California Privacy Rights Act Disclosure for California Applicants and Employees of Servbank, N.A.

Under the California Privacy Rights Act (CPRA), businesses subject to the California Consumer Privacy Act (CCPA), must provide their workers with both (a) a notice of collection at or before the point of collection of their personal information; and (b) a privacy policy describing the personal information collected in the past 12 months, explaining the worker rights under the CCPA and how to exercise them.

 

Servbank, N.A. (the Bank) is providing the below information to its applicants and employees regarding employment related personal and sensitive personal information collected, used, and retained.

Information We Collect & Business Purpose

We have collected, and will collect, the following personal information about our California applicants and employees over the past 12 months: 

Employment Related Personal Information Collected 

Identifiers:

• Examples: Legal name, postal address, IP address, email address, account name, social security number, driver's license number, passport number.
• Collected From: Applicants and Employees.
• Business Purpose: Human Resources Operations, contacting applicants and employees, validating employment eligibility, background checks, and payroll processing. 

Characteristics of Protected Classifications:

• Examples: Date of birth, age, gender, military or veteran status, marital status, nationality, and citizenship.
• Collected From: Applicants and Employees.
• Business Purpose: Human Resources Operations, required Equal Employment Opportunity Commission (EEOC)reporting, and diversity efforts. Note: Provision of this information is optional, except for age. 

Biometric Information:

• Examples: Fingerprints.
• Collected From: Executive Officers Only.
• Business Purpose: Regulator review and approval. 

Internet Activity:

• Examples: Interactions with the company website and/or advertisements, browsing and search history.
• Collected From: Employees (not applicants).
• Business Purpose: Detecting security incidents or fraud, and detecting adherence to IT and Acceptable Usage Policies. 

Geolocation Data:

• Examples: IP address, Geofencing data.
• Collected From: Employees (not applicants).
• Business Purpose: Detecting security incidents or fraud, detecting adherence to IT and Acceptable Usage Policies, and electronic timesheet usage. 

Sensory Information

• Examples: Recorded phone calls
• Collected From: Employees (not applicants).
• Business Purpose: Loan servicing; Legal and regulatory recordkeeping obligations; Auditing and quality control

 

Professional or employment-related Information

• Examples: Education, employment, employment history
• Collected From: Applicants and Employees.
• Business Purpose: Human Resources Operations; Contacting References; Validating Employment Eligibility; Background Checks

 

Employment Related Sensitive Personal Information Collected
 

Identifiers

• Examples: Social security, driver’s license, state identification card, or passport number
• Collected From: Applicants and Employees.
• Business Purpose: Human Resources Operations; Contacting Applicants and Employees; Validating Employment Eligibility; Background Checks; Payroll Processing

 

Geolocation Data

• Examples: A consumer’s precise geolocation
• Collected From: Employees (not applicants).
• Business Purpose: Electronic Timesheet Usage

 

Protected Classifications

• Examples: A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership
• Collected From: Applicants and Employees.
• Business Purpose: Required EEOC Reporting; Diversity Efforts Note: Provision of this information is optional only.

 

Personal Communications

• Examples: The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication
• Collected From: Employees: No, unless viewed or received on a work computer or other company owned device (not applicants)
• Business Purpose: Detecting security incidents or fraud; Detecting adherence to IT and Acceptable Usage Policies

 

Biometric Information

• Examples: Fingerprints
• Collected From: Executive Officers Only
• Business Purpose: Regulator review and approval 

 

Personal Information – Health

• Examples: Personal information collected and analyzed concerning a consumer’s health
• Collected From: Employees: Yes, if related to employer sponsored health insurance (no applicants)
• Business Purpose: Employer sponsored health insurance coverage and processing

 

Sources of Information

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

• Directly from you - the California applicant or employee or your authorized representative(s)
• Our websites, HR systems, and recruitment tools
• Third Parties involved in the processing of your employment application, background or credit check, or payroll processing
• Public records or other publicly available sources

 

Information Sharing

We may disclose your personal information to a third party for a business purpose, such as those described in the chart above. Please know that we treat your information with the utmost care. We do not share information with third parties unless the relationship is governed by a legal contract that protects the confidentiality of the information shared and requires careful treatment and protection of such information in line with applicable laws and regulations and industry best practices. We do not sell any employment related personal information. 

Retention 

Applicants: Applicant records are retained by the Bank for four (4) years following the date of application. If the Applicant is hired by the Bank, then the application material becomes part of the personnel record and is subject to the corresponding retention policy.

Employees: Personnel records are retained by the Bank for six (6) years after employment ends. 

Your Rights 

California consumers have the right to request that a business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of personal information the business has collected.

California consumers also have the right to request that a business delete or correct any personal information about the consumer which the business has collected from the consumer, subject to certain exceptions.

To exercise these rights and request that the Bank supply, correct, or delete specific employment related information, please email us at recruiting@servbank.com.