California Job Applicant Privacy Policy
Last Updated: June 29, 2023
This Job Applicant Privacy Policy (“Policy”) describes how Ro (“Ro”, “we”, “us” and “our”) collects, uses, and discloses “personal information” as defined under California law from and about job applicants who are residents of California.
This Policy does not apply to our handling of data gathered about you in your role as a user of our consumer-facing services. When you interact with us as in that role, the Ro Privacy Policy applies.
We may update this Policy at any time. We may also provide you additional privacy notices regarding our collection, use or disclosure of information. Please read this Policy and any other privacy notices carefully. Please note that this Policy does not form part of any employment contract or contract to provide services.
Types of Personal Information We Handle
We collect, store, and use various types of personal information through the application and recruitment process. We collect such information either directly from you or (where applicable) from another person or entity, such as an employment agency or consultancy, background check provider, recruitment or professional networking website or company, or other referral sources. This information includes:
Contact information and other identifiers, such as full name, home and business addresses, telephone numbers, and email addresses.
Professional and employment-related information, such as:
Information included in your application forms, resume, or cover letter, or otherwise provided by you during the application, recruiting, and hiring processes.
Copies of identification documents, like your driver’s license, passport, and visa.
Evaluations of your performance during the interview process, background/criminal screening results, and information provided by your references.
Career information, like your past job titles, work history, work dates and work locations; and information about your skills, qualifications, experience, publications, speaking engagements, and professional memberships.
Business travel and expense information, such as travel itinerary information and expenses incurred for travel during the interview process.
Education Information, such as institutions attended, degrees, certifications, training courses, publications, and transcript information.
Legally protected classification information you voluntarily provide to us, such as race, sex/gender, gender identity/expression, sexual orientation, marital status, military service, nationality, ethnicity, and request for family care leave.
Audio or visual information, such as CCTV footage, as well as other information relating to the security of our premises collected during in- person interviews or other parts of the recruitment process.
Health-related information you voluntarily provide to us, such as if you provide disability information in connection with a request for accommodations during the recruiting process.
Other information that directly or indirectly identifies you, such as date and place of birth, citizenship, and permanent residence.
Other information, such as any information you voluntarily choose to provide in connection with your job application.
How We Use Personal Information
We collect, use, share, and store personal information from job applicants for our and our service providers’ business and operational purposes in the recruitment process, such as:
Recruiting and hiring, including job advertising, processing your application, tracking your application through the recruitment process, contacting references with your authorization, conducting background checks you authorize, and making hiring decisions.
HR management, including compensation determinations, scheduling, fraud prevention and investigation.
Internal analytics, including conducting internal analyses to understand the applicants who apply and to improve our recruitment process.
Safeguarding Ro, our workforce, users, services, systems, and third parties.
Exercising our legal rights and other legal purposes, including in connection with any challenges made to our hiring decisions and as required to comply with applicable laws or respond to legal or regulatory requests and investigations.
As requested by you or as required to complete your request to be considered for employment.
We may also use your personal information for any other legally permitted purpose (subject to your consent, where legally required).
Except where you provide such information voluntarily on your resume or in your application, we do not collect “sensitive personal information” under the California Consumer Privacy Act during the recruitment process.
With Whom We Share Personal Information
We will disclose job applicant personal information to the following types of entities or in the following circumstances (where applicable):
Internally: to other Ro personnel involved in the recruiting and hiring process.
Vendors: such as technology vendors, search firms who submit candidate information to us, recruiters we retain, travel management providers, human resources suppliers, background check companies, and employment agencies, where applicable.
Recruiters: such as where you authorize a recruiter to obtain feedback from us regarding your application and interview process.
Legal Compliance: when required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency.
Litigation Purposes: to seek legal advice from our external lawyers or in connection with litigation with a third party.
Business Transaction Purposes: in connection with the sale, purchase, or merger.
Consent: with your consent and as permitted by law, we may disclose your personal information in accordance with your consent.
Data Retention
The personal information we collect from job applicants will be retained for as long as necessary to satisfy the purposes for which it was collected and our legal obligations and shall be retained in accordance with our internal document retention policies. As described above, these purposes include our business operations and complying with reporting, legal, and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.
Additional Information for California Residents
California residents have certain rights regarding their personal information. Subject to certain exceptions, if you are a California resident, you may request:
access to your personal information including the right to know the categories of personal information we have or will collect about you and the reason we will or have collected such information;
correction of the personal information that we have or will hold about you that is inaccurate;
deletion or removal of your personal information.
You also have the right not to be discriminated against (as provided for in California law) for exercising your rights.
Exceptions to Your Rights: There are certain exceptions to these above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our service providers to provide a service that you have requested or to comply with law or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity.
Exercising Your Rights: To exercise one of the rights above, you or your authorized agent may contact us as provided below.
We will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.
California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for “cross-context behavioral advertising” as those terms are defined under the California Consumer Privacy Act (“CCPA”). We do not “sell” or “share” the personal information covered by this Policy and have not done so in the twelve months prior to the effective date of this Policy.
How to Contact Us About this Policy
If you have any questions about this Policy, or want to exercise your rights, please contact us by emailing [email protected] or by by submitting a request here.