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The California Consumer Privacy Act (CCPA)

CCPA Job Applicant Disclosure – 1/1/2020

Thryv, Inc. provides this notice and disclosure pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), as to its job applicants who are residents of the State of California. Any terms defined in the CCPA have the same meaning when used in this notice. To the extent, and as of the date that a job applicant accepts an offer of employment or contract work from Thryv, Inc. the company’s disclosure as to information collected from or about employees and contractors will apply to such individual.

Collection of Personal Information

Thryv, Inc. may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (“personal information”) as to persons who are job applicants to Thryv, Inc. and are residents of California. Per the CCPA, personal information does not include:

  • Publicly available information that is lawfully made available from government records.
  • De-identified or aggregated information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information collected or maintained pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, Thryv, Inc. has collected the following categories of personal information from or about such job applicants within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, etc. Some Personal Information included in this category may overlap with other categories.YES
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), etc.YES
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.NO
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, video security surveillance, and sleep, health, or exercise data.YES
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.NO
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NO
I. Professional or employment-related information.Current or past job history or performance evaluations.YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.YES
K. Inferences drawn from other Personal Information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES

Use of Personal Information

Thryv, Inc. may use or disclose the personal information we collect regarding our job applicants for, or in the course of, one or more of the following business purposes:

  • To comply with state and federal law(s) requiring businesses to collect, monitor, maintain or transfer certain records regarding applicants or applications for employment or contract work, including demographic characteristics;
  • To assess ability, fitness or eligibility of applicant to fulfill or perform prospective job duties and work in relevant corporate location and environment;
  • To schedule travel, and pay for or reimburse job applicants for covered business expenses related to the job application or interview or similar expenses;
  • To comply with the provisions of collective bargaining agreements as to prospective employees;
  • To maintain and protect the rights, security and safety of job applicants, our personnel, clients and others, as well as our facilities, premises and other property;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • To provide job applicants with information, products or services related to the job opportunity or that they request from us;
  • To provide job applicants with notices or announcements concerning our business operations, opportunities, or policies that may be relevant and/or of interest to them;
  • To fulfill or meet the reason for which the information was provided to us by the job applicant;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Last Updated 2/4/20