LAST
UPDATED: December 18, 2024
CALIFORNIA CONSUMER PRIVACY ACT NOTICE – PRODUCTION EMPLOYEES
AND OTHER WORKERS
This California
Consumer Privacy Act Notice explains
what types of personal information may be collected by Studio Ramsay Global,
LLC and its affiliated entities (together “COMPANY,” “we,” “us,” or “our”)
about (i) our prospective, current, and former
California production employees, and (ii) contractors on productions, who are
California residents and who are informed of the applicability of this Privacy
Notice to their personal information, and (iii) California residents who are
designated as emergency contacts or beneficiaries of those production employees
or contractors (although they are not COMPANY employees) (collectively, “Production
Workers”). It also provides details
about how that personal information may be used and disclosed. All production employees are responsible for
reviewing this Privacy Notice.
As
used in this Privacy Notice, “Personal Information” means, in general,
information that identifies, or relates to, a particular person. Specific categories of Personal Information
are listed below.
Pursuant
to the California Consumer Privacy Act (“CCPA”),
we provide the following details regarding the categories of Personal
Information about California Production Workers that we have collected or
disclosed during the last 12 months:
Categories of Personal
Information Collected and Disclosed: The categories
of Personal Information that we collected and disclosed are below, along with
the categories of third parties to whom each category of Personal Information
was disclosed. Depending
on the California Production Worker’s interactions with us, COMPANY may not
have collected or disclosed each of these categories of Personal Information
about that person.
Category of Personal Information Collected |
Categories
of Third Parties to Whom Personal Information Is Disclosed |
Identifiers, such as name, government- issued identifiers
(e.g., Social Security number), and unique identifiers (e.g., employee ID) |
Service providers, COMPANY affiliates,
governmental bodies (e.g., in connection with reporting requirements), entities
with whom we have a business relationship, and other parties for our
operational business purposes |
Personal
information, as defined in
the California Customer Records law, such as contact and financial
information and vaccination status |
Service providers, COMPANY affiliates,
governmental bodies (e.g., in connection with reporting requirements), entities
with whom we have a business relationship, and other parties for our
operational business purposes |
Characteristics
of protected classifications under California law, such as age, gender, or medical conditions
(e.g., where relevant or required to provide accommodations), and marital
status |
Service providers, COMPANY affiliates,
governmental bodies (e.g., in connection with reporting requirements), entities
with whom we have a business relationship, and other parties for our
operational business purposes |
Commercial
information, such as
transaction information and purchase history (e.g., in
connection with travel or other reimbursements) |
Service providers, COMPANY affiliates,
governmental bodies (e.g., in connection with reporting requirements), entities
with whom we have a business relationship, and other parties for our
operational business purposes |
Biometric
information, such as
fingerprints (e.g., in connection with certain legal
requirements) |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Internet or
network activity information,
such as browsing history and interactions with our online systems,
websites, and digital applications |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Geolocation
data, such as
device location on certain safety apps |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Audio,
electronic, visual and other similar information, such as closed-circuit television, call
and video recordings (e.g., in connection with recorded web-based
trainings) |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Professional or
employment-related information,
such as work history and prior employer |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Non-public
education information |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Inferences
drawn from any of the Personal Information listed above (e.g., to analyze general
usage trends in connection with cloud-based applications) |
Service providers, COMPANY affiliates, and other
parties for our operational business purposes |
Sources of Personal
Information. We
collect this Personal Information directly from California Production Workers themselves,
or at their direction or with their authorization, where required, as well as
from prior employers, references, job boards, job search engines, recruiters
and/or other entities involved in the recruiting process, job-related social
media platforms, e-Learning or joint marketing partners, COMPANY affiliates,
and other sources of demographic or other information. Depending on the California
Worker’s interactions with us, COMPANY may not have collected Personal
Information from each of these categories of sources, and to the extent that COMPANY has disclosed Personal Information about that Production Worker, it
may not include all of the Personal Information collected about that Production
Worker.
Purposes. We
may use Personal Information and/or disclose it to third parties for the following purposes:
·
to operate, manage, and maintain our business,
including in connection with a sale, acquisition, reorganization, merger,
transfer of all or a part of our business, or other corporate transaction
(e.g., a bankruptcy or similar proceeding);
·
to provide our products and services;
·
for our employment purposes and objectives,
including employee health and safety and workplace monitoring and safety, and
employee benefits; and
·
to otherwise accomplish our business purposes including,
for example:
o
developing, improving, repairing, and maintaining
our products and services;
o
personalizing and marketing our products and
services;
o
conducting research, analytics, and data
analysis;
o
maintaining our facilities and infrastructure;
o
quality and safety assurance measures;
o
conducting risk and security controls and
monitoring;
o
detecting and preventing fraud;
o
performing identity verification;
o
performing accounting, audit, and other internal
functions, such as internal investigations;
o
complying with law, legal process, and internal
policies;
o
maintaining records; and
o
exercising and defending legal claims.
Depending on the California
Production Worker’s interactions with us, COMPANY may not have used Personal
Information collected about that person for each of these purposes, and to the extent that Company has disclosed
Personal Information about that California Production Worker, it may not
include all of the Personal Information collected about that individual.
Please note that there may be instances when COMPANY may use or disclose Personal Information, including situations where COMPANY has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of COMPANY, our COMPANY affiliates or our or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety, privacy, and security of Production Workers or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.
Sensitive Personal
Information. We do not
process sensitive Personal Information of Production Workers for purposes other
than those specified in the CCPA Regulations section 7027(m) (such as to
provide our products and services and for security purposes).
Sale
and Sharing of Personal Information. We do
not “sell” or “share” Production Workers’ Personal Information, as those terms
are defined by the CCPA. Please note,
however, that the CCPA definitions of “sale” and “sharing” do not include, for
example, the transfer of Personal Information as an asset that is part of a
merger, bankruptcy, or other similar transaction
involving all or any portion of our business.
Data Retention. We will retain Personal
Information from or about Production Workers as reasonably necessary and
proportionate to achieve the purpose(s) for which the Personal Information was
collected or processed as outlined in this Notice unless a longer retention
period is required or allowed by law.
California Rights.
California Production Workers
have the following rights:
(1)
Right to
Know. California Production Workers have the right to request that we disclose
to them the following information:
o The categories of Personal Information we collected about them and the categories of
sources from which we collected such Personal Information;
o The specific pieces of Personal Information we
collected about them for the applicable time period;
o The business or commercial purpose for collecting,
disclosing, or selling or sharing Personal Information
about them;
o The categories of Personal Information about them that we sold or shared and the
categories of third parties to whom we sold or shared that Personal Information;
and
o The categories of Personal Information about them that we otherwise shared or disclosed
and the categories of third parties with whom we shared or disclosed that Personal Information.
To make a request for access
to Personal Information, please
visit https://fcprivacy.exterro.net/portal/dsar.htm?target=SRG_Workforce or call us at 888-596-3929. The
California Production Worker will need to provide their name and email address,
along with other details about their request.
They will then receive verification instructions by email. In some circumstances, we may need additional
information from them in order to verify their identity or proceed with their
request.
California Production Workers
can use an authorized agent to submit a request for their Personal Information. When submitting a request online, the Production
Worker’s authorized agent should select the “Other” option on the form and,
in the field provided, include the California Production Worker’s name, email
address, and the Production Worker’s relationship to the Company (e.g.,
applicant, current/former employee, etc.).
In addition to verifying identity, as described above, we also will need
to verify the authorized agent’s ability to act on behalf of the California Production
Worker (e.g., by receiving a copy of their signed permission). Once verification is complete, we may
communicate directly with the California Production Worker for privacy and
security reasons.
Please note that, in
some instances, we may decline to honor a request, where, for example, we are
unable to verify the California Worker’s identity or an exception to this right
applies.
(2)
Right to
Request Deletion. California Production Workers have the right to
request that we delete certain Personal Information we collected from them.
To make a request for
deletion, please visit https://fcprivacy.exterro.net/portal/dsar.htm?target=SRG_Workforce or call us at 888-596-3929. The California Production Worker will need to
provide their name and email address, along with other details about their
request. The California Production Worker
will then receive verification instructions by email. In some circumstances, we may need additional
information from the California Worker in order to verify their identity or
proceed with their request.
California Production Workers
can use an authorized agent to submit a request for deletion. When submitting a request online, the Production
Worker’s authorized agent should select the “Other” option on the form and,
in the field provided, include the California Production Worker’s name, email address, and the Production Worker’s relationship to the
Company (e.g., applicant, current/former employee, etc.). In addition to verifying their identity, as
described above, we also will need to verify the authorized agent’s ability to
act on the Production Worker’s
behalf (e.g., by receiving a copy of their signed permission). Once verification is complete, we may
communicate directly with the California Production
Worker for privacy and security reasons.
Please note that, in
some instances, we may decline to honor a request where, for example, we are
unable to verify the California Production Worker’s identity or an exception to
this right applies.
(3) Right to Request Correction. California
Production Workers have the right to request that we correct inaccurate Personal Information we
collected about them.
To make a request for correction of inaccurate Personal Information,
please visit https://fcprivacy.exterro.net/portal/dsar.htm?target=SRG_Workforce or call us at 888-596-3929. California Production Workers will need to
provide their name and email address, along with other details about their
request. They will then receive
verification instructions by email. In
some circumstances, we may need additional information from the California Production
Worker in order to verify their identity or proceed with their request.
California Production Workers
can use an authorized agent to submit a request for correction of inaccurate Personal Information. When submitting a request online, the Production
Worker’s authorized agent should select the “Other” option on the form and,
in the field provided, include the California Production Worker’s name, email address, the Production Worker’s relationship to the
Company (e.g., applicant, current/former employee, etc.), and the personal
information they would like us to correct.
In addition to verifying their identity, as described above, we also
will need to verify the authorized agent’s ability to act on the Production Worker’s behalf (e.g., by
receiving a copy of their signed permission).
Once verification is complete, we may communicate directly with the
California Production Worker
for privacy and security reasons.
Please
note that, in some instances, we may decline to honor a request where, for
example, we are unable to verify the California Production Worker’s identity or
an exception to this right applies.
(4)
Right to be Free from
Discrimination. California
Production Workers have the right
to be free from unlawful discrimination for
exercising their rights under the CCPA.
Updates to this Privacy Policy:
COMPANY may modify this Privacy Notice. Please look at the Effective Date at
the top of this Privacy Notice to see when this Privacy Notice was last
revised. Any changes to this Privacy Notice will become effective when we post
the revised Privacy Notice.