Purpose: This Applicant Privacy Policy and Notice at Collection explains how LSMA Management, Inc. collects, uses, discloses, retains, and protects personal information about individuals who apply for roles with LSMA in California (“Applicants,” “you”). California workers (including applicants) are covered by the California Consumer Privacy Act as amended by the CPRA

1) Notice at Collection

At or before the point we collect personal information from you, California law requires us to tell you:

a. the categories we collect (including sensitive PI) b. the purposes, c. whether we sell/share, and

d. our retention period (or criteria). 

A. Categories of personal information we collect (Applicants)

Depending on the role and what you provide, LSMA may collect the following categories:

1. Identifiers: name, alias, postal address, unique personal identifier, online identifier, email address, phone number.
2. Personal records (as described in Cal. Civ. Code § 1798.80): signature, employment history, education, and similar information you submit.
3. Professional or employment-related information: resume/CV details, work history, references, interview notes, qualifications, licensing/certifications.
4. Education information (non-public): transcripts or records you choose to provide, where relevant.
5. Internet or network activity: interactions with our careers site/application portal, device and log data (where collected).
6. Audio/visual information: recordings or photos from interviews/events, if used and permitted.
7. Inferences: internal assessments about role fit based on application/interview information.

Sensitive Personal Information (SPI) (only where applicable/necessary):

• Government identifiers (e.g., Social Security number, driver’s license/state ID, passport) typically for background checks, identity/work authorization, or onboarding steps after an offer.
• Account log-in credentials for the application portal (if applicable).
• Health or disability information you provide to request accommodations.
• Race/ethnicity, gender, veteran status and similar EEO data only if you voluntarily provide it and where permitted/required.

We do not intentionally collect SPI beyond what is needed for recruiting, legal compliance, security, and accommodations.

B. Purposes for collecting/using applicant information

We collect and use Applicant personal information to:

• Recruit, evaluate, and select candidates, including reviewing qualifications, conducting interviews, and communicating with you
• Administer our recruiting operations (including through our ATS provider, Paylocity)
• Verify information you provide, such as references, credentials, and work history (as permitted)
• Conduct background checks through a third-party administrator (TPA) where relevant and permitted by law
• Provide accommodations in the application process
• Comply with legal obligations, including employment, equal opportunity, and related recordkeeping requirements
• Protect security and prevent fraud, including maintaining the integrity of our systems and investigation of incidents
• Defend and enforce legal rights, including responding to claims or legal requests
• Consider you for future roles where permitted and consistent with your preferences

C. Do we “sell” or “share” Applicant personal information?

LSMA does not sell Applicant personal information and does not share it for cross-context behavioral advertising (as those terms are defined under California law). If this changes, we will provide the required opt-out rights and notices. 

D. How long we retain Applicant personal information

LSMA retains Applicant personal information only as long as reasonably necessary for the purposes described above, unless a longer retention period is required or permitted by law. We use the following general retention approach:

• Application and recruiting records: typically up to 4 years after the hiring decision (to support compliance and respond to potential claims), unless a longer period is required or you request deletion and an exception doesn’t apply.
• Background check records (through a TPA): typically up to 2 years after completion (or longer if required by law or for dispute resolution).
• Accommodation/medical documentation (if any): retained only as needed for the accommodation process and legal compliance, and maintained with appropriate confidentiality safeguards.

(You may adjust the timeframes above to match your internal retention schedule; California notices must state a length of time or criteria by category. )

  

2) Sources of Applicant personal information

We collect Applicant information from:

• You, when you apply or communicate with us
• Paylocity (our applicant tracking system) as you submit materials through the platform
• Recruiters or referrals you authorize or who provide your information
• References and prior employers (where applicable and permitted)
• Our background check TPA and related screening partners (where applicable and legally permitted)
• Public/professional sources (e.g., LinkedIn, portfolio sites) that you make available

  

3) Who we disclose Applicant information to

We may disclose Applicant information to:

• LSMA personnel involved in recruiting, interviewing, and hiring
• Service providers/contractors that support recruiting and business operations (including Paylocity for ATS services, and our background check TPA), subject to appropriate contractual restrictions
• Professional advisors (legal, auditors, insurers) as needed
• Government authorities or other parties when required by law or to protect rights, safety, and security
• Transaction counterparties in the event of a merger, acquisition, financing, or sale of assets (subject to lawful protections)

  

4) Background checks and fair credit reporting notices

For certain roles, LSMA may request consumer reports / investigative consumer reports (background checks) through a third-party administrator (TPA). Where required, you will receive any legally required standalone disclosures and authorizations, and any required pre-adverse/adverse action notices.

  

5) California privacy rights (Applicants)

If you are a California resident, you may have the right to:

• Know / Access: request information about categories and specific pieces of personal information collected, used, and disclosed
• Delete: request deletion of personal information (subject to legal exceptions)
• Correct: request correction of inaccurate personal information
• Opt-out of sale/sharing: if a business sells or shares personal information (LSMA does not)
• Limit use/disclosure of sensitive personal information: where applicable (LSMA generally uses SPI only for permitted purposes)
• Non-discrimination: you won’t be discriminated against for exercising your rights 

How to submit a request. Submit a request by:

• Email: lyzaguirre@lsmamso.com 
• Phone: 909-890-0407 ext. 1535

We will take steps to verify your identity before fulfilling certain requests (such as access to specific pieces of information). The privacy policy must explain verification and authorized agent procedures. 

Authorized agents

You may designate an authorized agent to submit a request on your behalf. We may require proof of authorization and may still verify your identity directly.

  

6) Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect Applicant information. No method of transmission or storage is completely secure.

  

7) Changes to this policy

We may update this policy from time to time. The “Last Updated” date reflects the most recent revision