Notice to Job Applicants Residing in California

Last Updated: January 2023

1. About this Notice. This Notice to Job Applicants Residing in California (this “Notice”) sets out how Commonwealth Equity Services, LLC, DBA Commonwealth Financial Network^® (“Commonwealth”) collects and uses personal information about you in compliance with our obligations under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). This Notice supplements the Commonwealth Privacy Policy. 

We take the privacy of our job applicants very seriously. Please read this Notice carefully because it contains important information about the personal information we collect, why we collect it, how long we keep it, and whether it is sold to or shared with third parties.

This Notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, date of birth, driver’s license number, passport number, or other similar identifiers (“personal information”). Personal information does not include publicly available information and certain other information that is regulated by other applicable laws.

2. Personal information we collect about you. We collect and use the following categories of personal information about you:

      Categories of Personal Information Collected

• Identifiers: Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, date of birth, driver’s license number, passport number, or other similar identifiers
• Personal information as defined in Customer Records law: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, or employment history
• Characteristics of protected classifications under California or federal law, such as race, national origin, age, sex, pregnancy, familial status, disability, and military or veteran status
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding your interaction with internet websites and applications
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs and call recordings
• Professional or employment-related information, such as work history, prior employer, references, qualifications, skills and experience, human resources data, and data necessary for recruitment and related administrative services
• Education information that is not publicly available personally identifiable information, as defined in the Family Educational Rights and Privacy Act
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Our sources for this information:

• We receive this information directly from you when you apply for a position or when communicating with us
• Some information is automatically collected when you visit our websites or use our mobile applications
• Some information is collected by service providers (e.g., background check providers) on our behalf 

3. How and why we use your personal information. We use your personal information for the following purposes:

      Purposes for Collecting and Using Your Personal Information

      Managing Human Resource functions:

• Workforce planning
• Recruiting, hiring, and onboarding
• Performing background or credit checks
• Implementing diversity and inclusion initiatives

      Compliance with:

• Legal and regulatory obligations
• Court or other government directives
• Internal policies and procedures

 Third parties we share this information with:

• Our trusted third-party service providers and affiliates who provide a service to us or assist us with facilitating job applications
• Our auditors, consultants, accountants, attorneys, and others providing advice to us
• Any other person or entity we reasonably think is customary, necessary, or advisable for the business purposes disclosed in our Privacy Policy or to whom we are obliged by applicable law or regulation to make the disclosure
• Any other party where we have obtained your consent or authorization

4. Whether personal information will be sold or shared. We do not sell or share (for cross-context behavioral advertising) the personal information of applicants.

5. Your rights.

Right to Know

You have the right to request that we provide certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected about you
• The categories of sources from which we have collected your personal information
• Our business or commercial purpose(s) for collecting or selling your personal information
• The categories of third parties with whom we have shared your personal information
• The specific pieces of personal information we have collected about you

You have the right to request that we provide certain information to you about our disclosures and sales of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected from you
• The categories of personal information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold
• The categories of personal information that we disclosed about you for a business purpose

We have not, and do not, sell personal information. You may only make a verifiable “Right to Know” request twice within a 12-month period.

Right to Delete

You have the right at any time to request that we delete your personal information; however, in some cases, we cannot delete all or some of your personal information as required or permitted by applicable laws.

Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you; however, in some cases, we may deny requests to correct inaccurate personal information, or may alternatively delete such personal information.

Right to Nondiscrimination

We will not discriminate against you for exercising your rights under the CCPA with respect to your application for employment. Further, we will not retaliate against you in any way for exercising your rights under the CCPA.

6. How long your personal information will be kept. We will retain your information for a period reasonably necessary to evaluate job applications, and if you are hired, information obtained may be moved to your employee record. Thereafter, we will keep your personal information:

• To respond to any questions, complaints, or claims made by you or on your behalf
• To show that we treated you fairly
• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

7. How to contact us to exercise your rights. To submit a request to exercise your “Right to Know,” “Right to Delete,” or “Right to Correct” rights provided in this notice, please email cfnprivacyoffice@commonwealth.com or submit your request by calling us toll-free at 866.212.6513. We will evaluate the request and take action where required to do so.

We will confirm receipt of your request within 10 business days and will provide information about how we will process your request. We endeavor to respond to your request as soon as we can, within the timeframes permitted under the CCPA. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).

Verification of Requests and Authorized Agents

We may have to verify your identity when you contact us to exercise your “Right to Know” or “Right to Delete.” Our verification process may vary depending on the nature of your request. Generally, we will verify your request by asking you to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request. We may deny any request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Your authorized agent may make a request on your behalf by emailing cfnprivacyoffice@commonwealth.com.