ORC – Applicant Privacy Notice
Last updated October, 2023
This Applicant Privacy Notice (“Privacy Notice”) describes the collection, use, and sharing of your personal information when you apply for a position at O.R. Colan Associates, LLC (“ORC”, “us”, “we” or “our”). This Privacy Notice does not apply to third party sites or services outside of ORC’s careers page (“Careers Page”) and application process. For additional information, please see our main Privacy Notice.
I. PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG
When you apply for a position at ORC, we collect or receive personal information at various stages in the application process, as described below:
- Complete an application. When you apply for a position at ORC, we collect, from you, your personal identifiers (name, email address, telephone number, and physical address) your professional or employment information (resume/CV, certifications or licenses, qualifications, employment history, educational history, and references), and your education information (transcripts). If we offer you a position of employment and you accept the position, we will also collect, from you, your sensitive identifiers (Social Security number, driver’s license number, state identification number, or passport). Social Security number, driver’s license number, state identification number and passport are considered sensitive under the California Privacy Rights Act (“CPRA”). We use this information to determine your qualifications for the role you are applying to, and to confirm information related to your employment and education. For equal employment and affirmative action purposes, you also have the option to provide us with your protected classifications (gender, veteran status, and disability status), and your sensitive protected classifications (race and ethnicity). We use this protected classification and sensitive protected classification information for government reporting purposes, to comply with legal requirements, to analyze requested disability accommodations as applicable, and to document any accommodations we have provided to accommodate your needs.
- Information from references. When you provide references with your application, we will obtain from your references, your professional or employment information (confirmation of details on your resume/CV, certifications, qualifications, and employment history). We use this personal information to confirm details of your employment and job responsibilities.
- Responses to role-based aptitude and skills test. If you complete a role-based aptitude and skills test as part of our hiring process, we collect the responses you provided from our third-party test administrator, Mettl. We use your responses to draw inferences about your characteristics, intelligence, abilities, and aptitudes so that we can match you with jobs and determine your suitability for specific role(s).
- Credit report information. If you accept a position (assuming it is offered) at ORC that involves review/analysis of financial data, such as accounting-related positions, we also collect from credit reporting agencies your credit report (open lines of credit, outstanding balances, auto or student loans, foreclosures, late or missed payments, any bankruptcies and collection accounts, and other information returned in your credit report). We use this credit check to assess your fitness and suitability to the role you have applied for.
- Create a profile account. When you create a profile account (“Account”) on our Careers Page, we collect, from you, your personal identifiers (name, email address, and telephone number), your professional or employment information (resume/CV), and your online account information (Careers Page username and password). Once your Account is created, we will store your selected password (sensitive identifier). We use this personal information to assess your background and qualifications and to invite you to apply for specific positions at ORC. If you choose to apply for a specific position through your Account, we will also use this personal information to facilitate your application.
- Interact with our Careers Page. In addition to the personal information you provide or we collect from third parties, when you interact with our Careers Page, we collect information automatically via cookies and similar technologies. This includes the following internet or other electronic network activity information. We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information when you interact with the Careers Page. We use this information to: (i) track you within the Careers Page; (ii) enhance user experience; (iii) conduct analytics to improve functionality of the Careers Page; (iv) prevent fraudulent use of the Careers Page; (v) diagnose and repair errors, and, in cases of abuse, track and mitigate the abuse; and (vi) provide you information regarding the jobs to which you applied and those that may be of interest to you.
If you do not become an employee of ORC, we will retain your information for purposes of consideration for future positions, unless you submit a request to delete your information, in which case we will retain only what is legally required and only for as long as we are legally required to maintain it. If you do become an employee at ORC, your personal information is subject to our Employee Privacy Notice.
As part of the job application process, we recruit and screen candidates manually, without the use of profiling or automated decision-making capabilities.
II. HOW WE SHARE YOUR PERSONAL INFORMATION
A. General Sharing
ORC shares applicant personal information in the following instances:
- Within ORC. We share applicant personal information among our hiring decision-makers (i.e. human resources department, senior management, and hiring managers) to assess applications and make hiring decisions. Access to applicant personal information is limited to those on a need to know basis.
- In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share applicant personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share applicant personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
- For legal purposes. We share applicant personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.
B. Sharing in the Last Twelve (12) Months
For Business Purposes. In the preceding twelve (12) months, ORC has disclosed the following categories of applicant personal information for a business purpose to the following categories of service providers:
- With service providers: In the preceding twelve (12) months, ORC has shared applicant personal identifiers and professional or employment information with service providers that assist us in the application process. These third parties include our background check provider, cloud and SaaS application providers, IT support providers, and our third-party talent management provider.
For Sale. ORC only sells or shares applicant personal information via cookies as described above. ORC does not sell or share applicant personal information for monetary consideration.
III. RIGHTS OF CALIFORNIA RESIDENTS
The California Privacy Rights Act, (“CPRA”) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights:
- Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you. You may only submit a request for access twice within a twelve-month period.
- Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
- Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties. ORC does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. We only sell or share personal information under CPRA via cookies. Our use of third-party cookies may be deemed a sale or sharing under the CCPA/CPRA.
- Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA.
- Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain. If we believe the information in question is correct, we will ask you to provide documentation if it is necessary to rebut our own documentation that the personal information is accurate.
- Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the services or certain other permissible purposes. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin.
To exercise your right to know, access, or delete your personal information, or to limit use of sensitive personal information, you may submit a request through our Contact Us page or by contacting us toll-free at 704-529-3115. For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. When submitting your request, please describe the nature of your request and the nature of our relationship with you.
For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.
If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
IV. DO NOT TRACK
We will not place cookies or collect information via cookies when your browser is set to Do Not Track. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
V. INFORMATION SECURITY
We implement and maintain reasonable security measures to protect the personal information we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.
VI. PERSONAL INFORMATION OF CHILDREN
Our Careers Page is not intended for use by individuals under the age of eighteen (18) years. If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.
VII. CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is subject to change at any time. Changes to this Privacy Notice will be posted on this page and will indicate the date the changes go into effect. If we make any changes that materially affect your privacy rights, we will announce those changes by prominent post on the Careers Page and obtain your consent, if required.
VIII. CONTACT US
For questions on this Privacy Notice or the protection of your personal information and privacy rights, please contact our Corporate Office via telephone at 704-529-3115 or send us a message via Contact Us.