Notice at Collection and Privacy Policy for California Job Applicants

Last Updated: August 2023

Aaron Thomas Company, Inc. (“Company”) takes your privacy seriously. We want you to know how we collect, use, and disclose, your personal information.

California Notice at Collection: Company collects the personal information identified in Section 1 for the purposes identified in Section 3 and retains it for the period described in Section 5. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”). We also do not collect or process sensitive personal information for the purpose inferring characteristics about you.

EEO Statement
Company is an equal employment opportunity (EEO) employer.

EEO Statement
Company is an equal employment opportunity employer. Company’s policy is not to unlawfully discriminate against any applicant or employee on the basis of race, color, sex, religion, national origin, age, disability, or any other consideration made unlawful by applicable federal, state, or local laws. Company also prohibits harassment of applicants and employees based on any protected category, characteristic or status. It is also Company’s policy to comply with all applicable state, federal and local laws respecting consideration of unemployment status in making hiring decisions.

Company complies with the ADA, the ADAAA and applicable state law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job. Hire may be contingent upon a post-offer medical examination, and to skill and agility tests, as appropriate for the position.

Assistance For The Disabled
Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact HR@packaging.com for assistance.

This Privacy Policy explains:

  1. The categories of personal information we collect about you
  2. The categories of sources from which we collect your personal information
  3. The purposes for which we use your personal information
  4. How we may disclose your personal information
  5. How long we keep your personal information
  6. Your rights and how to exercise them
  7. Changes to this Privacy Policy

Scope:
This Privacy Policy applies to the personal information of California residents in their role as job applicants to Company (“Applicants”).

“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 Applicant.

“Personal information” does not include:

  • Information publicly available from government records or made publicly available by you or with your permission;
  • Deidentified or aggregated information;
  • Information excluded from the CPRA’s scope, such as:
    • protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”) or the Health Information Technology for Economic and Clinical Health Act (“HITECH”) or medical information covered by California Confidentiality of Medical Information Act (“CMIA”); or
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“FIPA”).

1) THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect the following categories of personal information. Not all categories may be collected about every Applicant.

  • Identifiers, for example: real name, nickname, telephone number, postal address, e-mail address, Social Security number, and signature.
  • Professional or Employment-Related Information, for example: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, and professional memberships and affiliations.
  • Non-public educational information, for example: academic transcripts.
  • Commercial Information, for example: travel expense records for an interview.
  • Internet or Other Electronic Activity Information, for example: interactions with Company’s Internet web site, job application, or job advertisement, and publicly available social media activity.
  • Sensory or Surveillance Data, for example: voice-mails and footage from video surveillance cameras.
  • § 1798.80: personal information described under Cal. Civ. Code § 1798.80 to the extent not already included in other categories in this section, such as a photograph or health information, for example, to conduct pre-employment physical examinations.
  • Other details, for example, hobbies and leisure activities or membership in voluntary/charitable/public organizations, for example, as stated on the Applicant’s resume.
  • Inferences, for example, Company might infer characteristics from a personality assessment completed by the Applicant.
  • Characteristics of Protected Classifications Under California or Federal Law for Applicants, collected on a purely voluntary basis, except where collection is required by law, and used only in compliance with applicable laws and regulations, for diversity and inclusion reporting and related purposes.

Note on inferring characteristics: Company does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the Applicant.

2) THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

We may collect the following categories of personal information. Not all categories apply to every Applicant.

  • You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
  • Vendors and service providers, for example, recruiters.
  • Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
  • Automated technologies on Company’s electronic resources, for example, to track logins and activity on Company’s careers page.
  • Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law
  • Government or administrative agencies, for example, law enforcement or public health authorities.
  • Acquired company, if Company acquired your employer, Company might collect personal information from that employer.

3) THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We may use the personal information we collect for one or more of the following purposes:

A. Generally Applicable Purposes

Unless stated otherwise in section 3.B, below, we may use Applicants’ personal information for the following purposes:

Recruiting, including:

  • To evaluate Applicants’ qualifications or suitability for employment with Company
  • To communicate with Applicants
  • To conduct a pre-employment or criminal history background check
  • For identification purposes
  • For diversity and inclusion purposes
  • To arrange and manage Company-sponsored events
  • To create a talent pool for future job openings
  • To demonstrate Applicants’ agreement to, or acceptance of, documents presented to them, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
  • To evaluate and improve the recruiting process
  • To promote Company as a place to work

Monitoring, Security, and Compliance, including:

  • To monitor and protect Company facilities and information systems
  • To ensure compliance with applicable laws and Company policies
  • To report suspected criminal conduct to law enforcement and cooperate in investigations
  • To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

Conducting Our Business, including:

  • For training purposes or quality assurance with respect to Company employees conducting the interviews or otherwise assisting with the recruiting and hiring process
  • For travel and event planning
  • To engage in crisis management
  • To manage travel reimbursements

Miscellaneous Other Purposes:

  • To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
  • To manage litigation involving Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
  • In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates; and
  • To protect the rights, property, or safety of Company, Applicants, customers or others.

B. Purposes Specific To Certain Categories Of Personal Information

We may use the categories of Applicants’ personal information listed in this Section 3.B for the purposes stated below:

Purposes For Using Applicant Health Information:

  • To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities
  • To protect the health and safety of Company’s employees and facilities, for example, to take the Applicant’s temperature
  • For occupational health and safety compliance and record-keeping
  • To conduct pre-employment medical examinations
  • To respond to an Applicant’s medical emergency

Purposes For Using Applicants’ Protected Categories Of Information:

Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, The Office of Federal Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act, and for purposes of diversity analytics.

Company also uses this personal information for purposes including: (a) with respect to disability and/or medical condition, as necessary, to comply with federal and California law related to accommodation; and (b) with respect to age, incidentally to the use of birth date for identity verification.

Company collects protected categories of personal information on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.

C. Deidentified Information
At times, Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that Company may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Company generally maintains personal information related to Applicants as confidential. However, from time to time, Company may have a legitimate business need to disclose Applicants’ personal information. In that event, Company discloses your personal information listed in Section 1, above, only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CPRA and other applicable laws.

A. Disclosures for Business Purposes

Company may disclose each of the categories of personal information listed in Section 1, above, to the third parties listed below for the following “business purposes” as that term is defined under the CPRA.

    • Service providers: Company may disclose to service providers any of the categories of personal information listed in Section 1, above, for the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in Section 3, above.
    • Auditors, lawyers, consultants, and accountants engaged by Company: Company may disclose the categories of personal information listed in Section 1, above, to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.
    • Affiliated companies: Company may disclose any of the categories of personal information listed in Section 1, above, to other companies within the [insert name of family of companies] family of companies for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

B. No Sales or Sharing

Company does not sell or “share” (disclose for cross-context behavioral advertising) your personal information in connection with the application process. In addition, we have no actual knowledge that we sell or share the personal information of individuals of any age in connection with the application process, including the personal information of children under 16.

C. Disclosures to Others

Company may disclose personal information to the following additional categories of third parties although these disclosures may be for purposes in Section 3, above, other than a business or commercial purpose as defined by the CPRA:

    • Your direction: We may disclose your personal information to third parties at your direction.
    • Clients: We may disclose your personal information to a client for whom the job position you are applying for primarily assists. For example, a customer service team member assigned to a specific client.
    • Government or administrative agencies: These may include, for example, the Equal Employment Opportunity Commission as required for reporting.
    • Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
    • Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, Applicants, or others.

4) HOW LONG WE KEEP YOUR PERSONAL INFORMATION

If Company hires you, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes. Company will retain this application information for the entire duration of your employment relationship with Company and for as long thereafter as permitted or required by applicable law. Company makes its document retention schedule available to employees for review.

Company will retain information of applicants who are not hired for four (4) years after the record is collected. These records will be retained for our internal recordkeeping and reporting purposes in compliance with California Government Code § 12946. During that time, we may use your information to consider you for positions in addition to the position(s) for which you initially applied.

5) YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

A. Your California Privacy Rights

Subject to applicable law, Applicants have the following rights:

  • Right to Know: You have the right to submit a verifiable request up to twice in a 12-month period for specific pieces of your personal information and for information about Company’s collection, use, and disclosure of your personal information.
    Please note that the CPRA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information. Moreover, Applicants have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients.
  • Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
  • Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.

B. How to Exercise Your Rights

Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

  • Call 877-667-8688
  • Email HR@pacakaging.com or Complete the request form available at www.packaging.com

C. How We Will Verify Your Request

We match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

D. Authorized Agents

You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorized Agent Designation” form by contacting us at HR@packaging.com. This provision does not apply if you have provided a power of attorney compliant with the California Probate Code.

E. Company’s Non-Discrimination and Non-Retaliation Policy

Company will not unlawfully discriminate or retaliate against you for exercising your privacy rights under the California Privacy Rights Act.

6) CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above.

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact us at HR@packaging.com.