NATIONAL TAX ADVISORY SERVICES LLC

CPRA Privacy Notice at Collection of Personal Information
for California Employees and Applicants

Effective Date:  January 1, 2023  

The California Consumer Privacy Act of 2018 (Cal. Civ. Code §1798.100, et. seq.) (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), imposes specific obligations on businesses processing the Personal Information of California residents.  

National Tax Advisory Services LLC, a California limited liability company (“NTAS”, “Company”, “we” or “us”) is required to provide its employees who are California residents (“California Persons”) a notice, used at or before the point of collection of such Personal Information, that identifies the categories of Personal Information that we collect and the purpose for our collection of such information.  

This California Employee Privacy Notice (“Notice”) is provided to California Persons as required by the CPRA.  
  1. Definitions. Capitalized terms in this Notice have the meanings set forth in the preamble above or as follows:

    2. “Employee”, “Employees” or “you” means an identified or identifiable natural person who is a California resident and who is a Company employee, a Company contractor, or is a job applicant to be a Company employee or contractor.  In this context, an “employee” is a person who is employed as a worker at the Company on a full-time, part-time, or temporary basis; a “contractor” is a natural person who provides services to the Company pursuant to a written contract; and a “job applicant” refers to any person who has submitted their candidacy to NTAS for a position at the Company.

    “Personal Information” has the meaning as defined in the CPRA and includes information that is collected by the Company about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. “Process” / “Processed” / “Processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Information.

    “Sale” or “Sell” has the meaning as defined in the CPRA, namely the selling, renting, releasing, disclosing, disseminating, making available, or transferring of Personal Information by the Company to a third party for monetary or other valuable consideration.

    “Sensitive Personal Information” is a subset of Personal Information including government identifiers (such as Social Security numbers and driver’s licenses); financial account and login information (such as credit or debit card number together with login credentials); precise geolocation; race, ethnicity, religious or philosophical beliefs, or union membership; content of nonpublic communications (mail, email and text messages); genetic data; biometric or health information; and sex life or sexual orientation information.

    “Share” has the meaning as defined in the CPRA, namely the disclosure of Personal Information by the Company for cross-context behavioral advertising.

  1. Personal Information We Collect About You. Listed below are the categories of information the Company may Process about Employees:
    1. Identifying information, such as your full name, gender, date of birth, and signature.
    2. Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
    3. Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
    4. Dependent’s or other individual’s information, such as their full name, address, date of birth, and Social Security numbers (SSN).
    5. National identifiers, such as SSN, passport and visa information, and immigration status and documentation.
    6. Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
    7. Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
    8. Financial information, such as banking details, tax information, payroll information, and withholdings.
    9. Health and Safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
    10. Information Systems (IS) information, such as your search history, browsing history, login information, and IP addresses on the Company’s information systems and networks.
    11. Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns.
    12. Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to a Company office location.]
    13. Sensory or surveillance information, such as COVID-19 related temperature checks and call monitoring and video surveillance.
    14. Profile or summary about an applicant/employee’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
    15. [OTHER INFORMATION CATEGORY.]
 
  1. Purpose. NTAS collects and uses Personal Information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. The Company collects Personal Information to use or disclose as appropriate to:
 
  1. Notice at Collection by Category of Personal Information.

    2. NTAS is collecting your Personal Information and Sensitive Personal Information to support its business operations, including for the business purposes in Section 3 above and as listed in the chart below.

    We will not Sell the Personal Information we collect. We also will not Share it with third parties for cross-context behavioral advertising.

    We will not Sell the Sensitive Personal Information we collect. We also will not Share it with third parties for cross-context behavioral advertising.

    Under the CPRA, you have the right to opt-out of Personal Information Sales or Sharing.  However, since NTAS does not Sell or Share your Personal Information, this opt-out is not applicable.

    To view our full privacy policy, visit [PRIVACY POLICY URL].

    We may collect the personal information and sensitive personal information categories listed in the tables below. The tables also list, for each category, our expected retention period, and use purposes.

     
    Personal Information Category Retention Period Business Purpose Sold or Shared
    Identifiers.  A real name; an alias; a postal address; an email address; a unique personal or online identifier; an IP address; an account name; a Social Security number (SSN); a driver’s license or passport number; or another form of persistent or probabilistic identifier that can identify a particular consumer, family, or device.   Indefinitely [USE PURPOSES] Not Sold/Shared
    California Customer Records personal information.  In addition to the identifiers listed above, also lists a person’s: signature; state identification card number; physical characteristics or description; insurance policy number; education; employment or employment history; bank account number, credit card number, debit card number, or any other financial information; or medical information or health insurance information.   Indefinitely [USE PURPOSES] Not Sold/Shared
    Protected classification characteristics under California or federal law. Age (40 years or older); Race; 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). Indefinitely [USE PURPOSES] Not Sold/Shared
    Commercial information.  Records of personal property; records of purchasing habits Indefinitely [USE PURPOSES] Not Sold/Shared
    Biometric information. Genetic (DNA), physiological, behavioral, and biological characteristics, that can be used singly or in combination with each other or with other identifying information to establish identity; Activity patterns from which organizations can 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.   Indefinitely [USE PURPOSES] Not Sold/Shared
    Internet or other similar network activity. Browsing history; search history; or information regarding a consumer’s interaction with an internet website, application, or advertisement. Indefinitely [USE PURPOSES] Not Sold/Shared
    Geolocation data.  Physical location, physical movements. Indefinitely [USE PURPOSES] Not Sold/Shared
    Sensory data.  Audio, electric, visual, thermal, olfactory, or similar information Indefinitely [USE PURPOSES] Not Sold/Shared
    Professional or employment-related information. Current job history; past job history; performance evaluations. Indefinitely [USE PURPOSES] Not Sold/Shared
    Non-public education information per the Family Educational Rights and Privacy Act. 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 Indefinitely [USE PURPOSES] Not Sold/Shared
    Inferences drawn from other personal information. Profile reflecting a person’s: preferences; characteristics; psychological trends; predispositions; behavior; attitudes; intelligence; abilities; or aptitudes Indefinitely [USE PURPOSES] Not Sold/Shared
    [OTHER PERSONAL INFORMATION DESCRIPTION] [RETENTION PERIOD] [USE PURPOSES] [No/Sold/Shared/Sold and Shared]
       
    Sensitive Personal Information Category Retention Period Business Purpose Sold or Shared
    Government identifiers (social security, driver's license, state identification card, or passport number) Indefinitely [USE PURPOSES] No/Sold/Shared
    Racial or ethnic origin Indefinitely Reporting to the United States Equal Employment Opportunity Commission data as required by the EEO-1 Component 1 Report. No/Sold/Shared
    Religious or philosophical beliefs Indefinitely Potential accommodations No/Sold/Shared
    Health, sex life, or sexual orientation information Indefinitely Pre-employment drug testing, reasonable suspicion drug/alcohol testing, disability leave or accommodation, health leave or accommodation.   No/Sold/Shared
    Precise geolocation Indefinitely Timekeeping to measure location of clocking in and out at workplace. Not Sold/Shared
   
  1. Your Data Rights; Requests; Responses.
    2.  
    1. Data Rights. As a California Person, you have the following rights with respect to your Personal Information.
      2.  
      1. The Right to Delete. You have the right to request that NTAS delete Personal Information collected directly from you, subject to certain exceptions.  You may make such a request a maximum of two (2) times in any 12-month period.
        2.  
      2. The Right to Correct. You can demand that NTAS correct inaccurate personal information.  An example would be if we have the wrong personal address for you on file if you have moved.
        3.  
      3. The Right to Know. You have the right to request, up to two (2) times in any 12-month period, that NTAS provide
        • The categories of Personal Information collected, disclosed, or sold about you in the last 12 months;
        • The categories of sources from which the Personal Information was collected;
        • The business purpose for which the information was used; and
        • The categories of third parties with whom your personal information was shared in the last 12 months.
      4. The Right to Access. You have the right to request, up to two (2) times in any 12-month period, that NTAS provide access to, or disclosure of, the specific pieces of Personal Information collected about you in the past 12 months.
        5.  
      5. The Right to Opt-Out. You have the right to request to opt-out of the Sale or Sharing of your Personal Information.
        6.  
      6. The Right to Restrict Sensitive Personal Information. You have the right to request that we limit the use and disclosure of your Sensitive Personal Information to exempted purposes under the CPRA, namely for: (a) security; (b) quality control; (c) short-term transient use; (d) performing services on behalf of the business; (e) uses necessary to provide goods or services reasonably expected by a California resident who requests those goods and services; and (f) purposes added by the CPRA’s regulations.
       
    2. Requests. To submit data requests, you may do so in writing by [email protected] or via telephone by (800) 256-5518.  
      3.  
    3. Responses. For items (1) (right to delete), (2) (right to know), (3) (right to correct), and (4) (right to access) above, we will confirm receipt of your request within ten (10) business days of the date submitted, and will respond in writing within 45 calendar days.  For items (5) (right to opt-out) and (6) (right to restrict Sensitive Personal Information), we will respond in writing no later than fifteen (15) business days of the date the request was submitted.
 
  1. Updates. This Notice will be updated to reflect changes in our business, legal, or regulatory obligations, so please check this Notice periodically for changes by visiting website URL for privacy. NTAS will not collect additional categories of Personal Information or use your Personal Information already collected for additional purposes without providing you with a notice of our intent to do so.  Any changes to this Notice will be effective from the date they are communicated to you.  If we make any material changes to this Notice, we will notify you by email before such changes are effective at the email address you have provided to us.