SDUT CCPA Notice

CCPA Notice of Privacy Practices
(for California Applicants)

Last updated January 1, 2023

This CCPA Notice of Privacy Practices (“Notice”) describes how The San Diego Union-Tribune, LLC and its Affiliates[1] (“Union-Tribune,” “we,” “us,” or “our”)  collect, use, and disclose “personal information” as defined under California law from and about job applicants who are residents of California.

This Notice does not apply to our handling of data gathered about you in your role as a user of our consumer-facing services. When you interact with us in that role, the Union-Tribune Privacy Policy applies.

1.    Types of Personal Information We Handle

We collect, store, and use various types of personal information through the application and recruitment process. We collect such information either directly from you or (where applicable) from another person or entity, such as an employment agency or consultancy, background check provider, or other referral sources.

The categories of information we have about you may include, where applicable:

• Identification and contact information, and related identifiers such as full name, home address, telephone numbers, and email addresses..
• Professional or employment-related information, including:
  • Recruitment, employment, or engagement information such as application forms and information included in a resume, cover letter, or otherwise provided through any application or engagement process; copies of identification documents, such as driver's, operator's, or other motor vehicle license number, passport number, social security number, birth certificate number and other state/federal-issued ID number; and information with respect to references, U.S. work eligibility, visa sponsorship and background screening results, including information about criminal convictions and bankruptcies.
  • Career information such as job titles, work history, work dates and work locations, work contact information, information about skills, qualifications, experience, publications, references, and speaking engagements.
• Education Information such as institutions attended, degrees, licensing and professional memberships, transcript and academic record information, and other non-publicly available educational record information held by an educational institution.
• Potentially protected classification information such as race, sex/gender, military or veteran status, nationality/ancestry/ethnicity information, disability information and criminal history.
• Financial Information such as credit history or credit checks.
• Other information such as online account name and password to the extent you apply for employment online, electronic signatures, and any other information you voluntarily choose to provide in connection with your job application.

2.    How We Use Personal Information

We collect, use, disclose, and store personal information from job applicants for our and our service providers’ business and operational purposes in our recruitment and hiring process such as:  processing your application; tracking your application through the recruitment process; contacting references with your authorization; conducting background checks you authorize; employment and educational history verification, evaluating you for current and future job opportunities, including matching your skills and interest to applicable job requirements; communicating with you throughout the hiring process; and making hiring decisions. We will also use job applicant information for internal analysis purposes to understand the applicants who apply and to improve our recruitment process, including improving our diversity and inclusion efforts.  We may sometimes need to use applicant information for legal purposes, such as in connection with any challenges made to our hiring decisions.

3.  To Whom We Disclose Personal Information

We will disclose job applicant personal information to the following types of entities or in the following circumstances (where applicable):

• Internally: to other Union-Tribune personnel involved in the recruiting and hiring process.
• Service providers: to service providers assisting us in the job application process, including technology service providers, account servicers, travel management providers, human resources suppliers, background check companies, and employment agencies or recruiters, where applicable.
• Legal compliance: when required to do so by law, regulation, or court order, provided that the Union-Tribune reserves the right to seek a protective order or other appropriate remedy prior to any such compelled disclosures; in response to a request for assistance by the police or other law enforcement agency.
• Litigation or legal counselling purposes: to seek legal advice from our external lawyers or in connection with litigation with a third party.
• Business transaction purposes: in connection with the sale, purchase, or merger.

We do not sell or share your personal information or sensitive personal information (as those terms are defined by applicable law).

4.    Data Retention

We retain your personal information and sensitive personal information for as long as necessary for the
purposes described in this Notice, unless a longer retention period is required by applicable law. The
criteria we use to determine the applicable retention periods include:

• The length of time of the application and recruitment process with you;
• Whether we have a legal obligation pursuant to applicable laws to retain the information; and/or
• Whether we have a legitimate business need to retain the information, including whether the information is relevant to enforcing our agreements, resolving disputes, company systems safety and security, improving company system functionality.

5.    Your Privacy Rights

If you are a California resident, you may have certain rights. California law may permit you to request
that we:

• Provide you the categories of personal information and sensitive personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling such personal information; and the categories of third parties to whom we disclose such personal information. Please note that we have provided this information in this Notice for your convenience.
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you – note that we are not required to delete information that is used for certain company business purposes, such as security operations; legal compliance.
  
• Correct inaccurate information we have about you.

We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and contact email address.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please: (i) contact us at sandiegouniontribune.com/dsarhr; or (ii) email us at privacy@sduniontribune.com.

You also have the right to not be discriminated against (as provided for in applicable law) for exercising
certain of your rights. Certain information may be exempt from such requests under applicable law.

6.    How to Contact Us About this Notice

If you have any questions about this Notice, please contact Human Resources at rrinkeviciute@sduniontribune.com or call us at (619) 293-2010.

[1] In this Notice, “Affiliates” refers to subsidiaries and entities in which Union-Tribune or its subsidiaries operate or have an ownership interest.