Equity Residential California Human Resources Privacy Pre-Collection Notice

Effective Date: January 1, 2020

Overview

This notice reflects our understanding of the law and our data practices as of the date posted. We may from time-to-time update information in this and other notices regarding our data practices and your rights as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.

Consistent with the provisions of the California Consumer Privacy Act (“CCPA”), job applicants, current and former employees and independent contractors (“Personnel”) are not considered “Consumers” for purposes of the CCPA. That said, we do collect personal information (“PI”), as defined in the CCPA, from you in connection with your application for employment and your employment with us, as follows:


Personal Information Under CCPA

This first section describes our personal information practices for the prior calendar year. The CCPA defines eleven Categories of PI, listed below. For each type of PI, below we have provided examples to explain what the PI is, where we may obtain it from, and why we may collect it from you in connection with your anticipated or actual employment with us.

We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed below. We typically prohibit our service providers and vendors from using your PI for any purpose other than our business purpose that the service provider or vendor is helping us to achieve, or for their permitted business purposes such as security and fraud prevention.

Category 1: Identifiers

Examples: This may include but is not limited to: 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.

Sources: We collect Identifiers directly from you when you provide us information online, over the phone or through paper documents such as applications for employment and consents to perform employment screening; from our websites with which you interact; in our notes and records we create about you; and from public sources of data such as government databases. We also collect Identifiers when you use certain company-managed applications to conduct business, whether on a company-owned device or on a personal device, such as a smartphone, that has been approved under our Mobile Device Management program.

Purpose for Collection: We collect Identifiers to perform employment screening, provide employment to you and as otherwise related to the operation of our business. This includes:

  • • processing your interactions with us, and managing those interactions and transactions (such as employee screening, onboarding, training, evaluations, payroll activities, and benefits enrollment and maintenance);
  • • research and development (such as improving our employment processes and analyzing the competitiveness of our compensation and benefits programs.);
  • • security (such as monitoring our website for malicious or criminal activity); and
  • • debugging or troubleshooting errors that may occur on our websites or mobile applications.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed above. For example, service providers who provide us with online employment application processing, employee onboarding, and benefits enrollment and updates.

In addition, we place, and allow certain third parties to place cookies or pixels on our websites and other online services which collect Identifiers from or about you or your device for the purpose of operating web sites and online services and for serving you with relevant content and advertisements about our communities.

Category 2: Personal Records

Examples: This may include information such as: physical characteristics or description, signature, telephone number, education, employment, employment history, insurance policy number, bank account number, credit card number, debit card number, or any other financial information.

Sources: We collect Personal Records directly from you when you provide us information about your interest in working for us, and your employment with us, and in notes and records we create about you. In addition, we may collect Personal Records about you from third parties such as credit reporting agencies or screening companies.

Purpose for Collection: We collect Personal Records from you to process and evaluate your employment application, process and manage your interactions with us, and as otherwise related to the operation of our business, including:

  • • Background checks, for example, may include education, employment, and certain financial information collected in order to qualify you to work with us.
  • • Direct Deposit Instructions, for example, will include your bank account information.
  • • We also may maintain, or engage a service provider to maintain on our behalf, benefit information and information concerning 401k and other similar savings plan information.
  • • Administering benefits, health and welfare plans, including qualifying you for certain benefits and recording your benefit elections over time.
  • • Maintaining information for an employee’s personnel file relating to hiring, employment, and termination of employment.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed above.

Category 3: Personal Characteristics or Traits

Examples: This may include, but is not limited to: sex, marital status, religion, veteran status, familial status, race, disability, gender identity, and creed.

Sources: To the extent we collect this type of PI, we do so from you directly.

Purpose for Collection: We collect this type of information so that we can operate as an employer in accordance with applicable laws and regulations. For example:

  • • We may inquire as to your marital status or request a list of dependents in order to select employee benefits, including health insurance.
  • • We may inquire as to your veteran status where you have legal rights based on that status.
  • • We may inquire as to your disability when you request us to make an accommodation for you related to your disability.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above.

Category 4: Customer Account Details/Commercial Information

Examples: This may include, but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We do not collect Customer Account Details/Commercial Information in connection with your employment or potential employment with us.

Category 5: Biometric Information

Examples: This may include but is not limited to: genetic, physiological, behavioral, and biological characteristics, that can be used to establish individual identity, including but not limited to fingerprints, voiceprints, retina scans from which an identifier template can be extracted, and other physical patterns, and sleep, health, or exercise data, that contain identifying info.

Sources: We do not collect Biometric Information in connection with your employment or potential employment with us. However, we may collect general information in connection with our Total Wellbeing programs. This information is collected from third party sources, such as companies that assist us in managing our Total Wellbeing programs.

Purposes for Collection: We may utilize this information to inform our services and offerings to you.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed above.

Category 6: Internet Usage Information

Examples: This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.

Sources: We may collect Internet Usage Information from your device when you connect with a wi-fi system at one of our office locations. When you interact with our websites, we do use certain tracking services to gather information about your usage and about you (see above under Category 1: Identifiers). When you access the internet using our computer devices or systems, our system will track and store that usage.

Purpose for Collection: We collect information about Internet Usage to better operate our web sites (including our employee intranet site) and online services. We reserve the right to monitor employee, independent contractor, and vendor use of our systems (including but not limited to Internet Usage) in order to ensure compliance with our policies governing such usage, and to maintain appropriate data security controls.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed above.

Category 7: Geolocation Data

Examples: This may include, but is not limited to: precise physical location or movements and travel patterns.

We do not collect Geolocation Data in connection with your employment or potential employment with us.

Category 8: Sensory Data

Examples: This may include, but is not limited to: audio recordings of calls, electronic, visual, thermal, olfactory, or similar information.

Sources: We may record calls that we have with you or that our vendors have with you. Certain of our office locations use video security technologies, and those videos may be stored for a period of time.

Purpose for Collection: We record calls for training and quality assurance purposes. Video technologies are used for site security and guest check in and identification.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed above.

Category 9: Professional or Employment Information

Examples: This may include, but is not limited to: professional, educational, or employment-related information.

Sources: We may obtain Professional or Employment Information from you as part of an application for employment or in connection with your employment with us. We collect Professional or Employment Information from you when you express an interest in working for us, submit an application for employment, during your employment with us, and in notes and records we create about you. In addition, we may collect Professional or Employment Information about you from third parties such as credit reporting agencies or screening companies.

Purpose for Collection: We collect Professional or Employment Information from you to process and evaluate your employment application, process and manage your interactions with us, and as otherwise related to the operation of our business, including:

  • • Background checks, for example, may include education, employment, and certain financial information collected in order to qualify you to work with us.
  • • Evidence of licensing or other required certifications may be required in connection with certain positions within our company.
  • • Maintaining information for an employee’s personnel file relating to hiring, employment, and termination of employment.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same purposes for which we collect PI as listed above.

Category 10: Non-public Education Records

Examples: This may include but is not limited to: 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.

Sources: We may obtain Non-public Education Records from you as part of an application for employment. We collect Non-public Education Records directly from you when you express an interest in working for us, submit an application for employment, during your employment with us, and in notes and records we create about you.

Purpose for Collection: We collect Non-public Education Records from you to process and evaluate your employment application, process and manage your interactions with us, and as otherwise related to the operation of our business, including:

  • • Evidence of levels of education achieved, licensing or other required certifications may be required in connection with certain positions within our company.
  • • Maintaining information for an employee’s personnel file relating to hiring, employment, and termination of employment.

Sharing PI: We may share PI with our service providers, vendors and affiliates for the same business purposes for which we collect PI as listed above.

Category 11: Inferences from PI Collected

Examples: This may include, but is not limited to: creating a profile about a person, reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sources: We may obtain general information about employees from third party sources, such as companies that assist us in managing our Total Wellbeing programs.

Purpose for Collection: We may utilize Inferences or employee characteristics to inform our services and offerings to you.

Sharing PI: To the extent we draw Inferences, we may share such Inferences with service providers, vendors and affiliates for the same purposes for which we collect PI as listed above.