NOTICE OF COLLECTING COVID-19-RELATED INFORMATION
PURSUANT TO THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
The Company is implementing procedures to (a) require all employees at certain times or upon certain events to be tested for the COVID-19 virus and/or its antibodies, (b) measure the temperature of all individuals coming into the Company’s facility, and/or (c) inquire and observe whether any individual, whether an employee or visitor, attempting to enter a Company facility has any symptoms of COVID-19 or related illness.
Pursuant to the CCPA, we are notifying you that in the process if taking the above steps, the Company is or may be collecting the following categories of Personal Information:
- Personal Identifiers & Contact Information (e.g., name, alias, postal or mailing address, email address, telephone number);
- Physical Characteristics or Description (e.g., eye color, hair color, hair style, height, weight, build);
- Family Information (e.g., contact information for family members listed as emergency contacts, contact information for dependents and other dependent information, medical and health information for family members related to COVID-19 symptoms, exposure, or testing, and family travel information);
- Information of Friends, Co-workers, and Other Associates or Individuals with Whom You Have Been in Close Contact within the Past 14 Days (e.g., medical and health information for friends, co-workers, and other associates or individuals related to COVID-19 symptoms and their travel information);
- Protected Classifications (e.g., race, ethnicity, national origin, sex, gender, age, disability, medical or mental condition, familial status);
- Medical and Health Information (e.g., your body temperature, COVID-19 diagnosis, COVID-19 antibody and related testing results, whether you have or display certain symptoms such as fatigue, cough, sneezing, aches and pains, runny or stuffy nose, sore throat, diarrhea, headaches, sudden loss of smell or taste, or shortness of breath, whether you have been in close contact in the last 14 days with anyone who has exhibited any of these symptoms, whether you have been in close contact in the last 14 days with anyone who has tested positive for COVID-19, and whether you have recently traveled to a restricted area that is under a Level 2, 3, or 4 Travel Advisory according to the U.S. State Department, including China, Italy, Iran, and most of Europe, as well as any COVID-19-related doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, and correspondence with you and your healthcare provider(s) regarding any request for accommodation or medical leave of absence related to COVID-19); and
- Travel Information (e.g., locations traveled to within the 14 days prior to coming to the workplace and the dates spent in those locations).
The Company may collect the above categories of Personal Information for all of the following business purposes:
- To reduce the risk of spreading the disease in and through the workplace;
- To protect employees and visitors in the workplace from exposure to COVID-19;
- To comply with local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19;
- To identify potential symptoms linked to COVID-19 (including through temperature checks, antibody testing, or COVID-19 questionnaire);
- To permit contact tracing relating to any potential exposure;
- To communicate with employees and visitors regarding potential exposure to COVID-19 properly warn others who have had close contact with an infected or symptomatic individual so that they may take precautionary measures, help prevent further spread of the virus, and obtain treatment, if necessary; and The Company will maintain this information under conditions of confidentiality.