Notice At Collection & Privacy Policy for Applicants, Employees and Contractors

Under the California Privacy Rights Act (CPRA), California residents may be entitled to certain notices and disclosures regarding the collection, use and storage of the Personal and/or Sensitive Information obtained from job applicants (“Applicants”) when applying for or employment or contract work at The Shift Network (“Company”), and from those hired as staff (“Employees”), or independent contractors, (“Contractors”).

Categories of Personal/Sensitive Information Collected from Applicants:

The Company may collect some or all of the following personal identifiers directly from Applicants when using our online application process, or indirectly when interacting with our sites or webpages, including on any 3rd party sites where job postings may be listed:

  • Name
  • Email address
  • Contact phone number
  • Home and/or mailing address
  • LinkedIn email or profile address
  • IP address
  • Data from cookies or web beacons or tags

Additionally, the Company may collect any or all of the following professional or employment related data directly from Applicants using our online application process, including follow-up emails and Applicant screening interviews:

  • Applicants resume and/or CV and all information listed therein
  • Employment and work history
  • Preferred salary or salary range
  • Descriptive information regarding skills, areas of expertise, and/or experience with or related to management, platforms, technologies and processes
  • Education, certifications, degrees or other training
  • Qualifications and ability to perform the advertised work and stated duties
  • Optional information such as affiliations, clubs, associations, memberships, interests and activities that Applicant may choose to provide on resume/CV
  • Contact information (name, email address, contact phone number) and other information (work and position history related to Applicant), provided to Company when submitting Applicant’s Professional References

In certain scenarios related to the hiring process, the Company may also collect or verify one or more of the following categories of Personal and Sensitive Information provided directly by Applicants or obtained when interacting with Applicant’s references, obtained from 3rd party data providers, or obtained when providing access to Company email and platforms:

  • Employment history verification
  • Education and degree verification
  • Criminal history records
  • Credit reporting agency records
  • Date of Birth
  • Social Security number
  • Driver License
  • Passport
  • Green Card
  • Work Visa Information
  • I-9 or W-9 information
  • Direct Deposit information
  • Health Insurance and FSA information
  • Beneficiary information
  • 401K Election information
  • Login credentials
  • Emergency contacts

The Company may also collect one or more of the following types of Personal and Sensitive Information provided directly by its Employees:

  • Legal name, preferred and/or nickname
  • Preferred pronouns
  • Gender and/or gender identity
  • Marital Status
  • Names and birthdates of children
  • Bio information for sharing with staff or to list on company site
  • Photograph and/or headshot
  • Racial or ethnic origin
  • Religious or philosophical beliefs

The Company may also collect one or more of the following types of Employee performance related information or data regarding fulfillment of contract by Contractor, either directly or from managers, colleagues and Company records:

  • Production records such as KPIs or other metrics
  • Performance review information
  • Reports from managers, colleagues, HR, faculty, contractors, vendors or customers
  • Data collected electronically when staff use our websites and platforms, such as history of login and activity performed while using the platform

Intended Purposes for Collecting Personal/Sensitive Information from Job Applicants, Employees and Contractors:

One or more of the following intended purposes of collection of Personal and Sensitive Information from Applicants, Employees and Contractors may apply:

  • Receiving applications, resumes and CVs for open or future positions
  • Reviewing applications, resumes and CVs to evaluate qualifications and fit
  • Contacting Applicants to respond to applications, to notify Applicants if position has been filled or to arrange for interviews
  • To schedule additional interviews with Applicant, respond to Applicant’s questions, to release from candidate pool, or to make an offer of employment or contract
  • Evaluation and confirmation of credentials such as work history, experience, education, management and executive qualifications
  • Receiving forms as required by law, such as W-4 forms or I-9 forms, and all other required documents when hiring employees
  • Verification of qualifications to accept and perform contract work and related forms such as W-9.
  • For quotation and policy administration of benefits provided to employees, such as health insurances, 401K contributions, life insurance, stock option grants, employee assistance programs, flexible spending accounts, FMLA, workers comp, claim processing and to process payroll including physical paychecks and/or direct deposits
  • To reach emergency contacts of employees in the event of an emergency or to execute beneficiary directives as established by an employee for distribution of assets such as life insurances, 401K, etc. in the event employee becomes deceased
  • Personal and Sensitive Information when and as required by law such as when reporting wages or payments on annual W2s or 1099s, and other government-mandated reporting
  • To evaluate performance and efficacy of employees and positions, and to keep records related to training such as Harassment Prevention Training as required by law
  • To document personnel investigations and interview related to issues, challenges, allegations of harassment, allegations of illegal activities or fraudulent behaviors, as needed to legally conduct business in compliance with city, state and federal laws
  • Providing access and login credential to Company platforms such as email, Slack, eCommerce platform, accounting software or any other platform necessary for the execution of duties
  • Compliance and security monitoring, screening and or auditing of risk factors

Selling or Sharing of Personal/Sensitive Information Collected from Applicants:

The Company never sells Personal or Sensitive Information of Applicants, Employees or Contractors. The Company does not share Personal or Sensitive Information of Applicants, Employees or Contractors for the purpose of cross-context advertising.

Sharing of Personal or Sensitive Information may occur in one or more of the following instances related to business administration or legal requirements:

  • Health Insurance providers and reporting agencies
  • Group Life Insurance Providers
  • Workers Compensation Insurance
  • Disability Insurance Providers
  • Paid Family Leave Providers
  • 401K third party administrators and Trustee providers
  • Payroll service providers
  • IRS or other government agencies as required by law
  • Name, email address, phone, title and job description may be shared with other staff, colleagues and faculty as needed for performance of duties
  • External auditing, accounting and tax preparation firms
  • Governance or law enforcement bodies in instances of alleged criminal behavior
  • Requests made by a court of law

Intended Retention Period or Retention Criteria for Personal/Sensitive Information Collected from Applicants, Employees and Contractors:

The intended retention period for data collected for job Applicants varies but in general it is kept until no longer needed for evaluation of position qualifications, or indefinitely if the candidate is being considered for future positions.

The criteria we use to determine the intended retention period for data collected regarding Employees and Contractors is complex and varied, but in general data is retained as long as needed to fulfill legal obligations and mandatory reporting and record-keeping requirements, to satisfy applicable statute of limitation periods, to operate the business, to protect the benefits of the Employee, or for other legitimate business purposes as delineated in applicable privacy laws.

When an Applicant, Employee or Contractor’s Personal or Sensitive Information is no longer needed, it may be securely destroyed or it may be de-identified and aggregated for analytics purposes, per the guidelines of the CPRA.

Exercising of Rights of Job Applicants, Employees and Contractors:

Under the California Privacy Rights Act (CPRA), valid California residents that are Applicants, Employees and Contractors of the Company have the rights to request one or more of the following, (subject to certain exclusions per CPRA policy):

  • Deletion of Personal or Sensitive Information
  • To have inaccurate Personal or Sensitive Information corrected
  • To access their Personal Information that the Company has collected
  • To know what Personal or Sensitive Information is sold or shared and to whom
  • To opt out of the sale or sharing of Personal or Sensitive Information
  • To limit the use or disclosure of certain Personal or Sensitive Information

Applicants, Employees and Contractors have the right to not be retaliated against for exercising these rights under the law.

Applicants, Employees and Contractors who wish to submit requests in accordance with the above mentioned rights, may do so by emailing HR@theshiftnetwork.com or by calling toll free 1-(866) 230-2326. Requests will be responded to in a timely manner in accordance with CPRA guidelines.

12-Month Lookback:

The Company updates its Privacy Policy for Applicants, Employees and Contractors at least once every 12 months to disclose the categories of Personal and Sensitive Information collected during the preceding 12-month period and the sources from which such information was collected, the purposes for the collection thereof and the categories of 3rd party providers to which Personal and Sensitive Information may be disclosed.

The above is in addition to the Company’s general Privacy Policy.

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