Public Consulting Group LLC (“PCG”) respects the privacy of your personal information. This Employee and Applicant Privacy Notice (“Notice”) outlines the types of information that PCG may collect from you, what we do with that information, and with whom we may share the information. PCG may amend this Employee and Applicant Privacy Notice from time to time. If we make changes to this Policy, we will post the amended version on the web, on our internal PCG Policy Library, and in other locations as may be required, and we will notify you about such changes.
This Employee and Applicant Privacy Notice applies solely to job applicants, employees, owners, directors, officers, and contingent workers (e.g. temporary workers and contractors) of PCG who reside in the United States (collectively referred to in this Policy as “PCG Workers”).
We are committed to protecting the privacy and security of the information we collect and to being transparent about the purposes for which we use your information. This Notice sets forth PCG’s policies and practices for handling the information we collect and use in the employment context.
This Privacy Notice does not form any contract of employment for any contractors nor modify the employment terms to any candidates hired by PCG.
1. Definitions
“Personal Information” or “PI” has the meaning as defined in the California Consumer Protection Act or “CCPA” and includes information that is collected by PCG about you in the course of your application for employment, direct services pursuant to a contract, or other 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” or “processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing, or destroying of Personal Information.
“Employees”, “employee” or “you” means an identified or identifiable natural person who is as acting as a PCG job applicant, employee, owner, director, officer, or contractor. In this context “job applicant” refers to any person who has submitted their candidacy with PCG; “employee” refers to any person who is employed at PCG as a full or part-time employee or temporary worker; and “contractor” means a natural person who provides any service to PCG pursuant to a written contract directly with PCG.
2. Categories of Personal Information We Collect and Purpose of Collection
When a PCG Worker applies to join the PCG team as an employee; works pursuant to a direct agreement with PCG as a contractor; or provides services as a temporary worker or during the course of employment with PCG, we may collect the following categories of Personal Information. PCG collects and uses this Personal Information only as permitted or required by, and in compliance with, law.
PCG has collected the following Personal Information for the following purposes within the 12 months prior to the last update of this PCG Employee and Applicant Privacy Notice:
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Categories of Personal Information Collected |
Purposes Personal Information is Used |
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Identifiers and Contact information. This category includes name, alias and other names, address, telephone and/or mobile phone numbers, email address, date of birth, Social Security Number, driver’s license number or state ID card number, passport number, and other unique personal identifiers associated with you or your beneficiaries such as your spouse or child.
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· Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding · Process payment or payroll and employee benefit plan and program administration, including enrollment and claims handling · Maintain personnel records · Comply with record retention requirements required by law · Communicate with employees and/or employees’ emergency contacts and plan beneficiaries · Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, unemployment claim information requests, workplace safety, and related laws · Prevent unauthorized access to or use of the PCG’s property, including the information systems, electronic devices, network, and data · Ensure employee productivity and adherence to PCG policies · Investigate complaints, grievances, and suspected violations of PCG policy · Use in the event of a substantial corporate transaction, such as a merger, asset sale, or consolidation · Respond to valid requests for data pursuant to a subpoena, court order, legal process, law enforcement requests, legal claims, and government inquiries · Carry out our contractual obligations or enforce our rights arising from any contracts between us |
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Protected classification information. This category includes characteristics of protected classifications under California or federal law, including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age. |
· Comply with applicable state and federal Equal Employment Opportunity laws · Design, implement, and promote PCG’s diversity and inclusion programs · Investigate complaints, grievances, and suspected violations of PCG policy · Administer the employee benefit plan and program design and administration, including leave of absence administration
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Sign-in, device, internet, or other electronic network activity information. This category includes without limitation: • username and password, account name or number, and other online or device identifiers • all activity on PCG’s information systems, such as internet browsing history activity, search history, intranet activity, email communications, stored documents and emails and information regarding interactions with websites and applications, our systems, and networks · all activity on PCG-provided communications systems including call logs, chat logs, and direct messages, application use on company systems, browsing and search history on PCG systems, email communications via PCG email systems, and other information regarding an Employee’s use of PCG-issued programs, applications, and systems |
• Facilitate the efficient and secure use of PCG’s information systems • Ensure compliance with PCG information systems policies and procedures • Comply with applicable state and federal laws • Prevent unauthorized access to, use, or disclosure/removal of the PCG’s property, records, data, and information • Enhance employee productivity • Investigate complaints, grievances, and suspected violations of PCG policies • Verify and maintain the quality, safety, and performance of our products and services, including product and service testing, research, and development • To monitor work-related software licenses and credentials, including provisioning software licenses for use in the course of an employee’s work-related responsibilities
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Geolocation data. This category includes badge access at PCG offices. |
• Improve safety of employees, customers, and the public with regard to access of PCG properties and equipment therein • Preventing unauthorized access, use, or loss of PCG property • Ensure employee productivity and adherence to PCG policies • Investigate complaints, grievances, and suspected violations of PCG policy |
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Professional and employment-related information. This category includes without limitation: • data submitted with employment applications including, employment history, employment recommendations, etc. • background check and criminal history • work authorization • professional licenses • educational degrees • fitness for duty data and reports (upon return from a medical leave of absence) • 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/her/their 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 • Determine compensation, bonus, and other incentive programs • Maintain personnel records and comply with record retention requirements • Communicate with employees and/or employees’ emergency contacts and plan beneficiaries • Comply with applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws • Business management • Prevent unauthorized access to or use of PCG property, including PCG information systems, electronic devices, network, and data • Ensure employee productivity and adherence to PCG policies • Respond to client or potential client requests for proposals • Recruiting, retention, and promotion of employees • Manage professional development • Manage conflicts of interest • Investigate complaints, grievances, and suspected violations of PCG policies |
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Education information. This category includes education history and transcripts that are not publicly available. |
• Evaluate an individual’s appropriateness for hire or promotion to a new position |
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Financial Information.
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• Process payroll • Manage company expenses, corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs • Confirm eligibility for certain types of employment, background and related checks, as permitted by law |
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Inferences drawn from the personal information in the categories above. This category includes any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
• Engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve retention, and analyzing employee preferences to inform department and HR Policies, Programs and Procedures |
We do not hire minors under 16 years of age, and as a result, we do not knowingly collect Personal Information from minors under 16 years of age.
PCG does not sell, rent, or trade Personal Information.
PCG does not transfer Personal Information outside of the United States.
3. Sharing of Your Personal Information
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
• Authorized third-party vendors and service providers. We may share your Personal Information with third-party service providers and vendors that help us with specialized services, including onboarding, employment-related background checks, payroll, tax withholding, benefits administration, employee education, leave administration, technology and information systems management and support, expense management, and/or compliance and legal support.
• Corporate affiliates. We may share your Personal Information with our corporate affiliates that are subject to this Policy.
• Legal purposes. We may disclose Personal Information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of PCG, our affiliates, users, or the public.
• Business transfers. We may share your Personal Information in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
• With your consent or at your direction. We may share your Personal Information for other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.
4. Rights of California Workers under the CCPA
If you are a California Worker, you have the following rights with respect to the Personal Information PCG holds about you:
• You have the right to request that we report to you how we collect, use, transfer, or sell your Personal Information.
• You have the right to request that we delete your Personal Information.
• You have the right to opt out of the sale of your Personal Information. (Please note, however, that PCG does not currently sell any Personal Information.)
• You have the right to not receive discriminatory treatment for exercising any of these rights.
If you would like to exercise any of your privacy rights, please use this form.
Only you, or a person whom you authorize to act on your behalf, may make a request related to your Personal Information.
In making your request, you must:
• Provide us with sufficient information that allows us to verify that you are the person for whom we collected Personal Information or an authorized representative of that person;
• Describe your request with sufficient detail that allows us to understand the request.
We may need to contact you in order to clarify your request, confirm your identity, or collect more information in order to verify and respond to your request. If we are unable to verify your identity, PCG will not disclose any specific pieces of Personal Information to you and will inform you that we cannot verify your identity. In the event your request is denied in whole or in part, we will inform you of the reason for such denial.
5. Disclaimer
Maintaining the security of your Personal Information is of utmost concern to PCG. PCG uses reasonable security measures to protect Personal Information from unauthorized access. However, no system can be absolutely secure. Consequently, you should not transmit through email or our website any health information or other information that you consider sensitive. PCG cannot warrant the security of any data transmitted via email or through our website, and you do so at your own risk.
6. Updates
This Notice may be changed to reflect changes in our business, legal, or regulatory obligations, so please check this Notice periodically for changes. To the extent PCG intends to collect additional categories of your Personal Information or use your Personal Information already collected for additional purposes PCG will notify you by providing an updated CCPA Employee and Applicant Privacy Notice. Any changes to this Notice will be effective from the date they are communicated to you.
7. Further Information
PCG’s Privacy Office handles inquiries, comments, and complaints regarding the handling and privacy of your personal information and can be contacted by email at privacy@pcgus.com or by regular mail at:
Privacy Officer
Public Consulting Group LLC
148 State Street, 10th Floor
Boston, MA 02109
1-800-210-6113
If you have questions about the PCG privacy policies and procedures, rights you may have regarding your Personal Information, you may contact PCG’s Privacy Officer at 1-800-210-6113. If you are a California Worker and you would like to exercise your rights to make a request about your Personal Information under the CCPA, please make a CCPA Employee Request.
LAST UPDATED: July 25, 2024