PRIVACY POLICY

Assistance For the Disabled: Alternative formats of this form are available to individuals with disabilities. Please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695 for assistance.


The Company's policy (the Policy”) is that the collection, storage and use of employee information must comply with applicable laws in the employee’s Employment State, which is defined in Section 1 below.


1. Employment State. For purposes of this Policy, the employee’s employment state (the “Employment State”) is the state where the employee primarily resides and works for the Company when last employed with the Company, and if the employee’s state of residence is different from the state where the employee is primarily employed to work for the Company (meaning where the employee’s employment is based) then the employee’s Employment State will be the state where the employee’s employment is deemed to be based by the Company.  The employee understands that the employee cannot have more than one (1) Employment State at the same time. The laws of the Employment State will control the interpretation and application of this Policy without regard to any conflicts of law principles of the Employment State or any other state to the contrary. The policies and procedures stated in this Policy are subject to any state-specific modification under Appendix A that may apply. In the event of a conflict between the terms stated above and any applicable modifications, the modifications will supersede the terms stated above, but only to the extent required to comply with the modifications.


2. No Expectation of Privacy. All electronic files and similar items stored on Company owned, issued, or sponsored devices or accounts are Company property unless otherwise agreed in writing as to a specific item, and the employee will have no expectation of personal privacy with regard to any such stored items.


If you have questions or concerns, please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695.

  

APPENDIX A

STATE SPECIFIC MODIFICATIONS

Assistance For the Disabled: Alternative formats of this form are available to individuals with disabilities. Please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695 for assistance.


The Employee’s Employment State (and thus the controlling law for this Policy) will change if the Employee’s primary place of residence and work changes during employment with the Company. If this occurs, and the new Employment State is listed below, then the modifications for the new Employment State will control and any modifications applicable for the former Employment State shall no longer apply. The Employee understands that if the Employment State is not listed below then there are no modifications to the Policy in this Appendix A that apply.


California. If California is the Employment State, then:

PRIVACY POLICY AND NOTICE FOR CALIFORNIA WORKFORCE

1. California Notice. The Company collects, stores, uses, and discloses Personal Information (defined below) as necessary and in accordance with this Privacy Policy and Notice (“Policy”). Company does not sell Personal Information or disclose it for cross-context behavioral advertising (“sharing”). Company does not collect or process sensitive Personal Information for the purpose of inferring characteristics in any manner prohibited by law. To the extent you provide Company with Personal Information about your dependents, spouse, beneficiaries, or emergency contacts, you are responsible for providing this notice to them.


2. Assistance For the Disabled. Alternative formats of this Policy are available to individuals with a disability. For assistance, please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695.


3. Scope. This Policy applies to Personal Information of California residents who are (a) employees, (b) independent contractors, interns, volunteers, owners, board members, and other individuals who perform work for Company (collectively “Non-Employee Workers”), or (c) employees’ and Non-Employee Workers’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), (all collectively, “Covered Persons”) in their role as Covered Persons. This Policy includes the categories of Personal Information Company has collected in the past 12 months as well as the categories of Personal Information that the Company will collect about Covered Persons in the foreseeable future. Except where the Privacy Policy specifically refers only to a specific category of HR Individuals, e.g., employees, this Privacy Policy refers to all categories of Covered Persons collectively. 


4. Personal Information. For the purposes of this Policy, “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 individual. Personal Information does not include:

A. Information publicly available from government records or made publicly available by you or with your permission;

B. Deidentified or aggregated information;

C. Information excluded from the scope of the California Consumer Privacy Act (CCPA), such as:

1) protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”) or the Health Information Technology for Economic and Clinical Health Act (“HITECH”) or medical information covered by California Confidentiality of Medical Information Act (“CMIA”); or

2) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“FIPA”).


5. The Categories Of Personal Information Company Collects. Not all categories are necessarily collected about every Covered Person.

A. Identifiers: such as real name, alias, telephone number, postal address, email address, signature, bank account name and number for direct deposits, Social Security number for tax purposes, driver’s license number, and photographs.

B. Professional or Employment-Related Information: such as educational institutions attended, degrees and certifications, licenses, work experience and previous employers, professional memberships and affiliations, union representation, seniority, training, employment start and ending dates, and job title.

C. Compensation and Benefits Information for Employees: such as salary, salary history, bonus and commission, equity compensation information, hours and overtime, leave information, bank details (for payroll and reimbursement purposes only), benefits in which you may be enrolled, and identifying information for dependents and beneficiaries.

D. Non-Public Educational Information: such as academic transcripts.

E. Commercial Information: such as business travel and expense records.

F. Internet or Other Electronic Network Activity Information: such as Internet browsing and search history while using Company’s network, log in/out and activity on Company's electronic resources, interactions with Company’s Internet web site, application, or advertisement, and publicly available social media activity.

G. Sensory or Surveillance Data: such voice-mails, recordings of meetings or video-conferences, and footage from video surveillance cameras.

H. California Civil Code Section 1798.80 Personal Information: to the extent not already included in other categories here, such as benefit information to administer short and long-term benefits as well as other benefit plans.

I. Preferences: such as hobbies and leisure activities, membership in voluntary/charitable/public organizations, and preferences regarding work tools, travel, hours, food for company events, etc.

J. Inferences: e.g., Company might infer characteristics from activity on Company’s electronic resources, e.g., willingness to try new technologies.

K. Characteristics of Protected Classifications Under California or Federal Law: such as race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations and to support diversity and inclusion programs; disability, medical condition, and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with Federal and California law related to leaves of absence and accommodation; and marital and familial status as necessary to provide benefits to employees and for tax purposes.

L. Biometric Information: such as finger or hand prints or facial heat signature for a biometric timeclock, or voice for audio inventory control devices. Please refer to Company’s Biometric Policy for further information.

M. Geolocation Data: such as GPS tracking on Company vehicles.

N. Non-Employee Workers: Company collects the categories of Personal Information listed above, excluding the following categories: (a) Compensation and Benefits Information for Employees and (b) Characteristics of Protected Classifications Under California or Federal Law.

O. Emergency Contacts: contact information for emergency purposes only.

P. Family and Beneficiaries. Company may collect Personal Information about spouses or domestic partners, dependents, and beneficiaries as needed for employment purposes and employment related social functions, and that information may include: (1) Identifiers; (2) Commercial Information if, for example, Company arranges travel for a dependent to attend a Company event; (3) Internet Activity Information if the individual uses Company electronic resources and web sites; (4) Sensory or Surveillance Data if the individual enters Company facilities; (5) Cal. Civ. C. § 1798.80 Personal Information, such as insurance policy numbers if the individual is covered by Company insurance or health information, for example, infectious disease testing when a Related Contact attends a Company event; and (6) Protected Categories of Personal Information, for example, childbirth to administer parental leave, marital status to pay taxes, and familial status to administer benefits. 


6. Inferences from sensitive Personal Information: Company does not collect or process sensitive Personal Information or characteristics of protected classifications for the purpose of inferring characteristics about the individual. 


7. The Categories of Sources For Personal Information Company Collects. Not all sources are necessarily used for every Covered Person.

A. Covered Person: such as job application, employment and onboarding forms, assessments, surveys, and any information the individual provides us during the course of the interview, application and employment relationship.

B. Related Contacts: as applicable.

C. Vendors and service providers: such as background checking companies, private investigators, law firms.

D. Affiliated companies: such as when an employee works on a cross-enterprise team, health care providers in our MPN, drug testing, and background check companies.

E. Third parties: such as job references, business partners, professional employer organizations or staffing agencies, insurance companies.

F. Automated technologies: such as to track logins and activity across Company network, applications, and electronic equipment.

G. Surveillance/recording technologies installed by Company: such as video surveillance in common areas of Company facilities, global positioning system (“GPS”) technologies, voicemail technologies, webcams, audio recording technologies, and blue-tooth technologies, any of these with consent to the extent required by law.

H. Government or administrative agencies: such as law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department, Dept of Motor Vehicles, courts, internet research tools such as Lexis and Westlaw, and any public source.

I. Acquired company: such as if Company acquired your employer, Company might collect Personal Information from that employer.


8. General Purposes Company Uses Personal Information For.

A. Fulfilling the purpose for which you provided the information or at your direction. For example, if you share your name and contact information to apply for a job or become an employee, we will use that Personal Information in connection with your employment or potential employment.

B. Administering the employment relationship including, but not limited to, human resources administration, payroll processing, benefits administration, leave programs, corporate travel and other business expenses, timekeeping, managing work supplies, grievance or disciplinary matters, diversity and inclusion, ascertaining your fitness to work, drug and alcohol screening, worker’s compensation administration, occupational health surveillance, direct threat analysis, and facilitating communication and collaboration.

C. Managing and/or analyzing all aspects of employee performance including, but not limited to, talent management, periodic reviews, performance tracking, promotions, retention, discipline, education, training and development, and data analytics.

D. Administering the relationship with Non-Employee Workers, including, but not limited to, evaluating the Non-Employee Worker’s qualifications, negotiating and executing work contracts, orientation and familiarization with Company’s working environment, administering the contractual relationship including payments, facilitating communications, and workforce satisfaction.

E. Administering the relationship with Related Contacts, including, but not limited to, communications, managing and administering benefits, and managing participation in Company events.

F. Promoting Company and creating a positive environment in the workplace, including, but not limited to, planning and running Company events, conducting surveys, running contests, and supporting diversity, equity, and inclusion.

G. Ensuring compliance with Company policies and applicable laws and regulations, including, but not limited to, developing and enforcing policies and procedures, authenticating your identity, conducting internal audits and investigations, administering Company’s whistleblower hotline, and preparing reports.

H. Protecting health and safety of Covered Persons, visitors, customers, and the public, including, but not limited to, responding to medical emergencies, reducing the risk of exposure to infectious disease and preventing its spread in compliance with applicable laws and regulations, and protecting the safety and security of Company’s facilities.

I. Managing the security and integrity of our information and electronic resources including, but not limited to, monitoring use of our electronic resources, preventing unauthorized access to our electronic resources, preventing malicious software distribution, debugging, audits, disaster recovery, business continuity, and cyber security.

J. Running our business, including, but not limited to, customer service, project management, research, data analysis, and development, quality assurance and improvement, managing licenses, permits, and authorizations applicable to Company’s business operations, maintaining records, and efficiently managing and operating administrative, information technology, and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning.

K. Providing, supporting, personalizing, and improving our website and online services relating to your prospective, current, or former employment or engagement.

L. Protecting the rights or property of Company, including, but not limited to, detecting and prevent fraud or other types of wrongdoing, managing litigation involving Company, and other legal disputes and inquiries, crisis management, dispute resolution, reporting suspected criminal conduct to law enforcement and cooperating in investigations, short-term transient use of Personal Information, responding to requests or orders from governmental agencies, exercising Company’s rights under applicable law, and supporting any claim, defense, or declaration involving the Company in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.

M. In connection with a corporate transaction, transfer, or assignment of assets, merger, divestiture, or other changes of control or our financial status or any of related subsidiaries or affiliates.


9. Purposes For Using Employees’ Health Information.

A. To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities.

B. To conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law.

C. For workers’ compensation purposes.

D. For occupational health surveillance.

E. For occupational health and safety compliance and record-keeping.

F. To conduct fitness-for-duty examinations.

G. To administer leaves of absence and sick time.

H. To provide a wellness program.

I. To respond to an employee’s medical emergency.


10. Purposes For Using Employees’ Protected Categories Of Information.

A. Company collects information about race, age, national origin, disability, sex, veteran status and/or other legally protected categories as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, The Office of Federal Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act.

B. Company collects information about disability status to the extent an employee may need special assistance during emergencies from Company or from first responders.

C. Company may collect the following information (in addition to those listed above) for purposes of diversity, equity and inclusion (including analytics) if the employee is willing to provide it: (a) religion, (b) sex, (c) gender, (d) pregnancy, (e) childbirth, (f) breastfeeding, or related medical conditions, (g) sexual orientation, (h) disability, (i) gender identity, (j) gender expression, (k) marital status, (l) age, (m) familial status, and/or (n) ancestry.


11. Other Purposes Company May Use Personal Information for.

A. Disability, medical condition, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions may be used as necessary to comply with Federal and California law related to leaves of absence and accommodation.

B. Military and veteran status may be used as necessary to comply with leave requirements under applicable law and for tax purposes.

C. Date of birth and age may be used incidentally to the use of birth date for birthday celebrations and identity verification.

D. Religious affiliation and pregnancy, childbirth, breastfeeding, and related medical conditions may be used as necessary for accommodations under applicable law.

E. Protected classifications, such as national origin may be used to the extent this information is contained in documents that you provide in I-9 documentation.

F. Marital status, dependents and familial status may be used for Company events and as necessary to provide benefits and for tax purposes.

G. Personal Information about membership in protected categories is collected on a purely voluntary basis, except where required by law, and Company uses the information only in compliance with applicable laws and regulations.


12. How Company May Disclose Personal Information.  Company generally maintains Personal Information related to Covered Persons as confidential. However, from time to time, Company may have a legitimate business need to disclose Personal Information. In that event, Company discloses information within the categories of Personal Information listed above, but only if the disclosure is permitted by the CCPA and other applicable laws, and in that event only to the minimum extent necessary to achieve the purpose of the disclosure.

A. Disclosures for Business Purposes. Company may disclose each of the categories of Personal Information listed in Section 5, above, to the following categories of third parties for the following “business purposes”, as that term is defined under the CCPA:

1) Service providers:  Company may disclose to service providers any of the categories of Personal Information listed in Section 5, above, for the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in Section 8, above. 

2) Auditors, lawyers, consultants, and accountants engaged by Company:  Company may disclose the categories of Personal Information listed in Section 5, above, to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.

3) Affiliated companies:  Company may disclose any of the categories of Personal Information listed in Section 5, above, to other companies within the Blackrock Holdings family of companies for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

B. No Sales or Sharing. Company does not sell or “share” (disclose to a third party for cross-context behavioral advertising) your Personal Information in connection with the HR relationship. In addition, we have no actual knowledge that we sell or share the Personal Information of individuals of any age in connection with the HR relationship, including the Personal Information of children under 16. 

C. Disclosures to Others. Company may disclose Personal Information to the following additional categories of third parties for purposes other than a business or commercial purpose as defined by the CCPA:

1) Your direction: We may disclose your Personal Information to third parties at your direction.

2) Clients: We disclose Personal Information to the clients for which you work or to whom you have applied as necessary to meet the client’s requirements.

3) Affiliated companies: Other companies within the Blackrock Holdings family of companies, for example, if you work on a cross-enterprise team. 

4) Business partners: For example, Company might disclose your business contact information to a co-developer of a new product or service with which you will be working. 

5) Government or administrative agencies: These may include, for example the Internal Revenue Service to pay taxes or the California Department of Industrial Relations as required to resolve workers’ compensation claims.

6) Public: Company may disclose your Personal Information to the public as part of a press release, for example, to announce promotions or awards. If you do not want your Personal Information in press releases, please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695. Company does not disclose sensitive Personal Information to the public.

7) Required Disclosures: We may be required to disclose Personal Information (a) in a court proceeding, (b) in response to a court order, subpoena, civil discovery request, other legal process, or (c) as otherwise required by law.

8) Legal Compliance and Protections: We may disclose Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, Covered Persons, or others.

9) Corporate Transactions: We may disclose your Personal Information in connection with a corporate merger, consolidation, bankruptcy, the sale of all, or substantially all, of our membership interests and/or assets or other corporate change, including to any prospective purchasers. 


13. How Long Company Keeps Personal Information. Company keeps your Personal Information no longer than necessary for the purposes described in Section 8 above and in accordance with Company’s record retention policy available from the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695, unless Company is required to retain your Personal Information longer by applicable law or regulation, by administrative needs, by legal process, or to exercise or defend legal claims.


14. California Privacy Rights.

A. Right to Know: You have the right to submit a verifiable request up to twice in a 12-month period for specific pieces of your Personal Information and for information about Company’s collection, use, and disclosure of your Personal Information. Please note that the CCPA’s right to obtain specific pieces does not grant a right to the whole of any document that contains Personal Information, but only to discrete items of Personal Information. Moreover, Covered Persons have a right to know categories of sources of Personal Information and categories of external recipients to which Personal Information is disclosed, but not the individual sources or recipients.

B. Right to Delete: You have the right to submit a verifiable request for the deletion of Personal Information that you have provided to Company.

C. Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate Personal Information maintained by Company, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.


15. How to Exercise Your Rights. Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

A. Contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695; or


16. How Company Will Verify Your Request. Company will match Personal Information the requestor provides to previously collected Personal Information in Company’s files. The more risk entailed by the request (e.g., a request for specific pieces of Personal Information), the more items of Personal Information Company may request to verify the requestor’s identity. If we cannot verify the requestor’s identity to a sufficient level of certainty to respond securely to the request, Company will arrange for alternate means verify identity, such as coming into a branch office or joining a videoconference and showing identification.


17. Authorized Agents. A requestor may designate an authorized agent to exercise the individual’s right to know, to correct, or to delete. If an authorized agent submits a request on an individual’s behalf, the authorized agent must submit with the request another document signed by the individual that authorizes the authorized agent to submit the request on the individual’s behalf. In addition, Company may ask the individual or the authorized agent to follow the applicable process described above for verifying the individual’s identity. In the alternative, an individual can provide a power of attorney compliant with the California Probate Code.


18. Non-Discrimination and Non-Retaliation. Company will not unlawfully discriminate or retaliate against any individual for exercising rights under this Policy or the CCPA.


19. Changes To This Policy. The Company reserves the right to change this Policy in its sole discretion, however, if any changes are made, we will give you advance notice in writing of those changes before they take effect.


20. For More Information. For questions or concerns about this Policy, please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695.


Illinois and Texas. If Colorado, Illinois, or Texas is the Employment State, then:

The Company's Biometric Data Security Policy (“Policy”) sets out the policies and procedures to protect Biometric Data collected and stored by the Company. For employees assigned to work for a client of the Company, the Policy also addresses the client’s collection of Biometric Data from the Company’s employees.


1. Definitions. For purposes of this Policy, the following definitions shall apply:

A. “Biometric Data” means data generated by the technological processing, measurement, or analysis of an individual's biological, physical, or behavioral characteristics, which data can be processed for the purpose of uniquely identifying an individual. 

1) “Biometric Data” can include fingerprints, voiceprints, a retina scan, and scans of hand or face geometry.

2) "Biometric Data" does not include a digital or physical photograph, video, or voice recording in themselves, but would include data generated by the technological processing, measurement, or analysis of this content that could be, or is used, for identification purposes.


2. Scope. In addition to applying to employees whose Employment State is Colorado, Illinois, or Texas, this Policy applies to all employees of the Company, regardless of their Employment State, who in the course of performing their regular job responsibilities are involved in the collection, use, handling, safeguarding, storage, retention, or destruction of Biometric Data of other employees whose Employment State is Colorado, Illinois, or Texas.


3. Collection of Biometric Data by the Company.

A. Notice. To the extent required by applicable law, before collecting Biometric Data from an employee, the Company will provide the individual with a copy of a notice that explains the specific purpose of the collection of Biometric Data and obtains the employee’s written consent to the collection.

B. Prohibited Conduct. The Company will not sell, lease, trade or otherwise profit from employees’ Biometric Data.

C. Restrictions on Disclosure. To the extent required by applicable law, the Company will not disclose or otherwise disseminate Biometric Data unless:

1) The individual provides written consent for the disclosure; 

2) The disclosure is required by law; or

3) The disclosure is made to a law enforcement agency for a law enforcement purpose in response to a warrant.

D. Security for Biometric Data. The Company uses administrative, technical and physical safeguards for Biometric Data that are consistent with industry standards and at least as stringent as the safeguards the Company uses for its other confidential information. In addition, Biometric Data in electronic form will be encrypted when in storage and in transmission. Paper documents containing Biometric Data, when unattended, will be stored in a locked filing cabinet, storage area, or office. Only employees with a legitimate business need may access Biometric Data. Authorized employees should avoid creating paper documents containing Biometric Data whenever possible. No employee may disclose Biometric Data to any third party without prior authorization from the Company’s senior management.

E. Biometric Security Incident Response. Any employee who becomes aware of the unauthorized access or acquisition of Biometric Data (“Biometric Security Incident”) must immediately contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695. As soon as reasonably possible, the Company will: (a) investigate any report of a Biometric Security Incident; (b) stop the Biometric Security Incident; (c) determine whether the Biometric Security Incident is a data breach under applicable law; and (d) implement steps to prevent a recurrence of the Biometric Security Incident. If the Company determines that a breach of Biometric Data has occurred, the Company will provide breach notifications and services in accordance with applicable law.

F. Retention of Biometric Data. The Company will permanently destroy an individual’s Biometric Data from its systems, or the systems of its vendor(s), on or before the earliest of the following dates:

1) When the initial purpose of collection is satisfied; 

2) Within 24 months after Company’s last interaction with the individual; or 

3) Within forty-five days of when storage of the Biometric Data is no longer necessary, adequate, or relevant to the express processing purpose identified by a review conducted by Company at least once annually.

To the extent permitted by applicable law or required by court order, the Company will suspend the destruction of Biometric Data when, and to the limited extent, necessary to satisfy the Company’s duty to preserve information that would be discoverable in litigation or other legal proceeding.

G. Destruction Of Biometric Data. Paper documents containing Biometric Data will be shredded or burned. Biometric Data in electronic form will be destroyed in a manner that renders the information irretrievable. The Company’s Human Resources and Information Technology departments shall be responsible for directing the destruction of such information upon expiration of the retention period described in paragraph F, above.

H. Compliance With This Policy. Violations of this Policy or its procedures by any Company employees will result in disciplinary actions under the Company’s discipline policy, and may include suspension or termination of employment in the case of severe or repeat violations.


4. Collection of Biometric Data by the Company’s Clients. If the employee is assigned to work for a client, the Company cannot control the clients’ use of biometric technology in their workplaces or their collection of Biometric Data from the Company’s employees. For example, the client may collect your fingerprint information for timekeeping or security related purposes.

A. The Company does not receive, acquire, store, or have access to any Biometric Data collected by clients. As a result, the policies and procedures in this Policy do not apply to the client’s collection of Biometric Data.

B. The collection, storage and use of Biometric Data by a client is governed by the client’s policies and procedures.

C. Any consent form that a client may ask you to sign prior to collecting your Biometric Data does not create any type of employment relationship between you and the client. The regulations governing the collection of Biometric Data are privacy laws and not employment laws. Employees that are assigned to work for a client are required to comply with the client’s policies and procedures as a condition to accepting the assignment.


If you have questions or concerns, please contact the Human Resources Department by email at imahar@brh.ai or by phone at 949-547-6695.


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