Staff Privacy Notice (CCPA Addendum)

Effective from:  November 2020
Last reviewed: November 2020

Introduction

We are disclosing information about our data processing practices as required by the California Consumer Privacy Act of 2018 (CCPA) and its Regulations.   This CCPA Addendum supplements the information contained in the Bright Horizons Global Staff and Supplier Privacy Notice and applies exclusively to California residents.

Information Subject to this CCPA Policy

California residents (including staff) are protected as “consumers” by the CCPA with respect to personal information. A number of statutory exceptions apply under the CCPA. As a result, this CCPA Privacy Policy does not apply to personal information that is:

  • collected during a business relationship between businesses;
  • ‘aggregate consumer information’ defined as data ‘not linked or reasonably linkable to any consumer or household, including via a device;’
  • publicly available from federal, state, or local government records;
  • covered by the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act or clinical trial data; and
  • covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act 1994.

A separate Global Consumer Privacy Notice applies to prospective, current and former consumers.

Information We Collect

The Global Privacy Notice provides information on the categories of sources from which we collect personal data and the business/commercial purposes for which we collect personal data.

Below we have set out for California residents the categories of personal information we collect about them and the categories of third parties with whom we share this personal information with.  The table covers the last twelve months.  The services you provided, websites and application you visited/used or requests you made together determine which categories and types of personal information are applicable to you.

Categories of Personal Information we Collected

Categories of Third Parties with whom we Shared (including Service Providers and Exempt Third Parties)

Identifiers such as name, alias, postal address, email address, driver’s license number, unique personal identifiers including Social Security Number / passport and visa information / immigration status and documentation, online identifier, Internet Protocol address, or other similar identifiers.

Operating systems and platforms, IT developers, internet service providers, credit card/payment providers/financial institutions, insurers and professional advisers, government entities, and/or our business partners.

Personal information categories such as name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, education, employment, bank account number, credit card number, debit card number, or medical information.

 

Your dependent's or other individual's information as necessary for them to access any benefits we provide to you in relation to your employment, such as their full name, address, date of birth, and Social Security numbers (SSN).

Protected classification characteristics under California/federal law being age, ethnicity, hair/eye color, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy or childbirth and related medical conditions).

Operating systems and platforms, IT developers, insurers and professional advisers, government entities, and/or our business partners.

Internet or other similar network activity such as browsing history, search history, information on a consumer's interaction with our website, application, or advertisement.

Advertising networks, internet service providers, data analytics providers,

operating systems and platforms, IT developers and social networks. Information in this category may be shared with these categories of third parties by cookies placed on your device when you interact with our websites and applications. Learn more about how we use cookies and similar technologies by clicking here.

Geolocation data - physical location (when you have given permission to do so).

Internet service providers, IT developers, data analytics providers, operating systems and platforms.

Professional or employment-related information such as current job role, job history or performance evaluations, disciplinary records, leave records, background check information such as references and / or criminal record information as applicable.

Operating systems and platforms, IT developers, insurers and professional advisers, government entities, and / or our business partners.

Education records such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Operating systems and platforms, IT developers, insurers and professional advisers, government entities and/or our business partners.

Inferences drawn from other personal information (profile reflecting a person's preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.)

Operating systems and platforms, IT developers, insurers and/or professional advisers, government entities.

Biometric and thermal information.

Operating systems and platforms, IT developers, professional advisors, and/or government entities.


We do not collect the following categories of personal information in relation to you:

  • Audio, electronic, visual, olfactory, or similar information.

Sale of Your Personal Information

Bright Horizons does not sell your personal information.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com.