PRIVACY POLICY (HR DATA)
California Privacy Rights Act
Updated: January 1, 2023
YOUR PRIVACY IS IMPORTANT TO DERREL’S MINI STORAGE
Derrel’s Mini Storage, Inc., (also referred to as “DMS” or “the Company”) is and always has been built on trust. We are proud to provide products you can trust, and we view our relationship with our employees as a vital factor in the success of our products. We are committed to protecting your privacy.
This Privacy Policy and Notice to Consumer (“Privacy Policy”) describes the Company’s practices with respect to the collection, use, and disclosure of personal information it has collected within the past 12 months. DMS does not sell any of the personal information it collects. This Privacy Policy also provides information about consumers’ rights, under California law, with respect to the personal information DMS collects about them.
This Privacy Policy describes the Company’s generalized practices only and does not provide any specific information regarding the Company’s activities with respect to any individual consumer’s personal information.
ACCESSING THE PRIVACY POLICY
If you are unable to access this policy because of a language barrier, disability, or any other reason, please contact the Human Resources Department at 559-224-9900 or email at HR@derrels.com so that the Company can provide you with a version of the Privacy Policy accessible to you. The Privacy Policy is available for review in the Human Resources Department at any time during normal business hours.
DEFINITIONS
The terms used in this Privacy Policy shall have the same definitions given to them by the California Privacy Rights Act (“CPRA,” Cal. Civ. Code §1798.100 et seq.), the regulations to the CPRA, and the California Online Privacy Protection Act (“COPAA,” Cal. Bus. & Prof. Code §22575 et seq.).
COLLECTION, DISCLOSURE, AND USE OF PERSONAL INFORMATION
1. Summary of the Company’s Collection and Use of Personal Information
Since 1963, Derrel’s Mini Storage has provided self-storage to the Central Valley. From Sacramento to Bakersfield and even on the Central Coast, Derrel’s Mini Storage provides the largest storage facilities in the nation. Today, there are over 60 locations, and we continue to grow! We value our customers and take great pride in our reputation as the premier self storage company in the communities we serve. With beautifully landscaped grounds and clean facilities, it is a priority for us to be good neighbors. Our focus is on providing a quality product and excellent customer service, and we know our employees are the backbone of our company.
The Company employs people throughout California, and in the regular course of business may collect the personal information of job applicants, employees, vendors, contractors, employee beneficiaries, consumers and other related people as required by law and as required for the Company’s human resource (“HR”) processes.
For example, personal information commonly collected by the Company includes information submitted in online and paper job applications, personal information included on HR and payroll forms, performance reviews, and job-related electronic communications and services (such as log-in identifications). Generally, this information is collected in order to comply with the Company’s legal obligations and HR practices.
DMS respects each persons’ right to privacy, including the right to data privacy. Therefore, the Company processes sensitive personal data only as needed to meet legal obligations and retains all personal information securely in compliance with all applicable laws.
The Company has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Please be sure to maintain the confidentiality of all of your personal information and refrain from sharing it with others.
2. Table of the Company’s Collection, Disclosure and Use of Personal Information
Below is a table that explains what personal information the Company has collected from consumers over the past twelve months, the categories of sources from which the Company collected the information, and the categories of Third Parties and Service Providers with whom the Company shares the personal information. Additionally, the table identifies whether or not the Company has sold or otherwise made available to Third Parties for a commercial purpose any category of personal information within the past twelve months.
JOB APPLICANT(S)
INFORMATION COLLECTED
Identifiers, including but not limited to:
• Legal names and aliases;
• Signatures;
• Addresses;
• Telephone Numbers;
• Email Addresses;
• Social Security Numbers;
• Driver’s License Numbers
• State ID Card Numbers
• Passport Number (or other acceptable documents for purposes of completing I-9 Employment Eligibility Form)
Background Information, including but not limited to:
• Employment and Educational History.
Protected Classifications, including but not limited to:
• Age;
• Gender;
• Race.
SOURCES OF INFORMATION
We collect this information directly from you when you:
• Complete various company documents, including but not limited to: Job Application(s), Drug Test Authorization Form(s).
• Submit your resume to the Company when seeking employment.
We collect some of this information directly from you when you:
• Complete various company documents, including but not limited to: the Job Application.
• Submit your resume and references when seeking employment with the Company.
We collect this information directly from you when you:
• Complete various company documents, including but not limited to: the Job Application.
BUSINESS PURPOSE(S)
We use this information to:
• Conduct background checks and to confirm identity of job applicants;
• Confirm acknowledgment of particular policies or procedures;
• Verify the identity of an employee or related person;
• Verify employment eligibility;
• Verify class and status of licenses;
• Contact applicants to the extent necessary.
We use this information to:
• Assess an applicant’s eligibility to work in various positions;
• Assess an applicant’s qualifications for various positions.
We use this information to:
• Comply with state and federal law;
• Comply with governmental regulations, including affirmative action responsibilities;
• Report demographics as required by the Equal Employment Opportunity Commission.
THIRD PARTIES TO WHOM INFORMATION IS DISCLOSED
We share identifiers with the following categories of persons in the following circumstances:
• Our background check Service Providers.
We do not sell this information.
We share this information with the following categories of persons in the following circumstances:
• Our background check Service
Provider.
We do not sell this information
We share this information with the following categories of persons in the following circumstances:
• Equal Employment
Opportunity Commission
We do not sell this information
EMPLOYEE(S), OWNER(S), DIRECTOR(S), AND OFFICER(S)
INFORMATION COLLECTED
Identifiers, including but not limited to:
• Legal names and aliases;
• Signatures;
• Addresses;
• Telephone Numbers;
• Email Addresses;
• Social Security Numbers;
• Driver’s License Numbers
• State ID Card Numbers
• Passport Number (or other acceptable documents for purposes of completing I-9 Employment Eligibility Form)
• Insurance Policy Numbers
Background Information, including but not limited to:
• Employment and Educational History.
Protected Classifications, including but not limited to:
• Age;
• Gender;
• Race.
Financial Information, including but not limited to:
• Bank Account Numbers
Geolocation Data, including but not limited to:
• Precise or approximate location as determined through data such as your mobile device or company owned vehicle
Commercial Information, including but not limited to:
• Records of Products or Services obtained by employee, owners, officers or directors for Company travel or other purposes
Biometric information, including but not limited to:
• Audio and/or Visual Records, Including Photographs
• Finger prints
Internet or other electronic network activity information, including but not limited to:
• Internet Activity
• Web Tracking Information
SOURCES OF INFORMATION
We collect some of this information directly from you when you:
• Complete various company documents, including but not limited to: your personal resume; the Job Application; Background
Authorization Form; I-9 Form; Personnel Information Form; Confidentiality and NonDisclosure Agreement; Arbitration Agreement; W-4, DE-4; Direct Deposit Form; Personal Information Form; Time Off
Request Forms;
• Onboarding Checklist; Wage Employment Notice Form; Accident Report Form; Safety Training and Meeting Attendance Forms.
We collect some of this information directly from you when you:
• Submit your resume to the Company when seeking employment;
• Complete various company documents, including but not limited to: the Job Application.
We collect this information directly from you when you:
• Are signed up for Company sponsored insurance plans
• Complete various company documents, including but not limited to: the Job Application.
We collect some of this information directly from you when you:
• Complete various company documents, including but not limited to: the Direct Deposit Form.
We collect some of this information directly from you when you:
• Engage the technology while operating company vehicles or using Company owned IT devices;
• Utilize Company timekeeping systems, where required by the timekeeping system.
• Company owned vehicle tracking technology
We collect some of this information directly from you when you:
• Submit expense statements or request funds to facilitate travel or other operations
We collect some of this information directly from you when you:
• Use Company time clock devices;
• Access certain company facilities;
• Sign documents on behalf of the
Company requiring a notary acknowledgement.
We may also collect this information from:
• Our alarm/security provider
• Paylocity
We collect some of this information directly from you when you:
• Use company IT systems and equipment
We may also collect this information
from:
• IT service providers
BUSINESS PURPOSE(S)
We use this information to:
• Process payroll;
• Withhold and pay appropriate taxes;
• Administer benefits, such as insurance and 401(k) distributions;
• Verify the authenticity of documentation;
• Undertake activities necessary for federal and state taxes related to wages earned by employees;
• Verify the identity of an employee or related person;
• Verify employment eligibility;
• Verify class and status of license;
• Enroll employees or related persons in Company-administered benefits beyond open enrollment periods;
• Contact employees to the extent necessary;
• Complete various employment related documents, such as filing Workers’ Compensation claims.
We use this information to:
• Assess an employee’s eligibility to work in various positions and to assess an employee’s qualifications for a job position.
We use this information to:
• Comply with state and federal law;
• Reporting demographics as required by the Equal Employment
Opportunity Commission;
• Complete insurance/pension enrollment documentation as required by carriers/plan document
• Complete Workers’ Compensation claims.
We use this information to:
• Process payroll;
• Administer direct deposit payments;
• Comply with payroll tax withholding legal obligations
We use this information to:
• Geofence employees’ ability to use timeclock systems.
We use this information to:
• Reimburse employees, owners, officers or directors for business related expenses.
We use this information to:
• Facilitate the use of the Company’s timekeeping systems;
• Monitor safety on Company owned or operated premises.
We use this information to:
• Monitor activity on Company owned devices, if necessary;
• Administer data-flow over data lines;
• Conduct workplace investigations and/or disciplinary actions
• Monitor and test data security systems and firewalls
THIRD PARTIES TO WHOM INFORMATION IS DISCLOSED
We share identifiers with the following categories of persons in the following circumstances:
• Background check Service Providers.
• Payroll service providers such as Paylocity.
• OSHA
• Occupational Clinics
• We do not sell this information.
We share this information with the following categories of persons in the following circumstances:
• Background check Service Provider.
• We do not sell this information.
We share this information with the following categories of persons in the following circumstances:
• Insurance carriers
• Retirement plan administrator
• Equal Employment
Opportunity Commission
We do not sell this information
We share this information with the following categories of persons in the following circumstances:
• The financial institution where payroll is deposited or a direct deposit is made by the Company
• Paylocity
We do not sell this information
We share this information with the following categories of persons in the following circumstances:
• Paylocity
We do not sell this information
We share this information with the following categories of persons in the following circumstances:
• Credit card providers when disputing a charge or monitoring fraud activity We do not sell this information
We share this information with the following categories of persons in the following circumstances:
• Paylocity
We do not sell this information
We share this information with the following categories of persons in the following circumstances:
• IT service providers to monitor system security, capacities and efficiencies
We do not sell this information
EMERGENCY CONTACT(S) FOR JOB APPLICANT(S), EMPLOYEE(S), OWNER(S), DIRECTOR(S), OFFICER(S), MEDICAL STAFF MEMBER(S), AND/OR CONTRACTOR(S)
INFORMATION COLLECTED
Identifiers, including but not limited to:
• Legal names and aliases;
• Telephone Numbers
• Addresses
• Email Addresses
SOURCES OF INFORMATION
We collect this information directly from employees, vendors, and others when they designate you as their emergency contact:
We may also collect this information from:
• Known associates of the above in the event of an emergency
BUSINESS PURPOSE(S)
We use this information to:
• Contact the designated party in the event of an emergency
THIRD PARTIES TO WHOM INFORMATION IS DISCLOSED
We share this information with the following categories of persons in the following circumstances:
• Law enforcement or medical personnel in the event of an emergency
We do not sell this information
BENEFICIARIES OF JOB APPLICANT(S), EMPLOYEE(S), OWNER(S), DIRECTOR(S), OFFICER(S), MEDICAL STAFF MEMBER(S), AND/OR
CONTRACTOR(S)
INFORMATION COLLECTED
Identifiers, including but not limited to:
• Legal names and aliases;
• Telephone Numbers
• Addresses
• Email Addresses
SOURCES OF INFORMATION
We collect this information directly from our employees when they:
• Sign up for Company administered Insurance, pension and other benefit plans
• Make changes to their beneficiary information
BUSINESS PURPOSE(S)
We use this information to:
• Make payments to an employee’s beneficiary as related to insurance or 401(k) pension and profit
sharing payments as required
THIRD PARTIES TO WHOM INFORMATION IS DISCLOSED
We share this information with the following categories of persons in the following circumstances:
• Insurance companies in the event of claims that the employee is unable to receive
• Pension administration provider in the event of a distribution that the employee is unable to receive
We do not sell this information
SUMMARY OF CONSUMER RIGHTS WITH RESPECT TO THEIR PERSONAL INFORMATION
The CPRA grants consumers (California residents) certain rights with respect to their personal information. The Company respects the privacy rights of consumers and endeavors to make known to and comply fully with the rights granted to consumers by the CPRA.
In summary, the CPRA grants consumers the following rights:
• The right to request disclosure of the Company’s data collection and business practices in connection with the requesting consumer. This disclosure right includes the right to request disclosure of: (1) The categories of personal information the Company has collected about the consumer; (2) The categories of sources from which the Company collects the personal information; (3) The business or commercial purpose for collecting or selling the personal information; (4) The categories of third parties with whom the Company shares personal information; and, (5) The specific pieces of personal information the Company collects about the consumer upon request.
• The right to request a copy of the specific personal information collected by the Company about the consumer during the 12-months preceding the consumer’s request. For purposes of this Privacy Policy, this right is referred to as the “Request to Know.”
• The right to have such information deleted, subject to certain exceptions. For purposes of this Privacy Policy, this right is referred to as the “Request to Delete.”
• The right to request that the personal information collected by the Company not be sold to third parties, if applicable. For purposes of this Privacy Policy, this right is referred to as the “Request to Opt-Out.”
• The right to not be discriminated against by the Company because the consumer exercised any right granted to the consumer by the CPRA.
These rights, however, are subject to limitation.
• If a consumer shares with the Company the consumer’s personal information in the following capacities and the information is used by the Company solely within the context of the consumer acting in such capacity, then the
Consumer, pursuant to the CPRA, does not have the right to “Request to Know,” “Request to Delete,” or the “Request to Opt-Out” with respect to such information:
o Personal information that is collected by the Company about a consumer in the course of the consumer acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of the Company.
o Personal information that is collected by the Company about a consumer that is the emergency contact information of a consumer who acts as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of the Company.
o Personal information that is collected by the Company about a consumer that is necessary for the Company to retain to administer benefits for another consumer who acts as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of the Company.
• The rights summarized above shall not apply to a consumer who shares personal information with the Company in a transaction between the Company and the consumer, where the consumer acts as an employee, owner, director, officer, or contractor of another company, partnership, sole proprietorship, non-profit, or government agency and the transaction occurs in the context of the Company conducting due diligence regarding, providing, or receiving a product or service to or from the consumer who acts as an employee, owner, director, officer, or contractor of another company, partnership, sole proprietorship, non-profit, or government agency.
CONTACT FOR MORE INFORMATION
If you have any questions or concerns about the Company’s privacy policies and practices, please contact the Human Resources Department at (559) 224-9900 or email at HR@derrels.com.