Effective January 1, 2023
This California Employee, Job Candidates and Job Leavers California Privacy Notice (“Notice”) is provided by dentsu international, which is referred to in this Notice as “our,” “we,” or “us.”
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (“CCPA”), we are required to provide you a notice, at or before the point of collection of such personal information, that identifies the categories of personal information that may be collected and how that personal information is collected, used, and disclosed. Any terms defined in the CCPA have the same meaning when used in this Notice.
This Notice covers residents of California who are current employees, applicants, former employees, contractors, contingent workers, directors, officers, owners, and including as applicable, those individual’s emergency contacts and beneficiaries, all of which are referred to in this Notice as “employees,” “you” and “your.”
For example, this Notice explains how you can exercise your rights under the CCPA to request that we provide certain personal information that we have collected about you, correct inaccuracies in your personal information, or delete certain personal information that we have collected from you, subject to certain exemptions.
This Notice is intended to provide you with the CCPA required notice. This Notice supplements the Employees, Job Candidates and Job Leavers Privacy Notice. Any terms we use in this Notice that aren’t defined here, or under the CCPA, will have the meanings we give them in the Employees, Job Candidates and Job Leavers Privacy Notice.
California residents who are consumers should refer to our dentsu Privacy Policy to understand how your information is collected and processed as a consumer.
Categories of Personal Information that We Collect
We collect personal information in a variety of contexts. For example, we collect personal information for our employment and human resource purposes.
The personal information that we collect about you will depend on, for example, our relationship or interaction with you.
During the past 12 months, we may have collected the following categories of personal information.
- Personal Identifiers — personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security Number, driver’s license number, and passport number, email address, and account name;
- Personal Information — personal information, including full name, telephone number and address, financial information such as account number and balance, medical and health insurance information;
- Characteristics of Protected Classes — characteristics of protected classes or groups under state or federal law, such as sexual orientation, veteran or military status, or marital status;
- Commercial Information — records of personal property, such as products and services obtained and transaction histories;
- Biometric Information — biometric information, such as fingerprints, photographs, and voiceprints;
- Internet or Online Information — internet or online information such as browsing history, and information regarding interaction with our websites, applications, or advertisements;
- Geolocation Data — geolocation data, such as device location;
- Audio and Visual Information — audio, electronic, visual, thermal, olfactory, or similar information, such as call and video recordings;
- Employment Information — professional or employment-related information, such as work history and prior employer;
- Education Information — education information, such as school and related information;
- Inferences — inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics; and
- Sensitive Personal Information – personal information, that is not publicly available, and reveals:
- social security, driver’s license, state identification card, or passport number;
- account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- precise geolocation;
- racial or ethnic origin, religious or philosophical beliefs, or union membership;
- the contents of a mail, email and text messages, unless the business is the intended recipient of the communication;
- genetic data;
- the processing of biometric information for the purpose of uniquely identifying an individual; or
- information collected and analyzed concerning an individual’s health, sex life or sexual orientation.
Why We Collect Personal Information and How We Use It
The personal information we collect and use depends on, among other things, our relationship or interaction with you. Section 5 of our Employees, Job Candidates and Job Leavers Privacy Notice lists the purposes for which we collect and use personal information in different contexts.
Sources of Personal Information
We collect the majority of your personal information directly from you, but, in some cases, we will collect it from third parties. The sources from which we collect personal information depend on, among other things, our relationship or interaction with you.
The information below lists the categories of sources from which we collect personal information in different contexts.
- From you directly, or other individuals acting on your behalf, through physical (e.g., paper application), audible (e.g., phone), or electronic (e.g., website, social media) sources.
- Public records or widely available sources, including information from the media, and other records and information that are made available by federal, state, or local government entities.
- Outside companies or organizations from whom we collect personal information to support human resource and workforce management activities. For example, references from your previous employer(s) and background checks, where permitted by applicable law.
We sometimes advertise through recruitment agencies or use the services of specialist search organizations. These companies will collect your application information. You may also be asked to complete an employment questionnaire which is used to assess your suitability for the role you have applied for, the results of which are assessed by our recruiters.
If you are applying to work with us through an agency, please review their privacy notice for details of how they will handle your information.
Categories of Third Parties and Our Disclosure of Personal Information
The categories of third parties to whom we disclose personal information about you depend on, among other things, our relationship or interaction with you.
We are a global organization. To ensure effective and efficient services and communication throughout the group, your personal information may be shared with other dentsu organizations, for example with our group companies in Japan and the USA.
During the past 12 months, we have disclosed for our business purposes the categories of personal information listed above to the following categories of third parties:
- Third-party suppliers: Organizations (and their sub-contractors) that provide us with technology solutions and/or support such as the organizations that have been engaged to host, support and otherwise maintain the HR Information Systems (“HRIS”). This could also include organizations that provide systems which interconnect with the HRIS. Examples include expenses management software, local payroll and benefits systems. Where we use a third-party service provider, we’ll make sure we follow the requirements of the law and that your personal information is protected by the appropriate technical and organizational measures.
- Our professional advisers: IT administrators, auditors, consultants, payroll providers, administrators of our benefits programs.
- Insurance providers: We may also need to share your information with insurance providers in relation to our insurance policies.
- Clients: We share your information with our clients where necessary to manage and deliver services to them.
- Public authorities: We may will share your information with public authorities to comply with lawful requests (including without limitation to meet national security or law enforcement requirements) or where otherwise required, whether within or outside your country. We only share your personal information in accordance with applicable laws and have strong internal oversight of what we do and take expert advice to inform our approach.
The table below shows, for each personal information category we may collect, the categories of third parties to whom we may disclose for our business purposes information from that personal information category.
| Personal Information Type | Third Party Category to Whom We May Disclose Personal Information |
| Personal Identifiers | Third-party suppliers Our professional advisers Insurance providers Clients Public authorities |
| Personal Information | Third-party suppliers Our professional advisers Insurance providers Clients Public authorities |
| Characteristics of Protected Classes | Third-party suppliers Our professional advisers Insurance providers Public authorities |
| Commercial Information | Third-party suppliers Our professional advisers Public authorities |
| Biometric Information | Third-party suppliers Our professional advisers Public authorities |
| Internet or Online Information | Third-party suppliers Our professional advisers Public authorities |
| Geolocation Data | Third-party suppliers Our professional advisers Clients Public authorities |
| Audio and Visual Information | Third-party suppliers Our professional advisers Public authorities |
| Employment Information | Third-party suppliers Our professional advisers Insurance providers Clients Public authorities |
| Education Information | Third-party suppliers Our professional advisers Clients Public authorities |
| Inferences | Third-party suppliers Our professional advisers Public authorities |
| Sensitive Personal Information | Third-party suppliers Our professional advisers Insurance providers Clients Public authorities |
California residents have the right to opt out of the sale of their information by businesses that sell personal information. The CCPA defines a “sale” as the disclosure of personal information for monetary or other valuable consideration. We do not offer an opt-out from the sale of personal information, in the context of employment, because we do not and have not within at least the last 12 months sold personal information that is subject to the CCPA’s sale limitation.
We do not “share” your personal information for the targeting of advertising to you, as defined by the CCPA.
Your Rights Under the CCPA
You have the right to request:
- A copy of the personal information covering the 12 months prior to January 1, 2023 and the period prior to your request (“Access Request”):
- The categories of personal information we collected about you
- The categories of sources from which we collected the personal information;
- Our business or commercial purpose for collecting personal information about you;
- The categories of third parties to whom we disclosed personal information about you, and the categories of personal information disclosed;
- The specific pieces of personal information we collected about you;
- Correct inaccuracies in your personal information, subject to certain exceptions (“Correction Request”); and
- Delete personal information we collected from you, subject to certain exceptions (“Deletion Request”).
In addition, you have the right to be free from discrimination by a for exercising your rights under the CCPA.
Exercising Your Rights
You can exercise your privacy rights by submitting your request here.
Consumers wishing to exercise their privacy rights, please review our dentsu international Privacy Policy or Merkle Privacy Policy.
The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or verify an authorized representative.
You may authorize an agent to make an access or deletion request on your behalf. Your authorized agent may make a request on your behalf by submitting a request as noted above. As part of our verification process, we may request that you provide additional information.
We will respond to requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.
Various laws, in addition to CCPA, apply to much of the personal information that we collect, use, and disclose. When other laws apply, personal information may be exempt from, or outside the scope of the CCPA requests. For example, information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability, is exempt from CCPA Requests. As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to personal information exempt from CCPA Requests. This means that we may not provide some or all of this personal information when you make an Access Request. Also, we may not delete some or all of this personal information when you make a Deletion Request if it is necessary to retain to comply with legal obligation.
In addition, we may not include personal information when we respond to or process requests if the law recognizes an exception. For example, we will not provide personal information about another individual if doing so would adversely affect the data privacy rights of the other individual.
Changes to this Notice
This Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal information. The date of the most recent revision will appear at the top of this page.
Contact Us
If you have any questions about your personal information and are an existing employee, please submit a case through our internal platform, Ask People Services. If you are a former employee, candidate, beneficiary, or otherwise external to us, you may submit a request to HROperations@dentsuaegisnetwork.zendesk.com.
If you have any questions about this Notice, please contact us at 1 (877) 570-5939.