California Consumer Privacy Act (“CCPA”) Employee Privacy Notice
Accolade, Inc., and its affiliates PlushCare, Inc., PlushCare of California, Inc., Accolade 2ndMD LLC (collectively “Company,” “we,” “us,” or “our”) provide this Privacy Notice which applies to California resident employees, employee applicants, owners, directors, officers, or contractors of Company, including as applicable, those individuals’ emergency contacts and beneficiaries. This Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”, collectively “CCPA”). Please note, there may be additional or different privacy notices or disclosures that govern our use of your personal information beyond the CCPA. Where collection, use and disclosure of personal information is subject to the CCPA, this Privacy Notice shall prevail. For collection, use and disclosure of personal information beyond the CCPA, those separate and relevant privacy notices and disclosures shall prevail. Any terms defined in the CCPA have the same meaning when used in this notice.
Pursuant to the CCPA, we provide the following details regarding the categories of Personal Information we have collected or disclosed within the preceding twelve (12) months.
| Categories of Personal Information Collected | Identifiers and Contact information |
|---|---|
| Purposes Personal Information is Used. | • 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 |
| Categories of Personal Information Collected | Protected classification information. This category includes characteristics of protected classifications under California or federal law, including without limitation, age, gender, medical conditions, marital status, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), race, color, religion or creed, ancestry, national origin, disability, sexual orientation, gender identity and expression, citizenship, primary language, immigration status, military/veteran status, political affiliation/activities, domestic violence victim status, and request for leave. |
| Purposes Personal Information is Used. | • Complying with applicable state and federal Equal Employment Opportunity laws • Design, implement, and promote the Company’s diversity and inclusion programs • Investigate complaints, grievances, and suspected violations of Company policy |
| Categories of Personal Information Collected | 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 activity, 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 • audio, electronic, visual and similar information, such as call and video recordings; |
| Purposes Personal Information is Used. | • 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 • Maintaining our facilities and infrastructure • Undertaking quality and safety assurance measures • Conducting risk and security controls and monitoring • Detecting and preventing fraud |
| Categories of Personal Information Collected | Geolocation data. This category includes GPS location data from Company-issued mobile devices and other Company-owned devices and equipment. |
| Purposes Personal Information is Used. | • 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 • Ensuring employee productivity and adherence to the Company’s policies • Investigate complaints, grievances, and suspected violations of Company policy |
| Categories of Personal Information Collected | 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 or her family members |
| Purposes Personal Information is Used. | • 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 |
| Categories of Personal Information Collected | Education information. This category includes education history. |
| Purposes Personal Information is Used. | • Evaluate an individual’s appropriateness for hire, a participation position at the Company, or promotion to a new position. |
| Categories of Personal Information Collected | Inferences drawn from the Personal Information in the categories above. |
| Purposes Personal Information is Used. | • 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 People and Culture Policies, Programs 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, outside legal counsel, and state or federal governmental agencies. The Company may add to the categories of Personal Information it collects and the purposes it uses Personal Information. In that case, the Company will inform you. Under the CCPA, California residents have the right to limit the use of their sensitive personal information (“SPI”) to only those purposes that are necessary for the business to provide products or services to the consumer. Company does not use any of your SPI for any other purposes than as described above. We have not sold and do not sell Personal Information for purposes of the CCPA. For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business. If you have questions about the Company’s privacy policies and procedures or the rights you may have concerning your personal information, you may contact the Privacy Team at [email protected] or People and Culture at [email protected].