California Resident Employee Notice at Collection and Privacy Policy

Effective Date: January 1, 2023

In compliance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), Guaranteed Rate, Inc. dba Certainty Home Lending (referred to herein as “we” or “us” or “our”) is providing this California Resident’s Employee Notice at Collection and Privacy Policy (“Employee Privacy Notice”), which describes the Personal Information (as defined below) we may collect from you. This Employee Privacy Notice applies only to residents of the state of California who have accepted an offer of employment from us or who are otherwise an employee, former employee, owner, director, officer, or a contractor of our company.

If you are also our customer for a financial product or service, please also see our California Resident’s Customer Privacy Notice and Policy available here.

What is Personal Information? 

For purposes of this Employee Privacy Notice, “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person who resides in California.

What is Not Considered Personal Information?

While Personal Information is broadly defined, other categories are specifically excluded from this definition including:

Personal Information We Collect and Our Purpose for Collection 

We are required to collect Personal Information about you, your dependents, beneficiaries, and emergency contacts, to provide and administer payroll, medical and financial benefits, human resource services, and assistance. Throughout the duration of your employment, we may actively or passively collect the information described in the chart below for the listed purposes. 

We collect this information from you and from a variety of sources, which may include online job platforms and social networks, government entities, data analytics providers, data brokers and background check providers, recruiting firms, and other service providers.

Category	Personal Information We Collect	Purpose(s) for Collection
Identifiers	Name, signature, social security number, address, telephone number, passport number, driver’s license or state ID number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information you provide to us, medical information, or health insurance information.	We may use this Personal Information to: evaluate your qualifications for ongoing employment or promotions; conduct conflicts checks arrange and manage our sponsored job fairs and recruiting events create a talent pool for future job opening comply with our recordkeeping obligations and policies demonstrate your agreement to, or acceptance of documents presented, or acceptance of documents presented to you perform human resource functions, including processing job applications, administering benefits, processing payroll, conducting analytics in an employee context, conducting performance reviews and managing other aspects of an employment relationship including, but not limited to, the establishment, maintenance, and termination of employment relationships; comply with licensing and regulatory requirements; determine eligibility for initial employment, including the verification of references and qualifications; process background checks of new applicants and existing employees; manage the terms and conditions of employment, such as payment of wages/salary, direct deposit authorization, the provision and administration of benefits and leaves of absence, and maintenance of emergency and beneficiary contact information; process work-related claims (e.g., worker’s compensation, insurance claims, etc.); conduct training, take disciplinary action, address injuries, and other employment related incidents; provide a safe work environment; administer our occupational safety and health programs; assist you with obtaining immigration or work documentation, when required; maintain internal directories; facilitate employee-related programs, including surveys and voluntary programs; investigate and respond to claims against us; and facilitate corporate transactions, such as transferring personal information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets.
Protected Classifications under California or Federal Law    We collect this category of Personal Information on a purely voluntary basis, except where collection is required by law, and use the information only in compliance with applicable laws and regulations.	Race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, marital status, sex, age, or sexual orientation	We may use this Personal Information for the following purposes:  conduct research and analytics: track and report on diversity and inclusion participate in studies and research projects; and comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act (EEOC) and California’s Fair Employment and Housing Act
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	We may use this Personal Information to: reimburse employees for business related expenses for travel, lodging and other approved expenses.
Sensory Data or Surveillance Data (Audio, visual, electronic data)	Personal likeness, voice, images, pictures, recordings, information related to a company issues device.	We may use this Personal Information to: protect the safety and security of our facilities and personnel through video surveillance, and communicate with and receive messages from employees.
Professional or Employment Related Information	Employment history, employment verification information, promotions, service dates, training information, length of service, compensation, tax information, bank account data, current department/position, employment status, job performance, attendance records, disciplinary actions, recordings of customer servicing calls, relocation information, employee development information, payroll information, or other employment-related information.	We may use this Personal Information to: evaluate applicants’ qualifications for employment.
Profile Data	Inferences drawn from Personal Information to create a profile about in applicant reflecting applicant’s intelligence, abilities, aptitudes, or characteristics/behavior	We may use this Personal Information to: evaluate your qualifications for ongoing employment or promotions; conduct conflicts checks, arrange and manage our sponsored job fairs and recruiting events; create a talent pool for future job openings; comply with our recordkeeping obligations and policies; demonstrate your agreement to, or acceptance of documents presented, or acceptance of documents presented to you; conduct market research, evaluate, and improve our recruiting process; perform human resource functions, including processing job applications, administering benefits, processing payroll, conducting analytics in an employee context, conducting performance reviews and managing other aspects of an employment relationship including, but not limited to, the establishment, maintenance, and termination of employment relationships; comply with licensing and regulatory requirements; determine eligibility for initial employment, including the verification of references and qualifications; process background checks of new applicants and existing employees; manage the terms and conditions of employment, such as payment of wages/salary, direct deposit authorization, the provision and administration of benefits and leaves of absence, and maintenance of emergency and beneficiary contact information; process work-related claims (e.g., worker’s compensation, insurance claims, etc.); conduct training, take disciplinary action, address injuries, and other employment related incidents; provide a safe work environment; administer our occupational safety and health programs; assist you with obtaining immigration or work documentation, when required; maintain internal directories; facilitate employee-related programs, including surveys and voluntary programs; investigate and respond to claims against us; and facilitate corporate transactions, such as transferring personal information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets.
Education Information	Information such as education verification information, level of education, training and degrees received, or certifications.	We may use this personal information to: evaluate an employee’s initial qualifications for employment and ongoing qualification for promotions; evaluate an employee’s compliance with applicable licensing and regulatory requirements; and evaluate an employee’s compliance with ongoing training or certification requirements.
Inferences drawn from Personal Information	Information to create a profile about your performance which may reflect your professional development goals and preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.	We may use this Personal Information to: evaluate an employee’s initial qualifications for employment and ongoing qualification for promotions; and to make compensation determinations with respect to an employee.
Sensitive Personal Information	Social Security or other state identification number; financial account numbers and documents permitting access to direct your pay to listed accounts, racial or ethnic origin, religious affiliation, the contents of and email, or text messages, unless we are the intended recipient of the communication.	We may use this Personal Information as described above under Identifiers and Protected Classifications. Employees voluntarily provide their gender and ethnicity and may limit our use and disclosure of this information by electing not to provide it during the initial application stage.

Other Purposes Potentially Applicable to Any Categories of Personal Information Listed Above 

We may also use your Personal Information and Sensitive Personal Information to facilitate administrative and other service functions, information technology and security operations, corporate transactions, and for legal reasons. These functions may include:

Disclosure of Personal Information for a Business Purpose

We disclose Personal Information in a variety of different contexts to the categories of recipients as described below. 

Your Rights and How to Exercise Your Rights

CCPA requires we create a way for eligible California residents to exercise their rights under CCPA, and to fulfill those consumer privacy rights regarding their Personal Information. These rights include the: 

To exercise your rights please complete the request form available here. We must verify your identity before we process any request. We may ask for your name, address, social security number, telephone number and/or information related to your employment to verify your identity. If we require additional information to verify your identity, you will receive an email from a member of our privacy team. If we are unable to verify your identity, then we will not be able to fulfill your request. 

Additionally, we may not fulfill a request in accordance with applicable exemptions under state and federal laws or regulations where we are not required to do so.  

California law permits California residents to use an authorized agent to make privacy rights requests. We require any such authorized agent to provide us with proof of the California resident’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California resident. An authorized agent must follow the process described above to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California resident about whom the request was made.

You may also submit a request by emailing: [email protected] or calling 866-934-7283

Information You Provide About Other Individuals

When you provide us with Personal Information about any other individual (e.g., beneficiary, dependent, emergency contact, etc.) as a part of completing certain enrollment documents related to your employment, it is your responsibility to inform other individuals of this Employee Privacy Notice prior to providing their Personal Information to us. If you are a parent or guardian of a minor who is your dependent, you consent to our and our third-party benefits administrators’ collection and use of such minor’s Personal Information for purpose of including them within your medical and financial benefits elections and providing services to them. If you do not consent, you may always change your dependent’s information with us. If you need assistance, please contact [email protected].   

We will not contact any third-party individuals listed in your employment for a purpose inconsistent with the purpose for which it was collected. We may contact your emergency contact in the event of an emergency. We will not sell, share, or send marketing and advertising communication to any third party you list in connection with your employment. 

Retention of your Personal Information

We retain your Personal Information throughout the term of your employment with us and thereafter only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain Personal Information for longer periods of time, for instance when we are required to do so in accordance with legal, regulatory, tax, and accounting requirements.

Change of Control 

Notwithstanding any privacy notice, disclosure, or agreement which list information to the contrary, we may disclose, receive, or transfer your Personal Information in connection with a sale, merger, acquisition, dissolution, divestiture, joint venture, bankruptcy, or any similar transaction where the control and responsibility of your information changes to or from us.  

Changes to this Notice

We will review and revise this Employee Privacy Notice on an annual basis or at our discretion. Updates to this Employee Privacy Notice take effect at the time of posting.   Your continued employment after such changes take effect will constitute your consent to such changes.  

Contact Us 

For Questions about this Employee Privacy Notice, questions about privacy generally, please contact us by: