Effective Date: January 1, 2023

Institute for Environmental Health, Inc. and its affiliated entities (collectively, “IEH,” the “Company,” “we,” or “us”) respects the privacy of its employees (and applicants for employment). To this end, we have implemented this Applicant and Employee Privacy Notice (the “Notice”) to detail the rights of employees and applicants to the extent that the Company collects and processes their personal information for recruiting, onboarding, or employment purposes.

This Notice sets forth the Company’s privacy practices required under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). That said, this Notice is intended to apply to all employees and applicants in the United States. 

For purposes of this Notice, the term “personal information” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular applicant or employee, members of their household, and/or their devices. This includes, what may be referred to as, “sensitive personal information,” which is defined as (i) personal information of children and/or (ii) personal information that reveals information about a living individual’s physical or mental health, racial or ethnic origin, political or religious views, trade union membership, sexual orientation, genetic information, biometric information, commission or alleged commission of crime or related proceedings, and/or financial information. In any event, personal information (including sensitive personal information) does not include (i) publicly available information from government or other publically available records, (ii) de-identified or aggregated information, or (iii) any other information excluded under applicable law. 

DISCLAIMER: This Notice does not imply or guarantee that any given applicant will be interviewed for the position to which they have applied or will receive an offer of employment. 

Personal Information We Collect. We collect several types of personal information, which may include the following:

• Personal identifiers, including your legal name, alias, postal address, email, telephone number, date of birth, social security number, signature, driver’s license or other identification card, and/or other similar personal identifiers. 

• Employment-related information maintained as part of the employment relationship, such as job titles, assigned work locations, hire dates, employment contracts, performance reviews, disciplinary records, attendance records, payroll and benefits related data, photos, biometric data, information regarding your physical access to any Company worksite, and information captured from video, audio systems, or other forms of monitoring or surveillance (in accordance with applicable law).

• Background information, including your academic and professional qualifications, education records, CV/resume, references, interview notes, and drug screening and criminal background records (in accordance with applicable law). 

• National identifiers, such your identification, passport, immigration status documentation, visa, social security number, or national insurance number.

• Emergency contact information, such as the name, address, telephone number, and/or email address of one or more emergency contact.  

• Financial data, including bank account, tax withholding, payroll, salary, bonuses, benefits, expenses, and other financial information. 

• Health and medical data, including information about short- or long-term disabilities, medical conditions, and illnesses that you might share with us, particularly in relation to benefits coverage, reasonable accommodations, or leaves of absence you may need to take. This may also include genetic information (including family genetic information) and information about your spouse, beneficiaries, and/or dependent(s). 

• Internet and other electronic network activity, such as your browsing/search history; unique personal identifiers; application access location and information regarding interaction with an internet website, application, or advertisement; and/or time and geolocation data related to use of an internet website. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize you, or device linked to you over time and across different services, such as a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, or similar technology or other forms of identifiers.

• Any other information you share with us and inferences drawn from any personal information you have provided.

We may also collect certain demographic data that qualifies as sensitive personal information, including your race, ethnicity, citizenship, sex/gender, genetic information, sexual orientation, sexual identity or expression, disability status (including mental and physical disabilities), domestic violence victim status, marital status, military or veteran status, or any other legally protected characteristics. Generally, we collect this for legal compliance purposes and to help us understand the diversity of our workforce. When collected, this information is generally done so on a voluntary consensual basis.

Most often, the personal information we collect is collected from you directly. In some cases, we may collect personal data about you from third parties; for example, when we perform background screening checks for vetting purposes, where permissible and in accordance with applicable law. In most circumstances, we will get your permission before we collect personal data about you from a third party.

How We Use Personal Information. We may use or disclose the personal information we collect for one or more of the following purposes:

• Determining eligibility for hiring, such as to verify references or qualifications, or to conduct background screening (such as criminal background checks, where applicable).

• To maintain contact information, for you and your emergency contacts, dependents, and beneficiaries, as applicable. 

• To administer payroll, including salary administration, payroll management, payment of expenses, travel administration, tax withholdings, loan and advance payments, and/or to other compensation-related payments.

• To administer benefits, including assessing and processing eligibility, absence and leave monitoring, travel administration, and insurance and accident/claim management.

• To assess performance, including performance appraisals, skills monitoring, and assessments related to transfers, promotions, layoffs, reductions in force, and staff re-structuring.

• To assess and monitor eligibility to work in the U.S., both at the time of hire and throughout employment (as required by law).

• To facilitate a better working environment, including conducting training, assessing and taking disciplinary action for violations of Company policy, and responding to and investigating employee inquiries and complaints.

• To monitor work-related licenses and credentials, such as software licenses, training, and audit compliance.

• To maintain security of Company websites and internet-connected assets, including hosting and maintenance of Company computer systems and infrastructure, management of Company software and hardware computer assets, systems testing, training, and monitoring email and Internet access.

• To comply with legal or regulatory requirements, for example, to comply with labor and employment, health and safety, tax, and anti-discrimination laws; responding to judicial or regulatory requests/orders; or exercising or defending the Company’s legal rights.  

• To evaluate or conduct a merger, restructuring, reorganization, dissolution, or other sale or transfer of Company assets, in which personal information held by IEH is part of the assets transferred.

• For any other lawful or legitimate business purpose, such as compiling internal employee directories, preventing and detecting fraud and other types of wrongdoing, and other actions required for day-to-day operations.

We will not collect additional categories of personal information or use the personal information we collect for any reason that is materially different, unrelated, or incompatible with the purpose for which it was originally collected without providing you advance notice and, if required by law, seeking your consent.

Data Retention. We will retain your personal information only for as long as is needed to fulfill the purposes outlined in this Notice or as may be required by law or regulation. Generally, this means we will keep your personal data until the end of your employment with us, plus a reasonable period of time after that, where necessary to respond to any employment inquiries; for legal, tax, accounting, or administrative purposes; or to provide you with ongoing benefits. 

No Sale of Personal Information. We do not sell (as defined in applicable data protection and privacy laws) your personal information, and will not sell it without providing any required notices and opt-in/opt-out rights required under applicable law.

The Company takes great care to ensure your personal information is accessed/accessible only by those who need such access to perform their work-related tasks and duties, and to third parties who have a legitimate purpose for processing or accessing it. As such, we may share your personal information with the following categories of recipients:

• Other employees
• Our subsidiaries, affiliates, or our or their successors or assigns
• Our contractors, business partners, service providers, and other third parties who require the data to assist us in establishing, managing, or terminating your employment with us, including third parties that provide products or services to us and, by extension, to our employees
• Potential buyers (and their agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case, personal data held by us about you will be among the assets transferred
• Other third parties under the following circumstances: (i) when we are compelled by applicable law or regulation; (ii) where necessary to exercise, establish, or defend our legal rights; (iii) to seek to protect our rights or property; (iv) to seek to protect IEH, our customers, or the public from harm or illegal activities; and/or (v) to seek to respond to an emergency which we believe requires us to disclose data to prevent harm.

Your Privacy Rights. Certain jurisdictions may provide you with privacy rights under applicable data protection or privacy law regarding your personal data. In particular, you may have the right to:

• Notice regarding your personal data;
• Access to specific information;
• Have your personal information erased;
• Obtain and reuse your personal data;
• Object to the sale of your personal data;
• Other rights as required under applicable data protection and privacy laws. 

These rights may be limited under applicable data protection and privacy laws. To exercise any of these rights, please contact us by using the contact details under the “Contact Information” heading below. We will respond to such requests in accordance with the requirements of applicable data protection and privacy laws. Please note that in order to fulfil your request, we may need you to provide certain personal data to verify your identity. Depending upon applicable data protection and privacy law, individuals may also designate an authorized agent to exercise these rights on their behalf.

Non-Discrimination. We will not discriminate against you for exercising any of your rights under this Notice. 

Cookies and Similar Technologies. For information about the cookies and other tracking technologies used by our website and how to manage your settings for these cookies and technologies, please see our Privacy Policy.

Changes to this Notice. We reserve the right to update or change this Notice from time to time. We ask that you review the Notice periodically to stay informed about any updates or changes that we may have made. You can see when this Notice was last updated by checking the “Effective Date” displayed at the top of this Notice.

Contact Information. If you have any questions or comments about this Notice and our privacy practices in general, or if you need to update, change, or remove your personal information or exercise any other rights, please contact IEH’s Human Resources at HR@iehinc.com or (206) 522-5432.