PRIVACY NOTICE TO CALIFORNIA JOB APPLICANTS

 

Griffin Capital Company, LLC and/or any affiliated entities (collectively, the “Firm” or “we”) provide this California Privacy Notice (“Notice”) to describe our privacy practices with respect to our collection of Personal Information as required under the California Consumer Privacy Act (“CCPA”). This Notice applies only to job applicants and candidates for employment who are residents of the State of California (“Consumers”) and from whom we collect “Personal Information” as defined in the CCPA. We provide you this Notice because under the CCPA, California residents who are job applicants qualify as Consumers. For purposes of this Notice, when we refer to Consumers, we mean you only to the extent you are a job applicant who resides in California.

 

Information We Collect From or About Job Applicants

We may collect Personal Information from you in a variety of different situations and using a variety of different methods, including, but not limited to, on our website, your mobile device, through email, in physical locations, through written applications, through the mail, and/or over the telephone. Generally, we may collect, receive, maintain, and use the following categories of Personal Information, depending on the particular purpose and to the extent permitted under applicable law

  • Personal Identifiers. Examples: Name, alias, postal or mailing address, email address, telephone number, social security number, driver’s license or state identification card number, passport number. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
  • Contact Information. Examples: Home, postal or mailing address, email address, home phone number, cell phone number. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
  • Pre-Hire Information. Examples: Information provided in your job application or resume, information gathered as part of background screening and reference checks, pre-hire drug test results, information recorded in job interview notes by persons conducting job interviews for the Firm, information contained in candidate evaluation records and assessments, information in work product samples you provided, and voluntary disclosures by you. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
  • Employment History. Examples: Information regarding prior job experience, positions held, and when permitted by applicable law your salary history or expectations. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
  • Education Information. Examples: Information contained in your resume  regarding educational history and information in transcripts or records of degrees and vocational certifications obtained. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
  • Inferences. Examples: Based on analysis of the personal information collected, we may develop inferences regarding abilities and aptitudes for purposes of recruiting and hiring assessments and decisions. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.
  • Internet, Network, and Computer Activity. Examples: Internet or other electronic network activity information related to a job applicant’s usage of Firm networks, servers, intranet, or Firm-owned computers and electronic devices, including system and file access logs, security clearance level, browsing history, search history, and usage history. Retention Period: 2 years.
  • Mobile Device Security Information. Examples: Data identifying a job applicant’s device accessing Firm networks and systems, including cell phone make, model, and serial number, cell phone number, and cell phone provider. Retention Period: 2 years.
  • Online Portal and Mobile App Access and Usage Information. Examples: Where job applicant or candidate must create an account to apply for a job, collect the applicant’s username and password, account history, usage history, and any information submitted through the account. Retention Period: 2 years.
  • Medical and Health Information. Examples: Information related to symptoms, exposure, contact tracing, diagnosis, testing, or vaccination for infectious diseases (e.g., COVID-19), pandemics, or other public health emergency. Retention Period: If hired, this data will be retained for duration of employment plus 4 years. If not hired, it will be retained for 2 years from date collected.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Firm may collect:

  • Personal Identifiers (social security number, driver’s license or state identification card number, passport number)
  • Account Information (your log-in to the applicant tracking system or Firm account log-in, in combination with any required security or access code, password, or credentials allowing access to the account).
  • Medical and Health Information 

Personal Information does not include:

  • Publicly available information from government records.
  • Information that a business has a reasonable basis to believe is lawfully made available to the general public by the job applicant or from widely distributed media.
  • Information made available by a person to whom the job applicant has disclosed the information if the job applicant has not restricted the information to a specific audience.
  • De-identified or aggregated information

How We Use Personal Information and Sensitive Personal Information

The Personal Information and Sensitive Personal Information we collect, and our use of Personal Information and Sensitive Personal Information, may vary depending on the circumstances. This Notice is intended to provide an overall description of our collection and use of Personal Information and Sensitive Personal Information. Generally, we may use or disclose Personal Information and Sensitive Personal Information we collect from you or about you for one or more of the following purposes:

  1. To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Firm, we will use that Personal Information in connection with your candidacy for employment.
  2. To comply with local, state, and federal law and regulations requiring employers to maintain certain records (such as immigration compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records), as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19.
  3. To evaluate, make, and communicate decisions regarding your job application  and candidacy for employment.
  4. To obtain and verify background checks, references, and employment history.
  5. To communicate with you regarding your candidacy for employment.
  6. To evaluate and improve our recruiting methods and strategies.
  7. To engage in lawful monitoring of job applicant activities and communications when they are on Firm premises or utilizing Firm internet and Wi-Fi connections, computers, networks, devices, software applications or systems.
  8. To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Firm.
  9. Infectious Disease Purposes (pandemic, outbreak, public health emergency, etc.): (a) To reduce the risk of spreading the disease in or through the workplace. (b) To protect job applicants and everyone else at Firm workplaces from exposure to infectious diseases (e.g., COVID-19). (c) To comply with local, state, and federal law, regulations, ordinances, guidelines, and orders relating to infectious diseases, pandemics, outbreaks, and public health emergencies, including applicable reporting requirements. (d) To facilitate and coordinate pandemic-related initiatives and activities (whether Firm-sponsored or through the U.S. Center for Disease Control and      Prevention, other federal, state, and local governmental authorities, and/or public and private entities or establishments, including      vaccination initiatives). (e) To identify potential symptoms linked to infectious diseases, pandemics, and outbreaks (including through      temperature checks, antibody testing, or symptom questionnaire). (f) To permit contact tracing relating to any potential exposure. (g) To communicate with job applicants and other consumers (including employees and visitors to our workplace) regarding potential exposure to infectious diseases (e.g., COVID-19) and properly warn others who have had close contact with an infected or symptomatic individual so that they may take precautionary measures, help prevent further spread of the virus, and obtain treatment, if necessary.
  10. To evaluate, assess, and manage the Firm’s business relationship with vendors, service providers, and contractors that provide services to the Firm related to recruiting or processing of data from or about job applicants.
  11. To improve job applicant experience on Firm computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
  12. To protect against malicious or illegal activity and prosecute those responsible.
  13. To prevent identity theft.
  14. To verify and respond to consumer requests from job applicants under applicable consumer privacy laws.

Sale/Sharing of Information to Third Parties

The Firm does not and will not sell your Personal Information or Sensitive Personal Information for any monetary or other valuable consideration. The Firm does not and will not share your Personal Information or Sensitive Personal Information for cross-context behavioral advertising.


Access to Privacy Policy

For more information, please review the Firm’s Privacy Policy at: https://www.griffincapital.com/privacy-policy/


EQUAL EMPLOYMENT OPPORTUNITY AT GRIFFIN

We are an equal opportunity employer, and all qualified applicants will receive consideration for employment without regard to age (40 and over), ancestry, color, religious creed (including religious dress and grooming practices), family and medical care leave or the denial of family and medical care leave, mental or physical disability (including HIV and AIDS), marital status, domestic partner status, medical condition (including cancer and genetic characteristics), genetic information, military and veteran status, political affiliation, national origin (including language use restrictions), citizenship, race, sex (including pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy, childbirth or breastfeeding), gender, gender identity, and gender expression, sexual orientation, or any other basis protected by applicable federal, state or local law, rule, ordinance or regulation.


We will consider qualified applicants with criminal histories in a manner consistent with the requirements of the Los Angeles Fair Chance Ordinance and the California Fair Chance Act and consistent with other similar and / or applicable laws in other areas.


We also afford equal employment opportunities to qualified individuals with a disability. For this reason, Griffin Capital will make reasonable accommodations for the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant consistent with its legal obligations and in accordance with applicable local, state and / or federal law. Any applicant who requires an accommodation in order to perform the essential functions of the job should contact a Human Resources Representative to request the opportunity to participate in a timely interactive process. 

 

This notice was last updated on March 27, 2024.