Privacy Notice for California Consultants and Candidates

 

Effective Date: June 1, 2023

Last Reviewed On: June 1, 2023

1. Purpose: The Matlen Silver Group, Inc.  (“Matlen Silver”) has adopted this policy to define requirements for the treatment of the personal information for consultants or candidates and residing in California, specifically how Matlen Silver may collect and use information about you. Note that as a consultant that may be placed with other companies, you may also receive privacy notices about the use of your information from those other companies.  Matlen Silver does not control those other entities and if you have any questions about the use of your personal information by those other companies, please contact them directly. This notice is intended to provide you with information about Matlen Silver’s practices only and is intended to comply with the data privacy laws in California.

2. Policy: As a consultant with Matlen Silver, this policy applies to you if you reside in California (“you”). This policy, as outlined below, may be modified from time to time without prior notice.  Where Matlen Silver collects additional categories of personal information or uses the personal information we collected for materially different, unrelated, or incompatible purposes, Matlen Silver will provide you with notice, including posting the updated notice on www.matlensilver.com and update the notice’s effective date.

1. Policy and Procedures Review: The policy and related procedures will be reviewed every 12 months or as necessary.

4. Personal Information: Matlen Silver collects and maintains different types of personal information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“personal information”) and is about its consultants and candidates in accordance with applicable law.
5. Collection and Sharing of Personal Information: Matlen Silver has collected the following categories of personal information about you within the last twelve (12) months:

Category	Examples	Purpose	Third Parties Shared
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	(a) Performance of employment activities, including conducting payroll or providing other benefits. (b) Necessary for our legitimate business interests, including to recruit and bring on consultants and candidates for placement at client locations. (c) Necessary to comply with a legal obligation, for example, drug testing.	(a) Matlen Silver’s clients where consultants are placed (b) Human resources information service providers (c) Financial investment service providers (d) Health Insurance providers (e) Payroll service providers (f) Physical security vendors
California Customer Records Law	A name, signature, Social Security number, contact information, insurance policy number, education, employment history, financial information, medical information and health information.	(a) Performance of employment activities, including conducting payroll or providing other benefits. (b) Necessary for our legitimate business interests, including to recruit and bring on consultants and candidates for placement at client locations. (c) Necessary to comply with a legal obligation, for example, drug testing.	(a)  Matlen Silver’s clients where consultants are placed (b)Human resources information service providers (c) Financial investment service providers (d) Insurance providers (e) Payroll service providers (f) Physical security vendors
Protected classification characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.	(a) Necessary for our legitimate business interests. (b) Necessary to comply with a legal obligation, including mandatory reporting requirements.	(a)  Matlen Silver’s clients where consultants are placed (b) Human resources information service providers (c) Financial investment service providers (d) Insurance providers (e) Payroll service providers (f) Physical security vendors
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	N/A	N/A
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints.	N/A	N/A
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	(a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation	(a) Analytics and business intelligence vendors (b) Security vendors
Geolocation data	Precise geolocation through IP address (device location); physical location or movements within office locations via surveillance cameras.	N/A	N/A
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	N/A	N/A
Professional or employment-related information.	Current or past job history or performance evaluations.	(a) Necessary for our legitimate business interests, including to verify task training and obtain policy consent and recruit and hire candidates.	(a)  Matlen Silver’s clients where consultants are placed (b) Human resources information service providers
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	(a) Necessary for our legitimate business interests, including to verify task training and obtain policy consent and recruit and hire candidates.	(a)  Matlen Silver’s clients where consultants are placed (b) Human resources information service providers
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	(a) Necessary for our legitimate business interests, including to recruit and hire candidates and determine and assess tendencies and performance.	(a) Talent assessment service providers
Sensitive personal information	Personal information that reveals government IDs; precise geolocation; racial or ethnic origin; personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	(a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation, including mandatory reporting requirements.	(a)  Matlen Silver’s clients where consultants are placed (a) Human resources information service providers (b) Financial investment service providers (c) Payroll service vendors (c) Government entities or regulators

6. Additional Uses of Personal Information. In addition to the uses described above, Matlen Silver may also use your personal information for the following purposes:
   1. To investigate and help prevent fraud or otherwise ensure compliance with policies and procedures.
   2. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
   3. To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
   4. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
   5. As described to you when collecting your personal information.
   6. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Matlen Silver’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Matlen Silver about our employees, contractors, consultants, or employee candidates is among the assets transferred.

Additionally, Matlen Silver obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or by communicating with us by post, phone, email or otherwise.
• Indirectly from you. For example, from observing your actions on our computer systems or other platforms.
• Third parties. For example, from vendors we use for background checks or our clients where you are placed.

7. Disclosure of Personal Information: Matlen Silver may share your personal information for business purposes by disclosing it to the categories of third parties identified in the chart above. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
   1. We do not sell or share (for cross-context behavioral advertising) your personal information.
   2. We may disclose sensitive personal information, including gender, race, ethnicity, or sexual orientation, as identified by you, to prospective or current clients who request this information for diversity statistics or otherwise use sensitive personal information outside of the permissible uses identified within the CCPA. You may have the right to limits the use of your sensitive personal information. If you would like to exercise this right, please contact us at [email protected].
8. Retention Periods: Matlen Silver will generally retain information about you for so long as we have a legal or business purpose for it or a legal requirement to maintain it. The criteria used to determine our retention periods include:
   1. the length of time we have an ongoing relationship with you (for example, for as long as you are working as a consultant with Matlen Silver or a prospective consultant) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
   2. whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
   3. whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
9. Your Rights and Choices: You may have rights regarding your personal information. This section describes the rights you may have and explains how to exercise those rights.
   1. Access to Specific Information: You may have the right to request that Matlen Silver disclose certain information to you about our collection and use of your personal information over the past 12 months.
   2. Deletion Request Rights: You may have the right to request that Matlen Silver delete any of your personal information that we collected from you and retained, subject to certain exceptions. If an exception applies, we will advise you of the applicable exception and the reason for denying your request.
   3. Correction Request Rights: You may have the right to request that Matlen Silver correct any inaccurate personal information we may hold about you. We will use commercially reasonable efforts to correct inaccurate personal information, taking into the account the nature of the personal information and the purpose for our processing.
   4. Right to Limit the Use of Sensitive Personal Information: You may have the right to limit how we use and disclose your sensitive personal information. At any time, on request, you can restrict our use and disclosure of sensitive personal information to just the permitted purposes under the CCPA. Sensitive personal information that is collected or processed without the purpose of inferring characteristics about you is not subject to the right to limits its use and disclosure.
   5. Non–Discrimination: We will not discriminate against you for exercising any of your rights.
10. Exercising Your Rights: To exercise your rights described above, please submit a request by either:
    1. Sending us an email at [email protected].
    2. Calling us at 908-393-8600.
    3. https://matlensilver.com/contact/

We may need to validate your request.  In order to validate your request, we may ask you for the following information; name, dates of employment, company where you were placed as a consultant. Only you or an authorized agent may make a request related to your personal information. To designate an authorized agent to make a request on your behalf, please provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also verify the identity of your designated agent.

11. Questions About This Notice: If you have any questions or comments about this notice or the ways in which Matlen Silver collects and uses your information, please contact:

Human Resources

[email protected]