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 and Sensitive 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 | Collected and Use, if applicable (descriptions in next section) | Sold or Shared | 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. | Yes #1 - #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Background Reporting Company Government Agencies; Affiliates; Legal or Regulatory Proceeding Recipients. |
| 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 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Background Reporting Company; Government Agencies; Affiliates, Legal or Regulatory Proceeding Recipients |
| 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). | Yes - #1 - #5; #10, #12-#14, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Background Reporting Company; 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. | Yes - #4, #9 - #12, #14, #15, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Internet or other similar network activity | All activity on the Company's information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee's use of company-issued devices). | Yes - #11, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Geolocation Data | Time and physical location related to use of an internet website, application, or device. | Yes - #6, #7, #10, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes - #4, #11, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
| Professional or employment-related information | Employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members. | Yes - #1, #11, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Background Reporting Company; 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. | Yes - #1, #14, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Background Reporting Company; 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. | Yes - #1, #4, #6, #9, #11, #12, #15, #16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients |
Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect information that falls within the sensitive personal information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.
| Sensitive Personal Information Category | Collected and Use, is applicable (descriptions in next section) | Sold or Shared | Third parties with which we may share the information |
|---|---|---|---|
| Government identifiers, such as your Social Security number, driver's license, state identification card, or passport number. | Yes - #1 – 6, 14, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Background Reporting Company Government Agencies; Affiliates; Legal or Regulatory Proceeding Recipients. |
| Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password. | Yes - #2, 3, 6, 9, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors; Benefits Administrators; Affiliates; Legal or Regulatory Proceeding Recipients. | Precise geolocation, such as your physical location within a small area (1,850 feet radius). | Yes - #7, 9, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Affiliates, Legal or Regulatory Proceeding Recipients. |
| Racial or ethnic origin. | Yes - #13, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Legal or Regulatory Proceeding Recipients. |
| Citizenship or immigration information. | Yes - #1, 13, 14, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Legal or Regulatory Proceeding Recipients. |
| Religious or philosophical beliefs. | Yes - #4, 14, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Legal or Regulatory Proceeding Recipients. |
| Union membership. | Yes - #2, 3, 4, 10, 11 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Legal or Regulatory Proceeding Recipients. |
| Mail, email, or text messages contents not directed to us. | Yes - #7, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Affiliates, Legal or Regulatory Proceeding Recipients. |
| Genetic data. | No | Generic data is not collected nor sold nor shared with third-parties. | Generic data is not collected nor sold nor shared with third-parties. |
| Unique biometric information used for identification. | Yes - #2 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Payroll Processors |
| Health information. | Yes - #4, 16 | No selling or sharing for cross-context behavioral advertising. May be shared with vendors or service providers for administrative employment purposes. | Benefits Administrators |
| Sex life, or sexual orientation information. | No | Sex life, or sexual orientation information is not collected nor sold nor shared with third-parties. | Sex life, or sexual orientation information is not collected nor sold nor shared with third-parties. |
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. - commercial information.
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).
Correction Rights
You have the right to request that Covestro correct inaccurate Personal Information that Covestro maintains about you. If your personal information happens to change during the course of employment, please keep contact HRService4You with questions or to correct any inaccurate personal information.
Opt-Out and Limitation Rights
For purposes of the CPRA, a “sale” is the disclosure of Personal Information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. We do not sell the categories of personal information or sensitive personal information we collect or share it with third parties for cross-context behavioral advertising, as indicated in the charts above.
Covestro has not sold or shared Personal Information belonging to Employees, Job Applicants or Contractors in the last twelve months. Further, Covestro does not sell or share the Personal Information of minors under 16 years of age.
You have the right to limit the use or disclosure of Sensitive Personal Information. To the extent Covestro uses or discloses Sensitive Personal Information, such processing is restricted to the permitted business purposes set forth under the CCPA and the CCPA Regulations. Therefore, Covestro does not offer to limit the use or disclosure of Sensitive Personal Information at this time.
Exercising Access, Data Portability, Correction and Deletion Rights
To exercise the access, data portability, correction 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.
If you submit a request for access, portability, correction or deletion through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify your identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization or where you have not verified your identity directly with us.
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.
Data Retention
Your data will only be kept for as long as necessary to meet the respective purpose and to fulfill regulatory requirements, including a possible statutory retention period. Data erasure is carried out within the framework of the deletion routines implemented by the process managers. For example, even after the end of the employment relationship it is necessary to store certain data until the end of the subsequent period of the statutory retention period.
Details on the deletion periods can be found in our Information Retention Disposal Schedules.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Financial Incentives
Under California law, we do not offer financial incentives to California Employees, Job Applicants or Contractors, who allow Covestro to collect, retain, sell or share their Personal Information.
Accessibility
If you encounter difficulty accessing this Notice due to a disability, please contact our Data Privacy Officer to request access to this Notice in an alternative format.
Contact
If you have any questions about this Notice or concerns about how we manage your personal information, please contact the office of our Data Privacy Officer by telephone, in writing or by e-mail, or HRService4You. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.
Julia DiPasquale
Telephone: 412-413-2901
Mobile: 412-277-6096
julia.dipasquale@covestro.com
1 Covestro Circle
Pittsburgh PA 15205
Original Date: 2/12/2020
Last Review Date: 1/1/2025
