Legal
California Employee and Candidate Privacy Notice
AIRSHIP GROUP, INC. “AIRSHIP”
JOB APPLICANT AND EMPLOYEE PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last Updated: July 1, 2023
1. PURPOSE OF THIS NOTICE
1.1 This Job Applicant and Employee Privacy Notice for California Residents (“California Employee Privacy Notice”) details the Personal Information (defined below) Airship Group, Inc. a corporation established in Delaware with a principal place of business at 1225 West Burnside Suite 401, Portland, Oregon 97209, and our affiliates and subsidiaries, (collectively “Airship”, “we”, “us”, or “our”) receives about you and how we process it during the course of your candidacy, job application process and to the extent applicable to you, employment with Airship.
1.2 Airship is committed to protecting the privacy and security of your Personal Information. This California Employee Privacy Notice describes how we collect and use Personal Information about you during and after candidacy, job application, and your employment with us (collectively, your “employment”). It applies to all job applicants and/or candidates, and current and former employees (collectively “employees”) who are California residents.
1.3 This California Employee Privacy Notice does not constitute a contract of employment, and does form part of any contract of employment or other contract to provide services. We may update this California Employee Privacy Notice at any time, but if we do so, we will provide you with an updated copy of this California Employee Privacy Notice as soon as reasonably practicable by either posting to our website here or if you are an Airship employee, via direct notice to you. As for Airship employees, in addition we may provide the updated version with a notice that it has been posted in a central location for easy viewing.
1.4 It is important that you read and retain this California Employee Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are aware of how and why we are using such information about what your rights may be.
1.5 This California Employee Privacy Notice is provided under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), which amended the CCPA, as further implemented by regulations or amended from time to time (the “CCPA”) and applies to Airship job applicants and/or candidates, and employees who are California residents (“California Candidate(s) and Employee(s)”). The CCPA defines “personal information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California resident. Certain information we collect may be exempt from the CCPA / CPRA because it is considered public information (because it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
2. COMPANY CONTACT DETAILS
For questions or complaints regarding our use of your Personal Information or this California Employee Privacy Notice, please contact us at:
E-mail: privacy@airship.com
Mail: Legal Department, 1225 West Burnside Suite 401, Portland, Oregon 97209
3. WHAT INFORMATION DOES THE COMPANY COLLECT ABOUT YOU?
3.1 “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Candidate and Employee. It does not include data that cannot be associated with you or for which identifying elements have been removed (“deidentified information”).
3.2 Identifiers: Airship may collect the following Personal information about you as part of your candidacy, job application process, or employment with Airship:
(a) identifiers such as title, full name, previous names, home and work address, phone number(s), personal email address(es), online identifiers, Internet Protocol address;
(b) bank account details, payroll records, and tax information;
(c) driver’s license number, passport, citizenship/nationality/visa status, or other unique ID number presented for identification purposes and to verify your employment eligibility;
(d) social security number for tax purposes;
(e) health information regarding you and your family, including medical conditions and health sickness records, when you report this information to the company to the extent included in employment related documents or contracts. This includes details of any absences (other than holidays) from work, including time on statutory parental leave and sick leave; information related to biological screenings or testing for controlled substances; records related to administering and maintaining your healthcare and other benefits; information about a condition needed for pensions and permanent health insurance purposes when you leave employment and the reason for leaving is related to your health; and meal preferences and food allergies;
(f) data related to travel for the purposes of the working relationship, including driver’s license details, special meal requests and travel preferences.
3.3 Protected Classifications: We collect your date of birth and gender in order to verify your identity. We collect your marital status and dependents for tax and benefits administration purposes. We also collect and maintain information about your racial and ethnic origin or sexual orientation if you choose to provide it during the job application or employment onboarding process. We use this information only to support our efforts to attract and maintain a diverse workforce, including reporting required by federal law.
3.4 Internet or Other Electronic Network Activity Information: During your employment relationship with Airship, Airship will monitor use of your Airship email account, office messaging systems (including Slack and GSuite), Airship phone lines (including any mobile provided by Airship for your business use), document management systems, online customer databases, and the internet while on Airship systems in accordance with Airship policies. Please refer to the Employee Handbook for more details.
3.5 Geolocation Data: During your employment relationship with Airship, we collect geolocation data about you if, for example, you are operating a company-issued device, such as a company-issued mobile phone, as part of the fulfillment of your employment duties.
3.6 Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information: We store photographs of you for employment identity verification, and we may record you on building security cameras. During your employment relationship with Airship, your telephone calls are monitored or recorded if you are accessing company resources, such as IT services and your calls are monitored or recorded if you are interacting with a customer or member of the public in a customer service capacity on recorded video or phone calls. Information related to use of building access control systems, including time and location of entry and exit, access to restricted zones, and security camera footage data related to access to and usage of office equipment and resources, including but not limited to fixed and mobile phones, computer systems, email, and the internet, office messaging systems (including Slack and GSuite), cost recovery systems, document management systems, contact management systems and online databases. We do not collect any of your thermal, olfactory or similar information.
3.7 Professional or Employment-related Information: Professional and work information and data with respect to the job application or the acceptance of the offer of employment, including proof of eligibility to work and details of any visa or work permit application, travel and relocation information for the purpose of the working relationship, data with respect to career management and development, including date of hire, employee category, full/part-time status, qualifications, references, résumé(s) or curriculum vitae, language(s) spoken, background checks (including education, professional licenses, civil and criminal records, and regulatory matters) and membership of professional bodies, presence and absence (whether due to sickness or otherwise), accident reporting, occupational health information, work schedules, responsible duties, employee ID, time recording, vacation, all types of leave (including but not limited to parental leave), training records, performance evaluations and documents relating to complaints, grievances, disciplinary actions, career progression and promotions, demotions, retirement and termination of employment or engagement and related data including notice periods, reasons for leaving and exit interviews.
3.8 Education Information: Your employment record information you provided during the job application or employment process about the educational institutions you have attended or your level of education. We may also collect and maintain information about any professional licenses you hold, certifications you receive, or additional education or training you undertake during your employment.
4. HOW DOES THE COMPANY COLLECT YOUR PERSONAL INFORMATION?
4.1 We collect Personal Information about employees and job applicants through the application and recruitment process, directly from candidates, employment agencies, and screening services or other background-check providers. We collect additional information from third parties including former employers, credit reference agencies, or other sources that supply employment verification services. To the extent that Personal Information about you is processed for the purposes of equal opportunities monitoring, such Personal Information shall be provided in anonymized form.
4.2 We collect additional Personal Information in the course of job-related activities throughout the period you work for us. This can be in the form of information you provide directly to us or information which we collect automatically about you, such as monitoring computer access and usage.
5. HOW DOES THE COMPANY USE YOUR PERSONAL DATA?
5.1 We will only use your Personal Information as permitted by law. Situations in which we use your Personal Information include:
(a) Decisions related to your employment, including processing your job application or your employment performance; evaluating your development as an employee; setting your job duties and assessing our staffing needs; assessing your qualifications for other roles within the company or promotion; determining salary and compensation; for grievance or other disciplinary procedures, including termination; dealing with legal disputes involving you or other employees and contractors, including accidents at work; and ascertaining your fitness for work.
(b) Business Purposes, including conducting data analytics studies to review and better understand employee retention and attrition rates; and ascertaining and fulfilling education, training, and development requirements.
(c) Administering payments and benefits, including making tax and other required deductions and making decisions about salary and compensation.
(d) Security measures and complying with health and safety obligations, including ensuring the physical safety of our facilities, resources, employees, and other people from threats; preventing fraud and to secure our systems, data, resources, and facilities from unauthorized access or exploitation; monitoring compliance with our IT policies; ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems, and preventing malicious software distribution; and investigating theft and other illegal activities.
(e) Compliance with legal obligations and lawful requests, and your Personal Information will be handled by Airship in accordance with this California Employee Privacy Notice, any applicable Airship Policies (the “Data Policies”) and (a) as required by law, regulation, legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, or by a regulator, bank examiner or self-regulatory organization or pursuant to mandatory ethics rules applicable to Airship or (b) as reasonably required in relation to any claim or investigation pursuant to any law and/or any matter which may lead to such a claim or investigation.
(f) Internal reporting and statistics purposes, we anonymize and/or aggregate data collected through our systems to create statistics that are used for internal reporting and analysis purposes, provided that such statistics do not identify any candidate, applicant, employee or individuals or contain any Personal Information.
5.2 Personal Information relating to your dependents, next of kin, emergency contacts and/or other restricted persons will be processed by Airship for a variety of reasons arising from your employment relationship with Airship, such as the administration of pension and/or retirement plans, compliance purposes and health insurance programs, travel on international assignments or as part of your benefits where applicable, and as a contact in emergency situations. It is your responsibility to inform such persons about the processing of their Personal Information for the described purposes and to confirm that they have given their permission.
5.3 We use any and all of the information collected for any of the purposes described in this California Employee Privacy Notice, unless limitations are listed. In some circumstances we deidentify your Personal Information so that it can no longer be associated with you, in which case we use such information without further notice to you.
6. DISCLOSURE OF YOUR PERSONAL DATA
6.1 We disclose Personal Information that we collect or that you provide to us as described in this California Employee Privacy Notice:
(a) To our affiliates, subsidiaries, and other Airship Group companies;
(b) To service providers, which are companies we use to support our business and who are bound by law and contractual obligations to keep your Personal Information confidential. Service providers use information we share with them only for the purposes for which we disclose it to them and as otherwise permitted by law. The categories of service providers that we share information with are:
- Payroll service providers that assist us in calculating and disbursing your salary and other compensation.
- Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
- Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
- Recruitment vendors that assist with the application process including assessing candidate qualifications and providing the platform through which candidates submit their candidacy.
- Analytics services, including entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers.
- Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
- IT vendors, such as entities that assist with people operations; website design, hosting and maintenance; data and software storage; and network operations systems.
(c) Where Airship is under an obligation to do so by law, it will disclose your Personal Information to regulators, courts, the police or tax authorities, or in the course of litigation or other legal or regulatory matters. In some cases, it may not be reasonably practicable or possible in accordance with law to notify you in advance about the details of such disclosures. Airship will use reasonable efforts to disclose the minimum Personal Information necessary in such cases.
(d) Should a proposed or actual merger, acquisition or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control occur, we transfer your Personal Information as an asset in connection with such proposed or actual transaction.
(e) Personal Information is also disclosed to a third party such as your bank, mortgage company, lender, credit agency, other financial institutions, landlord, prospective employer, relocation company, visa or travel agency, but only with your consent.
6.2 Airship will use all reasonable efforts (i) to ensure that any third-party services providers set forth in Section 6.1(b) protect your Personal Information with appropriate security measures and (ii) to prohibit them from using your Personal Information other than as instructed by Airship.
6.3 As provided below in Section 8.3, we do not sell or share your Personal Information to any third parties. However, we may disclose aggregated or deidentified information without restriction.
7. EMPLOYEE OBLIGATIONS IN RELATION TO THEIR PERSONAL INFORMATION
7.1 It is important that you update us with respect to changes in your personal circumstances as soon as possible by contacting updating Airship’s payroll and benefits systems or contacting the People Operations team. These include changes to the following:
(a) name;
(b) contact details (home address, phone number(s), email address(es));
(c) marital status;
(d) dependents (e.g. for medical insurance purposes);
(e) emergency contacts and next of kin;
(f) bank details for payment of wages; or
(g) professional and educational qualifications.
7.2 IF ANY OF THE ABOVE INFORMATION CHANGES DURING THE COURSE OF YOUR EMPLOYMENT, PLEASE LET US KNOW AT THE EARLIEST OPPORTUNITY SO THAT OUR RECORDS CAN BE UPDATED.
8. HOW TO ACCESS AND CONTROL YOUR PERSONAL INFORMATION: YOUR CALIFORNIA RIGHTS AND CHOICES
8.1 The CCPA and CPRA provide California residents, referred to in the law as “consumers,” with rights to receive certain disclosures regarding the collection, use and sharing of Personal Information, as well as rights to access and control Personal Information.
8.2 To the extent that we collect Personal Information about you that is subject to the CCPA and CPRA, that information, our practices, and your rights are described in the below disclosures:
(a) Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed: You have the right to obtain information regarding the categories of Personal Information we collect, sell, or disclose. That information is provided in this California Employee Privacy Notice. We collect the categories of information described in Section 3 above. The categories we use to describe the information are those enumerated in the CCPA.
| Categories of Personal Information | How We Use It | Sold or Shared |
|---|---|---|
| Identifying information such as your name, gender, date of birth, and signature. | • Decisions related to your job application or employment • Manage your relationship with us (e.g., facilitating meetings, communicating with you, providing you with requested information) • Track an application through the recruitment process • Contact (including by email) you or others on your behalf about suitable job opportunities as they may arise • Contact references with your authorization. • Conduct background checks with your authorization • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Demographic information such as your race, ethnicity, marital status, disability, and veteran or military status. | • Business purposes • Compliance with legal obligations and lawful requests | No |
| Contact information such as your home address, phone number, email address, and emergency contact information. | • Manage your relationship with us (e.g., facilitating meetings, communicating with you, providing you with requested information, evaluating you in the job application process) • Track an application through the recruitment process. • Contact (including by email) you or others on your behalf about suitable job opportunities as they may arise. • Contact references with your authorization. • Conduct background checks with your authorization. • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Dependents’ or other individuals’ information such as their full name, address, date of birth, and Social Security Numbers. | • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| National identifiers such as Social Security Number, passport and visa information, and immigration status and documentation. | • Business purposes • Conduct background checks with your authorization • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Educational and professional information such as your work history, academic and professional qualifications, educational records, references, and interview notes. | • Decisions related to your job application and employment • Manage your relationship with us (e.g., facilitating meetings, communicating with you, providing you with requested information, evaluating you in the job application process) • Track an application through the recruitment process • Contact (including by email) you or others on your behalf about suitable job opportunities as they may arise • Contact references with your authorization • Conduct background checks with your authorization • Business purposes | No |
| Employment information such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records. | • Decisions related to your job application and employment • Manage your relationship with us (e.g., facilitating meetings, communicating with you, providing you with requested information, evaluating you in the job application process) • Track an application through the recruitment process • Contact (including by email) you or others on your behalf about suitable job opportunities as they may arise • Contact references with your authorization. • Conduct background checks with your authorization • Business purposes | No |
| Financial information such as banking details, tax information, payroll information, and withholdings. | • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Health and safety information such as health conditions (if relevant to employment), job restrictions, workplace illness and injury information, and health insurance policy information. | • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Information systems information such as your search history, browsing history, login information, and IP addresses on the company’s information systems and networks. | • Decisions related to your employment • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Geolocation information such as time and physical location related to use of an Internet website, application, device, or physical access to a company office location. | • Business purposes • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Surveillance information such as video call monitoring or video meeting recordings, and office security camera video surveillance. | • Business purposes • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
| Sensitive personal information including Social Security Number; driver’s license number; state identification number; passport number; account log-in; precise geolocation information; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of email and text messages; health-related information; and information concerning sex life or sexual orientation. | • Business purposes • Administering payments and benefits • Security measures and complying with health and safety obligations • Compliance with legal obligations and lawful requests | No |
We determine the retention period for each of the categories of Personal Information listed above based on (1) the length of time we need to retain the information to achieve the business or employment related purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.
(b) Right to Request Access, Correction, and Deletion of Information: You have the right to request access to Personal Information collected about you and information regarding the source of that Personal Information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You also have the right to request in certain circumstances that we delete Personal Information that we have collected directly from you or to correct information that we have collected about you. As noted below, exceptions to these rights may apply.
(c) Right to Information Regarding Participation in Data Sharing for Financial Incentives: We may run promotions from time to time whereby we incentivize an employee to share certain pieces of information with us. Participation in any of these incentives is voluntary, and you may opt out of the data sharing at any time.
(d) Right to Opt Out of Sale of Personal Information to Third Parties: We do not sell or share your Personal Information with third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit and a company “shares” personal information when it discloses personal information to third parties for the purpose of “cross-context behavioral advertising.” A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us.
(e) Right to Limit the Use and Disclosure of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive Personal Information that we use to infer characteristics about you. We do not use sensitive Personal Information to infer characteristics about you.
(f) Exercising Your Rights: Please contact us at privacy@airship.com to exercise these rights if you are a California resident. You may authorize another individual or business registered with the California Secretary of States, called an authorized agent, to make requests on your behalf. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response. We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we have collected from you previously. We may need to follow up with you to request more information to verify identity. We will not use Personal Information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.
9. CROSS BORDER DATA TRANSFERS
9.1 Your Personal Information will be stored and processed in the United States. Airship and its service providers also transfers information that we collect about you, including Personal Information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. These jurisdictions may not have the same data protection laws as your jurisdiction. Wherever your Personal Information is transferred, stored, or processed by us, we will take commercially reasonable steps to safeguard the privacy of your Personal Information.
10. CHANGES TO THIS NOTICE
10.1 Except where expressly agreed as part of an employment contract between you and Airship, this California Employee Privacy Notice will not form part of any potential employment contract. We reserve the right to update this California Employee Privacy Notice at any time. We will post any changes to this California Employee Privacy Notice on this page and as described in Section 1.3 above. Each version of this California Employee Privacy Notice is identified at the top of the page by its version date.
10.2 If you are an Airship employee, we will provide you with a new privacy notice when we make any substantial updates, and we will also notify you in other ways from time to time about the processing of your Personal Information. For Airship employees, any such updated notice will be made available to you by the Airship People Operations team via the internal information systems as described in Section 1.3 above.