Effective Date: January 1, 2020

The California Consumer Privacy Act of 2018 (“CCPA”) imposes specific obligations on businesses processing personal information of California residents. Pursuant to the CCPA, Pacific Dental Services® LLC, its subsidiaries and affiliated entities (collectively, “PDS”, “we” or “us”) is required to provide its employees who are California residents (“California Persons”) a notice, used at or before the point of collection of such personal information, that identifies the categories of personal information that may be collected and why PDS collects such information.

This California Employee Privacy Notice (“Notice”) is intended to provide California Persons with the CCPA required notice.

1. Updates

This Notice will be updated at least once every twelve (12) months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes by visiting https://www.pacificdentalservices.com/.  We will not collect additional categories of your personal information or use your personal information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective on the date we post the updated Notice to our website.

2. Definitions:

“Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a PDS job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with PDS; “employee” refers to any person who is or was previously employed at PDS as a full-or part-time employee, temporary worker, owner, director, or officer; and “contractor” means a natural person who provides any service to a business pursuant to a written contract.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information or information that has been de-identified.

3. Personal Information We Collect About You

We may collect the following categories of personal information about you:

• Identifiers: This includes a real name; postal address; email address; phone number; emergency contact details; online account name and password; security question and answer; birth certificate; children’s names; parents’ names; mother's maiden name; marriage license; death certificate; passport number; national identification number; driver's license number; social security number; tax id number; government identification card number; immigration/naturalization number; retirement account number; beneficiary number; and National Provider Identifier (NPI);
• Commercial information: This includes vehicle make and model, VIN number; vehicle license plate number;
• Device and Online Identifiers and Related Information: This includes information relating to Internet activity or other electronic network activity, including website history; browsing time; device identifier/serial number; IP address; and media access control address (MAC address);
• Biometric Information:  This refers to facial images/photographs; shirt size; height; and weight;
• Geolocation Data: We may receive information about your location including from your mobile device(s) or vehicle(s), such a GPS coordinates;
• Sensory Data: This includes audio, electronic, or visual information; which may include video surveillance information; photographs; and other audio-visual information;
• Professional or Employment-Related Information: This includes professional or employment-related information, such as job title/role; employment identification number; company/entity; office location; business unit/division; line/reporting manager; employment status; start date; end date and reason for termination; exit interview; hours of work; record of absence/time tracking/annual leave; employment history; employment contract type; benefits and entitlements information; health and safety related information and reporting; performance rating; disciplinary action; grievances and complaints; salary/wage information; salary/wage expectation information; bonus payments; tax information; expense and reimbursement information; workers compensation claims; job application details; resume information; previous work history; and other employment information; professional memberships; professional licenses; qualifications/certifications; malpractice insurance information; DEA certificate and number; professional references; aptitude assessment results; and resume cover letter.
• Education information: This includes education history; educational degrees; academic transcripts/grades; training history; languages; and certifications/courses;
• Information not listed above and related to characteristics protected under California or federal law, this includes date of birth; age; gender; birthplace; nationality; racial or ethnic origin; citizenship status; marital status; family information; pregnancy; disability status; criminal history; drug test results; tobacco use indicator; veteran status; health and medical information;
• Other personal information not listed above, such as signature; physical characteristics or description; insurance Notice number; bank account number; credit card number; debit card number; and other financial, health and medical information or health insurance information; and legal issues (e.g., child support, alimony, wage garnishments and subpoenas).

Personal Information does not include deidentified or aggregated consumer information.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or services we provide you.
• Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
• Third parties. For example, staffing and recruiting agencies with whom we contract for services and consumer reporting agencies when we perform employee background screenings.

4. How Do We Use Your Personal Information?

We may collect or use personal information from you for the following purposes:

PDS collects the personal information identified in Section 3 above for the reasons listed below.

• To Process Employment Applications and Onboard New Hires, including to conduct employment related background screening and checks; and recruiting.
• To Credential Healthcare Practitioners, which includes both employee practitioners and independent contractor practitioners for participation on insurance carrier and managed care plan provider panels, including any legally required reporting to, and queries of, national provider data banks.
• To Administer Benefits, such as medical, dental, vision, wellness, EAP, life, retirement benefits, and reimbursement and assistance programs, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management.
• To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals.
• To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.
• To Monitor Work-Related Licenses and Credentials, including provisioning licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.
• To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.
• To Maintain Your Contact Information, including altering your details across relevant entities within PDS affiliated entities (for example personal, other employment and transferring roles).
• To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.
• To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.
• To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures.
• To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.
• To Ensure a Safe and Efficient Working Environment, which includes PDS actions relating to disciplinary actions, and code of conduct processes and investigations.
• To Maintain Security on PDS Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of PDS’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
• To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount by ethnicity and gender, management information, demographic and Health, Safety, Security and Environmental reporting.
• For other employment and HR purposes.

Any information collected is disclosed to you here and is used as permitted or required by law.

5. Rights to your Personal Information

You have a number of legal rights when it comes to your Personal Information, including the right to be informed about the Personal Information we collect and the purposes for which we use your Personal Information.

Your rights under certain applicable laws, such as rights to request access to or deletion of all Personal Information we may hold about you do not apply to employees and other personnel at this time. However, under other laws, you may have access to certain personnel details to verify the accuracy of or update your data, or you may have other privacy rights as an employee, and you can contact your PDS People Services Representative for more information and assistance.

• Initiate a request by submiting a CCPA Request Form.

As further detailed in our polices on information security, you have no right to privacy in your use of PDS information technology resources, including emails and communications for work purposes which constitute PDS business records and which are monitored and may be reviewed or disclosed at any time without further prior notice for compliance, legal and other operational needs.

6. How Do I Contact PDS with Questions About the CCPA Employee Privacy Notice?

If you have any questions about this CCPA Employee Privacy Notice, please email us at: privacy@pacden.com.