Privacy Notice for Employees, Job Applicants and Contractors who are California Residents
Covestro LLC and its subsidiaries and affiliates (collectively, the “Company”) respects and takes seriously the security and privacy of your personal information. This Privacy Notice for Employees, Job Applicants and Contractors who are California Residents (“Employee CCPA Notice”) describes how the Company handles the Personal Information (as defined below) of employees, job applicants, contractors, and other staff, the reasons why we collect the information, and how it may be used or disclosed to others.
This Employee CCPA Notice is a supplement to our Privacy Statement and applies to the “Personal Information,” as such term is defined in the California Consumer Privacy Act of 2018 (“CCPA”), or “Sensitive Personal Information,” as that term is defined in the California Privacy Rights Act (CPRA) of 2020, and applies only to natural persons who reside in the State of California. The CCPA and CPRA are collectively identified as the CCPA in this notice.
The Company receives Personal Information and Sensitive Personal Information from and about you during the course of hiring and employing or engaging you, and may continue to receive some Personal Information from you from time to time during the course of your work for the Company. For employees, we may also receive Personal Information about your dependents and beneficiaries under certain of our benefits programs. “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 individual or household.
Personal Information Collected and Uses
| Category | Examples | The Company’s use of the information (use descriptions of uses in the next section) | Types of third parties that may receive the information |
|---|---|---|---|
| Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | #1 - #16 | Payroll Processors; Benefits Administrators; Government Agencies; Affiliates; Legal or Regulatory Proceeding Recipients; Trade or Industry Groups |
| Personal information and sensitive 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. Some personal information included in this category may overlap with other categories. | #1- #11, #14 - #16 | Payroll Processors; Benefits Administrators; Government Agencies; Affiliates, Legal or Regulatory Proceeding Recipients; Trade or Industry Groups |
| 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). | #1 - #5; #10, #12-#14, #16 | Payroll Processors; Benefits Administrators; Government Agencies; Affiliates; Legal or Regulatory Proceeding Recipients |
| 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, and sleep, health or exercise data. | #4, #9 - #12, #14, #15, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | #11, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Geolocational Data | Physical location or movements. | #6, #7, #10, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | #4, #11, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Professional or employment-related information | Current or past job history or performance evaluations. | #1, #11, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| 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. | #1, #14, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | #1, #4, #6, #9, #11, #12, #15, #16 | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
Purposes for Processing Your Personal Information
The processing of your Personal Information and Sensitive Personal Information enables the Company to perform its role as an employer and/or for the purposes of engaging you, including fulfilling its legal obligations under applicable laws and as necessary in connection with the Company’s performance of its contractual and employment obligations to you. Without this information, it would not be possible for the Company to manage the workforce and meet applicable legal obligations. Certain Personal Information and Sensitive Personal Information is processed by the Company for its business purposes, including, but not limited to:
- recruiting and employee on-boarding;
- payroll administration;
- pension administration;
- health administration/health insurance/benefits;
- life insurance/benefits;
- expense reimbursement and management;
- contacting others in the event of an emergency;
- making information available on the intranet and to facilitate communication between and among employees within the Company’s affiliates and divisions;
- administration and management of your access to information technology systems;
- time entry and leave management;
- training and appraisal, including performance records and disciplinary records;
- employee and staff surveys;
- equal opportunities monitoring;
- any benefit administration of the Company including equity-related plans and benefits;
- for marketing and/or public relations purposes and in connection with the performance of your duties (e.g., the Company may send your contact information to customers and potential customers as part of the marketing and sales process so they can contact you); and
- to comply with applicable laws and legal obligations, including without limitation:
a. to maintain the ethics hotline;
b. to respond to governmental inquiries or requests from public authorities;
c. to comply with valid legal process or discovery obligations;
d. to protect the rights, privacy, safety or property of the Company, its workers or the public if such a disclosure is proportionate in the individual case;
e. to permit the Company to pursue available remedies or limit the damages that the Company may sustain;
f. to respond to an emergency; and/or
g. to comply with applicable regulations, policies and procedures.
Knowing Your Rights Under the CCPA
The CCPA provides individuals with specific rights regarding their Personal Information. In this section, we describe your rights under CCPA and explain how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Covestro provide certain information to you about our collection and use of your Personal Information over the past 12 months. If you wish to exercise either your right to access or your data portability right, you must submit a verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights).
Deletion Request Rights
You have the right to request that Covestro delete your Personal Information, subject to certain exceptions. If you wish to exercise this right, you must submit a verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights).
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by one of the following methods:
- Email: DataPrivacyUS@covestro.com
- Calling us at 1-877-229-3778. You may submit a request by calling the phone number provided and an operator will take your information. Covestro will contact you directly to provide more instruction and procure verification information.
Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. You may also make a verifiable request on behalf of a minor child to whom you are parent or guardian.
You may only make a verifiable request for access or data portability twice within a 12-month period.
Verification Process
A verifiable request must:
- Provide sufficient information in response to the website/email/phone verification question asked in the creation of your request that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such a person. In the event we need additional information we will reach out to you personally to ask additional questions.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request. Covestro or a third party on behalf of Covestro may follow up with you to determine whether a request is a verifiable request under applicable law.
If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, Covestro will deny the request. Covestro will respond to any such request with a denial and will also explain why it has no reasonable method by which it can verify the identity of the requestor.
Response Timing and Format
We will confirm receipt of a verifiable request within ten (10) days of its receipt.
We will respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option. If you do not indicate a preference for delivery, Covestro will use its discretion in choosing the method for delivery of the information.
We do not charge a fee to process or respond to your verifiable request.
Original Date: 2/12/2020
Last Review Date: 1/1/2023
