply for a job, or become an employee, we will use that personal information to respond to your inquiry.
  • For workforce management. Such as to process payroll and manage applicable tax withholding and reporting, determine employment or benefit eligibility, comply with state and federal laws requiring employers to maintain certain records, to conduct performance related reviews, background checks and healthcare exclusionary screenings, assess qualifications, or for emergency response.
  • To monitor work-related licenses and credentials, ensuring compliance, training, examination, and other requirements are met with applicable regulatory bodies and contractual requirements.
  • To provide services to our other consumers, such as determining case assignments.
  • To contact you and to inform you about benefits or information relating to your employment or potential employment.
  • To provide, support, personalize, and develop our Website and services.
  • To create, maintain, customize, and secure your employee profile with us.
  • To process your requests and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For research, analysis, and business development, including to develop and improve our Website, and services.
  • To respond to public health and government enforcement requests and as required by, and to comply with, applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To assist the safety of our clients, workforce, offices, and public health.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users or consumers is among the assets transferred.

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.

Sharing Personal Information

We may disclose your personal information to a third party 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.
We share your personal information with the following categories of third parties:

  • Service providers.
  • Third parties with whom you direct us to share your personal information.
  • Other third parties such as consumer reporting agencies when we perform employee background screenings or exclusionary checks, or to our information technology vendor for IT maintenance and security.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has 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 E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website, update the notice’s effective date, post to the Company policy library, and request employee acknowledgment by electronic review. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 800-472-9071
Website: www.360behavioralhealth.com
Email: Compliance@360bhmail.com
Postal Address:
360 Behavioral Health
Attn: Legal & Compliance Department
9201 Oakdale Avenue, Suite 101
Chatsworth, CA 91311