Effective Date: April 21, 2025
 

PURPOSE

EMS Management & Consultants, Inc (“EMS|MC”) is committed to protecting your privacy. This Applicant Privacy Policy explains how we collect, use, share, and safeguard the personal information of applicants and candidates during the recruitment process. It also outlines your rights regarding your information under applicable data protection laws such as the California Consumer Privacy Act (CCPA).
 

SCOPE

This policy applies to personal information collected and processed by or on behalf of EMS|MC from individuals applying for employment with us, whether submitted through our online recruitment system, via email, through third-party recruiters, or in person.

 

COLLECTED DATA

Depending on your specific interactions with us, we may receive and use the following information about you: 

• Application Information. If you submit a physical or electronic application for employment using a website, recruitment portal, via email, or otherwise, we will collect the personal information contained in your application. This generally includes information contained in your resume/CV, such as: name, contact information, work experience, educational history, references, qualifications, country of origin or residency.
• Sensitive Personal Information. Where permitted by law, you have the option to provide personal information that is considered “sensitive” under some circumstances, such as: race or ethnic origin. We collect this information for equal opportunity monitoring purposes. You will not be discriminated against, whether you decide to provide this information or not. In addition, if you provide health information related to disabilities or work restrictions, we will also collect this information so that we may make the appropriate accommodations and arrangements.
• Location Data. We may collect information related to your geolocation based on your IP address (when submitting information online) and in your stated address or place of residency.
• Professional Work History. We gather information about your work history and professional experience (such as certifications, specialties, and awards) if you provide it to us. We may also gather information about your work history from references you provide. 
• Education Information. If you provide information pertaining to your education history, we will collect this information. 
• Interview and Assessments. As part of the application process, we will collect information during interviews and assessments with you and others (such as recruiting partners and references) about you. We will collect responses and information you provide as part of assessments and interviews. 
• Internet/Electronic Network Activity Information. If you access or use our website, recruitment portal, physical facilities, or video conferencing platforms, those systems automatically collect information associated with your use, such as your IP address, browser and device identifiers, information associated with cookies and other tracking technologies, and other information regarding your usage of such systems, such as access/exit times and locations, check-in status, and signature (for sign-in purposes).
• Information from Third Parties. We may receive information from third parties associated with your application process. For example, we may receive your resume or application from a recruitment partner, references from your former employers, transcripts from universities you attend, and other information.
• Background Check Information. Certain applicants may be subject to pre-employment background checks as part of the onboarding process. As part of this process, we may receive information from third-party background check providers related to your criminal records, verifications for employment qualifications, finances, and other matters. Background checks, credit checks, and other investigatory checks will be conducted to the extent permitted by and consistent with applicable law. Background check information may not be subject to the CCPA. 
• Information Required for Legal Compliance. If we are required by law to obtain personal information about you, such as right to work, tax, familial status, etc., we will collect such information in accordance with our legal obligations and applicable law.
• Onboarding Information. Successful applicants who are offered employment with EMS|MC will undergo onboarding which will result in collection of more personal information related to the provision of employment, including tax information, Social Security Numbers, government ID numbers, right to work information (if required/permitted by local law), emergency contact information, familial information, and similar personal information associated with employment at EMS|MC. Additional notices regarding data collection and use practices will be provided at the time of onboarding. 

For purposes of compliance with the CCPA, in the past twelve months, EMS|MC has collected the following categories of personal information from Applicants (as described in more detail, above): (1) identifiers; (2) characteristics of protected classifications under California or federal law; (3) internet or other electronic network activity information; (4) geolocation data; (5) audio, electronic, and visual information; (6) professional or employment-related information; (7) education information; (8) sensitive personal information.  

 

PURPOSE OF DATA COLLECTION

We use your personal information for the following purposes:

• To assess your qualifications for employment
• To contact you during the hiring process
• To conduct interviews and assessments
• To process background checks
• To comply with legal or regulatory obligations
• To establish or defend legal claims and allegations
• To enforce our company policies
• To maintain records of the recruitment process 

DATA SHARING AND DISCLOSURE

We may share your personal information with:

• Internal personnel involved in the recruitment and hiring process
• Third-party service providers who support our recruitment (e.g. recruiting firms, background check providers) and business operations (e.g., IT operations providers, professional service providers)
• References provided by you, including past employers and educational institutions
• Legal or regulatory authorities, if required
• Legally required parties, such as pursuant to a subpoena or court order
• Reorganization recipients, such as persons involved in the consideration, negotiation, or completion of a business transaction (such as the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration)
• Authorized recipients, with your consent 

DATA RETENTION

We retain your personal data only as long as necessary fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider: (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements. In some circumstances, you may ask us to delete your personal information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
 

YOUR RIGHTS

Subject to applicable laws, you may have the right to: 

• Know: The right to know what personal information EMS|MC has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom EMS|MC discloses personal information, and the specific pieces of personal information EMS|MC has collected about you.
• Correction: The right to correct or update your personal information maintained by EMS|MC.
• Deletion: Request deletion of your personal information, subject to certain exceptions.
• Opt out of the sale or sharing: If we sell or share your personal information, the right to opt out of such sale or sharing.
• Limit the use of sensitive personal information: If EMS|MC uses or discloses sensitive personal information for reasons other than those permitted by the CCPA, the right to limit the use or disclosure of sensitive personal information by EMS|MC.
• Non-discrimination: The right not to be discriminated against for exercising any of the rights conferred by the CCPA.

EXERCISING YOUR PRIVACY RIGHTS

Applicants who are California residents may submit privacy requests themselves or using an authorized agent. Some requests are subject to our verification measures which vary depending on the type of request made and the sensitivity of the information you request. We may ask you to provide a few pieces of information to confirm your identity in our records. If you authorize an agent to submit a request on your behalf, we may require the agent to provide proof that you gave the agent signed permission to submit the request and may verify the agent’s identity and authority to act on your behalf.  

• Submitting Access, Deletion, and Correction Requests: To make an access, deletion, correction, or limitation request, please email us at HumanResources@emsmc.com.
• Limiting the Use of Your Sensitive Personal Information: Californians have the right to limit a business’s use or disclosure of sensitive personal information. However, EMS|MC does not use or disclose sensitive personal information of applicants for any purpose other than for permissible purposes under the CCPA.
• Opting Out of the Sale/Share of Your Personal Information: EMS|MC does not sell or share personal information related to the applicant relationship. 

DATA SECURITY

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Periodically, our operations and business practices are reviewed for compliance with policies and procedures governing the security, confidentiality, and quality of our information. In general, our business practices limit employee access to confidential information and limit the use and disclosure of such information to authorized persons, processes, and transactions.
 

UPDATES

We may update this Applicant Privacy Policy from time to time. If we make material changes, we will notify you by revising the date at the top of the Applicant Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our career portal or sending you a notification).

 

CONTACT US

If you have questions about this policy or how we handle your information, contact us at: HumanResources@emsmc.com