Applicant/Employee CCPA Notice

This notice describes the categories of personal information (“PI”) which may be collected by Aspen Power (“Company”) and the purposes for which PI may be used. We are providing this notice to you in accordance with California Civil Code Sec. 1798.100(b)

Categories of Personal Information Collected

Purposes Personal Information is Used

Identifiers and Contact information. 
This category includes names, addresses,
telephone numbers, mobile numbers, email
addresses, dates of birth, Social Security
numbers, driver’s license or state
identification numbers, bank account
information, and other similar contact
information and identifiers.
  • Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding
  • Processing payroll and employee benefit plan and program administration including enrollment and claims handling
  • Maintaining personnel records and record retention requirements
  • Communicating with employees and/or employees’ emergency contacts and plan beneficiaries
  • Complying with applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws
  • Preventing unauthorized access to or use of the Company’s property, including the Company’s information systems, electronic devices, network, and data
  • Ensuring employee productivity and adherence to the Company’s policies
  • Investigating complaints, grievances, and suspected violations of Company policy

Protected classification information. 
This category includes characteristics of
protected classifications under California or
federal law
  • Complying with applicable state and federal Equal Employment Opportunity laws
  • Design, implement, and promote the Company’s diversity and inclusion programs

Internet or other electronic network
activity information.
 
This category includes without limitation:
  • 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
  • all activity on communications
    systems including:
    • phone calls,
    • call logs,
    • voice mails,
    • 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 
  • Facilitate the efficient and secure use of the Company’s information systems
  • Ensure compliance with Company information systems policies and procedures
  • Complying with applicable state and federal laws
  • Preventing unauthorized access to, use, or disclosure/removal of the Company’s property, records, data, and information
  • Enhance employee productivity
  • Investigate complaints, grievances, and suspected violations of Company policy

Geolocation data. 
This category includes
GPS location data from company-issued
mobile devices and company-owned
vehicles.
  • Improve safety of employees, customers and the public with regard to use of Company property and equipment
  • Preventing unauthorized access, use, or loss of Company property
  • Improve efficiency, logistics, and supply chain management
  • Investigating complaints, grievances, and suspected violations of Company policy

Biometric information. 
This category includes fingerprint scans and related
information, and certain wellness metrics.
  • Improve accuracy of time management systems
  • Enhance physical security
  • Provide benefit plan offerings to promote health and prevent disease

Professional and employment-related
information.
 
This category includes without
limitation:
  • data submitted with employment
    applications including salary history,
    employment history, employment
    recommendations, etc.
  • background check and criminal history;
  • work authorization
  • fitness for duty data and reports
  • performance and disciplinary records
  • salary and bonus data
  • benefit plan enrollment, participation,
    and claims information
  • leave of absence information including
    religious and family obligations,
    physical and mental health data
    concerning employee and his or her
    family members
  • Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding
  • Employee benefit plan and program design and administration, including leave of absence administration
  • Maintaining personnel records and complying with record retention requirements
  • Communicating with employees and/or employees’ emergency contacts and plan beneficiaries
  • Complying with applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws
  • Business management
  • Preventing unauthorized access to or use of the Company’s property, including the Company’s information systems, electronic devices, network, and data
  • Ensuring employee productivity and adherence to the Company’s policies
  • Recruiting
  • Investigating complaints, grievances, and suspected violations of Company policy

Education information. 
This category includes education history.
  • Evaluate an individual’s appropriateness for an assignment or position at the Company, or promotion to a new position.

Inferences drawn from the PI in the
categories above.
  • To create a profile about an employee that reflects the employee’s qualifications, aptitudes, abilities, attitudes, benefit/claim history, preferences, characteristics, predispositions, and behavior or job performance. This might include the Company’s engaging in human capital analytics to identify certain correlations about individuals and success on their jobs. It also might include surveys the company takes from employees about work hours, selected holidays, etc., that are used to inform HR about policies and procedures.

To carry out the purposes outlined above, the Company may share information with third parties, such as background check vendors, third-party human resources and information technology vendors, parent, subsidiary or affiliated companies, outside legal counsel, and state or federal governmental agencies. The Company may add to or amend the categories of PI it collects and the purposes for which it uses PI. In that case, the Company will inform you.

If you have questions about the Company’s privacy policies and procedures, and rights you may have concerning your personal information, you may contact Kristina Segura, SVP, HR, at ksegura@aspenpower.com, or Aaron Bartell, General Counsel, at abartell@aspenpower.com.