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NOCD Employee Privacy Notice

Last Updated: June 29, 2022


This Employee Privacy Notice describes how NOCD, Inc. (together with its affiliated companies, “Company,” “NOCD”, “we”, “us”, or “our”) collects, uses, and processes personal information of prospective candidates (“Applicants”) and current and past employees or contractors (collectively, “Employee,” “Employees,” “you,” or “your”).

The Company collects, processes, uses, discloses, and maintains records that contain personal information with respect to Employees and their employment relationship or other engagement with the Company. This notice describes the Company’s Employee Privacy Policy with respect to your employment or other engagement, compensation, and benefit programs. The notice informs you of the ways the Company may use and disclose personal information about you, describes your rights, and the obligations the Company has regarding the use and disclosure of your personal information. However, it does not address the privacy policies or practices of your third-party health care providers, administrators, or insurers.

NOCD’s Pledge Regarding Employee Privacy

The Company is committed to protecting your privacy. Company policies are intended to help protect information that identifies you or could be used to identify you, which you submit to the Company on an employment or consulting application, payroll forms, or benefit enrollment forms. Employees are required to respect the privacy of all personal information, handle all such information with confidentiality and protect the information from unauthorized access. Your personal information will not be used or disclosed to third parties, except as described in this notice or as otherwise permitted by law.

What is Personal Information?

Personal information is information that identifies you as an individual. It includes information including, but not limited to, your name, home address, home telephone number, social security number, driver’s license number, home e-mail address, employment history, disciplinary records, performance evaluations, medical information, bank account, and compensation.

Collection of Personal Information

We may collect the following information about you:

Identifiers. This includes real name, alias(es), date of birth, postal address, email address, IP address, social security number,* driver’s licenses number,* passport number,* or other similar identifier like a state identification card number.* In addition, we may collect your telephone number, including your mobile phone number, and the names and contact information of individuals you provide as an emergency contact.

Characteristics of protected classifications under California or federal law. This includes, age, race,* color,* national origin,* citizenship status, marital status, medical condition (including the condition of being pregnant), physical or mental disability, sex, gender, sexual orientation,* and military or veteran status.

Professional or employment-related information. This includes educational and employment histories. This also includes information that may be obtained during a background check, for example credit history, criminal record, civil actions in which you were involved, and past addresses.

Communication contents.* This includes metadata, such as the time and date of the message and intended recipients, as well as the contents of your mail, email, or other messages sent through an account owned, controlled, or licensed by us, for example, your business email or Slack chat history, or otherwise sent through our Network.

Information described in California Civil Code § 1798.80. This includes (1) identifiers listed above; (2) professional or employment-related information listed above; (3) bank account information, including information related to 401(k) or similar financial accounts; (4) medical insurance information, including the names and identifiers of your dependent(s); and (5) life insurance or other similar insurance information, including the names and identifiers of your dependent(s).

The information marked with an asterisk (*) above is considered “sensitive information” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act.

Use and Disclose of Your Personal Information

Personal information that we have collected from you will only be used for the specific purposes for which it was provided or obtained, or as authorized or required by law. Your personal information may be collected, used, and disclosed in the employment or consulting context for purposes that include but are not limited to the following:

• Screening of Applicants;
• Hiring of Applicants;
• Monitoring of Employee performance;
• Regulation of Employee performance;
• Evaluation of Employee conduct;
• Conducting investigations of Employee misconduct;
• Maintenance of Employee records;
• Termination of the employment relationship; and
• Litigation and settlement of Employee claims.Special Use and Disclosure Situations

The Company may also use or disclose your personal information under the following circumstances:

• In an emergency threatening an individual’s life, health, or security (the Company must inform the individual of the disclosure);
• To a lawyer, accountant, auditor, or other similar professional representing or working on behalf of the Company to evaluate the Company’s legal or financial rights or capabilities;
• To comply with a court or administrative order, a subpoena, warrant, discovery request, or other lawful due process;
• To provide assistance to a public body or law enforcement agency concerning an offense under federal or state law(i) to determine whether the offense has taken place, or (ii) to prepare for the laying of a charge or the prosecution of the offense;
• To provide to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or assessment thereof, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets;
• If permitted or required by law.

Internal and Third-Party Disclosures:

Background Checks: To protect the Company’s interests and the safety of Company Employees and to ensure that the information reported on the employment application is verified in compliance with applicable regulations and insurance requirements, the Company may engage a third-party provider to perform a background check on any Applicant following a contingent verbal or written employment or consulting offer. The Company takes steps to help ensure that background checks are performed in accordance with applicable law. Offers of employment or engagement are contingent upon the satisfactory completion of the background check. In addition, background checks may be performed at any time during the employment/consulting period, including situations when the Employee is being considered for promotional opportunities.

Employment Administration, Payroll Administration, Benefit Administration:
The Company may disclose your personal information to designated Company personnel so they can carry out their Company-related administrative functions, including the uses and disclosures described in this notice. Such disclosures will be made only for the purposes of managing the employment/engagement of the Employee. We have taken steps to ensure that these individuals will protect the privacy of your personal information and ensure it is used only as described in this notice or as permitted by law.

To a Service Provider: Certain services are provided to the Company by third-party administrators. For example, the Company may input information about your compensation into a payroll processing system maintained by the Company’s service provider so your compensation may be paid. In so doing, the Company will disclose your personal information to its service provider so it can perform its payment function. However, the Company will require its service providers, through contract, to appropriately
safeguard your personal information.

Your Rights Regarding Personal Information About You

Residents of California have the right to: (1) know what personal information we collect, use, disclose, and sell; (2) request that we delete your personal information; (3) access and obtain a copy of your personal information that we collect; (4) request correction of inaccurate personal information; (5) opt out of targeted advertising; and (6) limit the use and disclosure of certain sensitive information. We will honor your request to the extent required by applicable law and will make a good faith effort to honor your request in all other cases. To exercise your rights, please contact us at privacy@nocdhelp.com or at 312-766-6780. For citizens of the European Union or United Kingdom, you can use this form to submit a request regarding your personal information that is processed by NOCD. If you disagree with our response to your request, you may appeal the request by submitting supporting documentation to legal@nocdhelp.com.

You will not be penalized or retaliated against for filing a complaint.

Changes to this Notice

The Company reserves the right to change this notice at any time and to make the revised or changed notice effective for personal information the Company already has about you, as well as any information the Company receives in the future. The Company will post a copy of the current notice for view by all Employees.

Your Personal Information after Separation

In the event of your separation from the Company, we will continue to protect your personal information and will use and disclose the information only for the specific purposes for which it was obtained.

Contact Information

All requests, questions, or concerns around this notice or the Company’s privacy policies or practices should be directed to privacy@nocdhelp.com or your immediate supervisor or point of contact at the Company. The Company will make every attempt to accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.