CALIFORNIA JOB APPLICANT PRIVACY NOTICE
Effective Date: January 1, 2023
LAST UPDATED January 1, 2023
Syneos Health, together with its subsidiaries and affiliates (collectively, "Company" "us," "we," or "our") is committed to protecting the privacy of Personal Information (defined below). This California Job Applicant Privacy Notice (“CCPA Applicant Privacy Notice”) informs you of our practices concerning the processing of Personal Information collected through our websites and through other online and offline interactions when you apply for a job with the Company. This CCPA Applicant Privacy Notice does not apply to Personal Information we may collect about you in other contexts, such as information we collect about you if you do other business with us or once you have become an employee.
We are required by the California Consumer Privacy Act of 2018, as amended, (“CCPA”) to explain to California residents, including Applicants, our online and offline practices with regard to how we collect, use and share their Personal Information, and the rights and choices we offer them regarding our handling of their Personal Information.
Changes: We may update this CCPA Applicant Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this CCPA Applicant Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated CCPA Applicant Privacy Notice.
This CCPA Applicant Privacy Notice does not form part of any contract of employment or other contract to provide services and does not give you any contractual rights.
1. Sources of Personal Information
“Personal Information” is any information relating to an identified or identifiable natural person.
We may collect Personal Information about you from the following sources:
A. Directly from you. We may collect Personal Information you provide to us directly, such as when you complete a paper or online application (including on a dedicated online talent management platform), communicate with us in connection with your application, provide references, or participate in an interview or any aptitude test or assessment (including online). We may also collect your Personal Information when you decide to complete questionnaires, such as a satisfaction survey or a diversity and inclusion questionnaire.
B. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and tracking technologies if you interact with our websites. This may include information about how you use and interact with our websites, information about your device, and internet usage information.
C. From third parties. We may collect Personal Information from third parties, such as companies or individuals who direct or refer you to us (including third-party staffing or recruiting firms or individuals who suggest or identify you, as well as from publicly available sources and third-party professional social networking websites). Where permitted or otherwise authorized by law, we may also collect information received from third parties in connection with references or background checks.
We may combine and use information and make inferences from information that we receive from the various sources described in this CCPA Applicant Privacy Notice, including third party sources. We also use or disclose the combined information and inferences for the purposes identified below.
2. Types of Personal Information We Collect
We may collect the following types of Personal Information about you such as:
A. Identifiers, such as your name, email address, physical address, telephone number, and other contact information.
B. Records About You, such as
1. Signatures; and
2. Your physical characteristics or a description of you;
C. Protected class and demographic information, such as your age (including birthdates), military or veteran status, and your gender.
D. Commercial information, such as salary and wage information and history.
E. Internet or other electronic network activity information, such as your browsing history, search history, and information regarding your interactions with and use of our websites, including via cookies and other tracking technologies. Please see Section 5 below for further information.
F. Non-precise geolocation data, such as your location as derived from your IP address.
G. Audio, electronic, visual, or other sensory information, such as photographs or security camera footage in public areas of the Company’s facilities (including reception, the work floor, conference rooms, parking, and other general areas) if you participate in on-site activities, such as a job fair, job interview or aptitude test, as well as photographs, audio, or footage collected in the course of video interviews or through an online applicant platform, or other recordings.
H. Professional or employment-related information, such as resume or curriculum vitae information, certifications, qualifications, membership in professional bodies, employment history, job preferences (including your willingness to relocate or travel), documentation required under immigration and employment laws (such as citizenship, visa data, details of residency, and work permit information), and such other information you provide. We may also collect and process information about you generated during or after interviews and related activities, such as tests or satisfaction surveys. This information may come directly from you or from our employees or contractors.
I. Education Information, such as education history, professional qualifications, academic certificates and licenses, languages spoken, and other relevant skills.
J. Inferences drawn from any of the information we collect, such as likelihood of your profile being a good fit with our internal team and long-term prospects with the Company.
K. Sensitive Personal Information, including but not limited to the following, where permissible or required under applicable laws and regulations:
1. Social Security number, driver’s license, passport, and other government-issued forms of identification (including both copies of documents and identifying numbers).
2. Account log-in information.
3. Racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership.
4. Information about your health, such as disability status and information about such disability, drug-test results, vaccination status, and food intolerances (if, for instance, we invite you for a meal or we book a flight for your job interview).
3. How We Use Personal Information
We may use Personal Information for the following purposes:
A. In connection with your application, such as assessing your application, interview, and test results for suitability for the position for which you have applied or other open positions; communicating with you concerning job openings or your application; conducting pre-employment verification and screening; offering you the job position, in our discretion; notifying you of job opportunities (including from affiliates in our group, where we have shared your job application with them); and dealing with any inquiry, challenge, or request for feedback received in relation to our recruitment and hiring decisions.
B. For our internal business purposes, such as managing and improving our recruitment process (for example, enhancing our scouting and talent identification processes); enforcing our policies and rules; and operating our diversity and inclusion initiatives.
C. For legal, safety or security reasons, such as complying with legal requirements, processes, or orders; complying with reporting and similar requirements; complying with government inspections and other requests from government or other public authorities; pursuing legal rights and remedies; investigating and responding to claims against the Company and its customers and employees; monitoring and managing equal opportunity programs; screening and conducting background checks (as required or permitted by law); protecting our, your, our customers’, and other individuals’ safety, property or rights; addressing security and health and safety issues (including managing spread of communicable diseases) and malicious, deceptive, fraudulent, or illegal activity; ascertaining your eligibility for work; and receiving legal advice or approval.
D. In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.
E. For promotional purposes, such as to notify you about new job openings in accordance with your preferences.
We may use anonymized, de-identified, or aggregated information for any purpose.
4. How and to Whom We Disclose Personal Information
We may disclose Personal Information to third parties, including the categories of recipients described below:
A. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership with us.
B. Service providers that work on our behalf to provide products and services, such as IT support providers, software service providers, background check vendors, and drug-screening providers.
C. Professional consultants, such as recruiters, accountants, lawyers, financial advisors, and audit firms.
D. Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
E. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our policies, and to protect ours, our customers’, or third parties’ safety, property or rights.
F. To other entities in connection with a corporate transaction, such as if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.
G. Business partners, such as certain travel services, recruitment firms, companies that operate cookies and other tracking technologies, social media companies, and certification providers. Where required by law, we will obtain your consent prior to disclosing your Personal Information to our business partners.
H. Entities to which you have consented to the disclosure, where consent is required by law.
5. Cookies and Other Tracking Technologies
6. Tracking Opt-Out Guide
Like many companies online, we use services provided by Google, Facebook and others companies that use tracking technology. These services rely on online tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, about your interactions with websites, and about the device you are using to connect to the Internet. There are a number of ways to opt out of having you online activity and device data collected through these services, which we have summarized below:
• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest- based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
• Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
o Digital advertising Alliance
o Network Advertising Initiative
7. Data Security and Data Retention
The Company maintains appropriate administrative, technical, and organizational measures designed to protect Personal Information against risks such as leakage, destruction, loss, damage, or accidental, unlawful or unauthorized, alteration, access, disclosure or use. We require third party recipients of your Personal Information to apply similar protections when they process Personal Information we share with them. Please note that no system is completely secure. While we strive to protect Personal Information, we cannot guarantee that unauthorized access, data loss or a data breach will never occur.
The Company will retain Personal Information for so long as necessary to fulfill the purpose for which it was collected and processed. To determine the appropriate retention period for Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we processed the Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements. We delete, erase, destroy or anonymize Personal Information when it is no longer needed, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible
7. Supplemental Information for California Residents
A. Rights Concerning Personal Information
California residents may have certain rights, subject to legal limitations, concerning the collection, use, and disclosure of Personal Information.
• Right to Know. You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting, selling, or sharing the Personal Information, and to whom we have disclosed Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you.
• Right to Delete. You have the right to request that we delete Personal Information that we have collected from you.
• Right to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you.
California residents may exercise the Right to Know, the Right to Delete, and the Right to Correct via our webform or by calling us at 866-875-1569.
We will not discriminate against you for exercising your privacy rights.
Verification: In order to process requests, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases, we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are, and will inform you if we need such information. Authorized Agents: Authorized agents may exercise rights on behalf of California residents by submitting a request via [our webform] and indicating that they are submitting the request as an agent. We will require the agent to demonstrate authority to act on behalf of the resident by providing signed permission from the resident. We may also require the resident to verify their own identity directly with us or to directly confirm with us that they provided the authorized agent permission to submit the request.
Timing: We will respond to Right to Delete, Right to Correct, and Right to Know requests within 45 days, unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.
B. Additional Data Processing Disclosures
In addition to the disclosures above, this section provides supplemental information about how we process Personal Information.
Disclosure of Personal Information
We do not knowingly sell or share Personal Information as defined by CCPA. We do not knowingly collect, sell or share Personal Information of minors under the age of 16.
Below please find a chart detailing the categories of Personal Information we may have collected and with whom it may have been disclosed for a business purpose in the past 12 months:
Categories of Personal Information We May Collect
Categories of Third Parties With Whom We May Disclose Personal Information for a Business Purpose
Categories of Third Parties to Whom Personal Information May be Sold or Shared
Identifiers (Section 2.A)
Personal information subject to the California Customer Records Act (Section 2.B)
Characteristics of protected classifications under California or federal law (Section 2.C)
Commercial information (Section 2.D)
Internet or other electronic network activity (Section 2.E)
Geolocation data (Section 2.F)
Audio, electronic, visual, olfactory, or similar information (Section 2.G)
Professional or employment-related information (Section 2.H)
Education information (Section 2.I)
Inferences (Section 2.J)
Sensitive personal information (Section 2.K)
Sensitive Personal Information
We do not collect or process Sensitive Personal Information to infer characteristics about you.
8. How to Contact Us
Should you have questions baout the Personal Information about you that the Company processes, or should you have any requests or concerns related to this CCPA Applicant Privacy Notice, you may contact Talent Acquisition.
You may also contact the Company's Global Data Privacy Office as set forth in our Privacy Statement.