Effective Date: May 7, 2024

This California Job Applicant Privacy Notice (“Notice”) describes the categories of personal information ISYS Solutions, Inc. and its affiliate doing business as CareerSmart Learning, a wholly owned division of ISYS Solutions, Inc. (“ISYS” or “we”) collect about California candidates who apply and/or are evaluated for jobs with ISYS Solutions, Inc. (“Job Applicants”). Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”). For more information about our Privacy Practices please see our company website privacy policy: website privacy policy.

Collection and Use of Personal Information

ISYS may collect (and may have collected during the 12-month period prior to the Effective Date of this Notice) the following categories of personal information from Job Applicants:

  • Employment Information: professional or employment-related information, such as information relating to your position (e.g., job title and job description) and talent management information (e.g., résumé information, references, occupation details, education details, certifications and professional associations, historical compensation details from previous employment (if voluntarily provided or as permitted by law), previous employment details, and pre-employment screening and background check information, including criminal records information)
  • Identifiers such as a real name, alias, postal address(es), telephone number, email address, Social Security number, driver’s license or state identification card number, Passport identification number date and/or place of birth, IP address, and other similar identifiers
  • Additional Data: This includes information subject to Cal. Civ. Code § 1798.80, such as your signature, physical characteristics or description, education information, financial information and medical information
  • Protected Classifications: racial or ethnic origin, religious or philosophical beliefs, biometric information for the purpose of uniquely identifying a consumer, and characteristics of protected classifications under California or federal law, including but not limited to race, color, national origin, religion, age, sex, gender, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status
  • Sensitive Personal Information. This category includes sensitive information such as those indicated above and including the following:1. social security, driver’s license, professional license, state identification card, or passport number
    2. racial or ethnic origin, religious or philosophical beliefs, or union membership,
    3. biometric information for the purpose of uniquely identifying a consumer, and
    4. information concerning health, sex or sexual orientation
  • Inferences: inferences drawn from certain parts of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, browser type and version, search history, and information regarding your interaction with websites or applications
  • Sensory Information: audio, electronic, visual, and similar information

We may use (and may have used during the 12-month period prior to the Effective Date of this Notice) the personal information described above for the purpose of processing job applications, evaluating candidates for employment, and/or carrying out and supporting Human Resources (“HR”) functions and activities, including as described below. In addition to these general HR purposes, the purposes listed below also include relevant “business purposes” as they are described in the CCPA.

  • Recruiting; processing job applications; performing background and other pre-employment checks; determining suitability for employment; determining physical and/or mental fitness for work; reviewing and evaluating applications; determining salary and other forms of compensation; providing references; reimbursing expenses; making travel arrangements; securing eligibility to work statuses; reviewing hiring decisions; and providing access to facilities.
  • Ensuring business continuity; protecting the health and safety of our staff and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities, and other property; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you.
  • Operating and managing our IT, communications systems, and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; managing any investment in or transactions relating to our business; and providing senior management oversight of the firm.
  • Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management, and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing complaints or claims; conducting investigations; and complying with internal policies and procedures.
  • Performing services.
  • Certain short-term, transient uses.
  • Helping to ensure security and integrity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance them.
  • To facilitate other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, mergers and acquisition activities; and maintenance of licenses, permits and authorization applicable to Company operations.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We retain your personal information for as long as necessary to process your application for employment and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal Information does not include certain categories of information, such as publicly available information from government records, deidentified or aggregated consumer information, and information subject to HIPAA or the California Confidential Medical Information Act.

Sources of Personal Information

During the 12-month period prior to the Effective Date of this Notice, we may have obtained personal information about Job Applicants from the following categories of sources:

  • Directly from you;
  • Your devices;
  • Other individuals, such as in connection with a referral or reference;
  • Your employer;
  • Our affiliates;
  • Vendors who provide services on our behalf such as professional services organizations and recruiting agencies and background checks;
    Data analytics providers;
  • Government entities;
  • Social networks;
  • Public databases.

Disclosure of Personal Information

We do not sell, or share for cross-context behavioral advertising purposes, personal information about Job Applicants. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary to process your application as reasonably expected by an average job applicant.

During the 12-month period prior to the Effective Date of this Notice, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information

Sensitive Personal Information including Identifiers, Additional Data Subject to Cal. Civ. Code § 1798.80 and Protected Classifications

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Internet service providers and operating systems and platforms
  • Data analytics providers
  • Data brokers, such as background check services
  • Government agencies

Category of Personal Information

Online Activity, Sensory Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Internet service providers and operating systems and platforms
  • Data analytics providers
  • Government agencies

Category of Personal Information

Employment Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network
  • Partners and investors, if applicable
  • Internet service providers and operating systems and platforms
  • Data analytics providers
  • Data brokers, such as background check services
  • Government agencies

Category of Personal Information

Inferences

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network
  • Partners and investors, if applicable
  • Government agencies

California Consumer Privacy Rights

If you are a Job Applicant, you have certain choices regarding your personal information, as described below.

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
  • Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you. There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Such instances include, but are not limited to, enabling solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information or to comply with a legal obligation.

We will not discriminate or retaliate against you for exercising any of your rights as described above.

How to Submit a Request. To submit an access, correction or deletion request on your own behalf or as an authorized agent, email us at [email protected] or call our toll-free number at (800) 992-8100.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of or deletion of your personal information, we may require you to authenticate your email address and/or provide information about your job application or other interactions with us. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the Job Applicant whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. We reserve the right to amend this California Job Applicant Privacy Notice at any time without advance notice.

How to Contact Us

If you have any questions regarding this California Job Applicant Privacy Notice or our privacy practices, please contact us at [email protected] or our toll-free number at (800) 992-8100.