Personnel Privacy Notice

Last Updated: 04/10/2023

This Personnel Privacy Notice (“Personnel Notice”) explains how PCF Insurance Services of the West, LLC DBA: Andreini & Company Insurance Services, including its affiliates, (collectively, “Company,” “we,” “us”, or “our”) collects, uses, discloses, and otherwise processes personal information about our employees, officers, directors, managers, members, contractors, freelancers, contingent workers, consultants and other outsourced and temporary workers (collectively, “Personnel”), and their family members or other individuals about whom we process personal information as a result of the relationships those individuals have with our Personnel (collectively, “Related Persons”). It is the responsibility of our personnel to make this Personnel Notice available to their Related Persons.

This Personnel Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law. This Personnel Notice also is not intended to replace other notices or disclosures we may provide to you in connection with your role in our organization, which will supersede any conflicting disclosures contained in this Personnel Notice.

What is Personal Information?

When we use the term “personal information” in this Personnel Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual within the context of the individual’s role as a member of our Personnel or a Related Person. It does not include aggregated or deidentified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

Our Collection and Use of Personal Information

Personnel

Collection of Personal Information

In connection with an individual’s role as a member of our Personnel, we may collect the following professional or employment-related personal information:

Contact Information: such as full name, email address (personal and work), home address, business address, telephone number, and emergency contact information.
Identification Materials: such as image, Social Security number or other national identification number, passport number, or driver’s license number.
Professional Information: such as hire date, employment location, business unit, department, supervisor, job title, position/grade, hours and days worked, working arrangement, work restrictions or accommodations, employee identification number, licenses and certifications, attendance, career goals, performance reviews, disciplinary records, information needed to establish eligibility to work for us, including visa information, and information relating to potential conflicts with the individual’s role in the organization.
Education & Training Information: such as highest level of education, schools attended and dates of attendance, degrees, certificates or other educational qualifications earned, and transcripts or training records.
Financial Information: such as salary, bonus, benefits, expenses, stock or equity grants, bank account and routing information.
Benefits Information: such as eligibility for benefits, information about family members and other related persons eligible for or covered by available benefits, and claims relating to available benefits.
Equal Opportunity Information: such as age, race, ethnicity, national origin, citizenship, sex, disability or accommodation request, or marital or veteran status when an individual chooses to provide them, but this equal opportunity information will not be used in employment-related decisions unless specifically permitted by law.
Audio / Visual Recordings: such as a recording of image or voice in connection with phone calls, virtual meetings and conferences, and other events, where permitted by law.
Security Information: such as work-related accounts and passwords, technical details about the individual’s use of work-related devices and information systems (including, for example, device, logs, analytics data, IP address, and general location information derived from such IP address), the content of communications sent through work-related devices and information systems, access to physical and electronic work-related locations, audio recordings and photographs, videos, and other visual images of the individual.
Background Check and Reference Check Information: when permitted by applicable law, we may choose to conduct a background check and/or a reference check in connection with an individual’s employment such as to verify professional and educational history and qualifications or identify criminal history that may be relevant for a position with us. The results of the background check and/or reference check may include personal information we do not already have about the individual who is the subject of the check.
Other Work-Related Information: we also may collect any personal information our Personnel choose to share with us or to make publicly available, or we otherwise receive from a third party in connection with their work for us, a grievance they are involved in, an agreement they enter into with us, or additional roles they take on as a part of our organization.
Inferences: we may generate inferences or predictions about personnel and their abilities, interests, or preferences based on the other personal information we collect and the interactions we have with them.

Although we often collect the personal information described above directly from our Personnel, we may also collect this information from supervisors, colleagues, customers, vendors, publicly available sources, and other third parties they may interact with as members of our Personnel. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, payroll providers and benefits providers.

Use of Personal Information

We may use the personal information we collect about our Personnel to:

Conduct organizational planning and development, including budget planning and administration;
Analyze and monitor compliance with our compliance policies and practices;
Administer recruiting, onboarding, staffing, leave, Personnel evaluations, promotions, performance management, training, discipline, participation in available activities or programs, and any other processing in connection with work-related purposes;
Authorize, grant, administer, monitor and terminate access to or use of company systems, facilities, records, property, and infrastructure;
Communicate with and between Personnel, as well as with designated emergency contacts;
Support and manage Personnel, including providing resources needed for Personnel to perform their roles with us;
Facilitate Personnel compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, insurance);
Conduct performance reviews and evaluations, as well as make decisions about promotions and job mobility;
Manage business travel (e.g., car service/rentals, flights, hotels) and Personnel expenses (e.g., reimbursement);
Operate our business, including marketing our Personnel to customers, facilitating the work of our Personnel, and providing the products and services made available to our customers;
Investigate, document, and report work-related injuries, illness, or grievances;
Conduct internal investigations, audits, compliance, risk management, problem resolution, and security operations;
Fulfill contractual obligations to Personnel and other third parties;
Facilitate business transactions and reorganizations impacting the structure of our business;
Comply with applicable law, rule, regulation, legal proceedings, and government investigations, including relating to tax reporting and immigration.

Personal Information of Related Persons

Collection of Personal Information

At times, we may receive identifiers and other personal information about our Personnel’s family members and other Related Persons in connection with emergency contacts and the benefits and services we provide. These identifiers and other personal information may include:

Contact Information: such as full name, home address, telephone number, and emergency contact information.
Other Identification Materials: such as Social Security number or other national identification number, or driver’s license number.
Benefits and Services Information: we may also collect personal information necessary to extend benefits and benefit-related services, including insurance-related information, claims-related information, and disbursement-related information.

Although we often collect the personal information described above directly from our Personnel, we may also collect this information directly from the Related Person, and from our benefit administrators. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers.

Use of Personal Information

We may use the personal information we collect about Related Persons to:

Communicate about eligibility benefits and services, events, or activities that are happening, or in the event of an emergency;
Administer benefits and services;
Respond to requests and inquiries;
Conduct internal investigations, audits, compliance, risk management, problem resolution, and security operations;
Fulfill contractual obligations;
Facilitate business transactions and reorganizations impacting the structure of our business;
Comply with applicable law, rule, regulation, legal proceeding, and government investigations, including relating to tax reporting and immigration.

Sensitive Information

We may process personal information about our Personnel or our Personnel’s family members and other related persons that is sensitive in nature and is subject to special protection under applicable law ("Sensitive Information"). This information may include the following:

Social Security number, driver’s license number, passport number or other national identification number;
Work-related accounts and passwords;
Financial account information;
Information relating to racial and ethnic origin, health and disabilities.

We may collect this information from a variety of sources, including directly from you, from our benefits administrators, our service providers, or other third parties that perform services on our behalf. We may process this Personal Information for a variety of reasons. For instance, we may process this information to understand our employee demographics and address equal employment opportunity requirements. We do not share your Sensitive Information except when necessary for a business purpose or to provide you with applicable benefits, or when required for us to fulfill a legal obligation or enforce our rights. In many cases, we may provide you with an opportunity to opt-out before processing any Sensitive Information.

Disclosure of Personal Information

We may share the categories of personal information outlined above with the following third parties for the purposes described below:

Within Company: We may share personal information relating to Personnel and Related Persons within our family of companies for internal administrative purposes and uses that are consistent with this Personnel Notice. For example, the entity responsible for payroll may receive personal information about Personnel employed by another one of our entities in order to determine the proper compensation to be provided.
Benefit Administrators: In order to provide our Personnel and Related Persons benefits and services available to them, we may share personal information with the third parties we engage to offer and administer benefits and services on our behalf. These third parties may also collect additional personal information directly from our Personnel and their Related Persons in connection with these benefits and services, which will be subject to the relevant third party’s own privacy policies and notices.
Compensation, Payroll and Tax Providers: We may share personal information with third parties who assist us in processing our payroll and other compensation-related obligations, including our tax withholding and reporting obligations.
Background Check and Reference Check Providers: When permitted by applicable law, we may choose to conduct a background check and/or reference check in connection with an individual’s employment, such as to verify professional and educational history and qualifications or identify criminal history that may be relevant for a position with us. In order to facilitate the background check and/or reference check, we may share personal information about the relevant individual with trusted background check and/or reference check providers.
Other Service Providers: In addition to the third parties identified above, we may engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including assisting us with our Personnel management, benefits and services offerings, and other related business operations. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
Customers: We may share personal information about our Personnel with prospective and actual customers in connection with the marketing, negotiation, sale, delivery and provision of the products and services we make available. For example, we may share the images and contact information for the team of Personnel who will be responsible for handling a specific customer’s account.
Public Disclosure: We may disclose certain personal information about our Personnel, such as name, job title, work-related contact information, and experience, publicly in connection with our recruiting and business operations.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws and regulations or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of employment;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our Personnel, their Related Persons, our customers, or any person; or
- as otherwise required by applicable law.
Otherwise with Consent or Direction: We may disclose personal information about our Personnel or their Related Persons to certain other third parties or publicly with the consent or direction of the Personnel or Related Persons.

No Sales or Targeted Advertising

We do not sell personal information about individuals acting in their capacity as Personnel or Related Persons, and we do not share or otherwise disclose personal information about individuals acting in their capacity as Personnel or Related Persons to third parties for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).

Retention of Personal Information

We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance, where we are required to do so in accordance with legal, tax, and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

Your Privacy Rights

FOR CALIFORNIA RESIDENTS ONLY

California Privacy Rights

As a California resident, you may be able to exercise the following rights (subject to certain limitations at law):

*The Right to Know*	The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including: The categories of personal information collected; The categories of sources of the personal information; The purposes for which the personal information was collected; The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information was disclosed; The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information was disclosed for those purposes; and The categories of personal information sold (if any), and the categories of third parties to whom the personal information was sold.
*The Right to Access & Portability*	The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
*The Right to Correction*	The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
*The Right to Control Over Sensitive Information*	The right to exercise control over our collection and processing of certain sensitive information.
*The Right to Deletion*	The right to have us delete the personal information we maintain about you.
*The Right to Control Over Automated Decision-Making / Profiling*	The right to direct us not to use automated decision-making or profiling for certain purposes.

You also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that if the exercise of these rights limits our ability to process personal information, this may impact how we interact with you.

Submitting Privacy Rights Requests

To submit a request to exercise one of the privacy rights identified above, please:

Complete our Rights Request form; or
Call 800-969-2522.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your work-related account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we may require requests to include your name, email address and mailing address. We may at times need to request additional personal information from you, taking into consideration our relationship with you and the sensitivity of your request.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of the State of California or where we are unable to verify your identity.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

You may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using our online form or by calling 800-969-2522.

Updates to This Personnel Notice

We may update this Personnel Notice from time to time. When we make changes to this Personnel Notice, we will change the "Last Updated" date at the beginning of this Personnel Notice. If we make material changes to this Personnel Notice, we will notify you by email, by prominent posting on our intranet, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Personnel Notice or other privacy-related matters, please contact privacy@andreini.com.

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