Personnel Privacy Policy

Effective Date: January 3, 2023

The California Consumer Privacy Act of 2018 (“CCPA”) and as amended by the California Privacy Rights Act (“CPRA”) as well as other U.S. state law requires Us to disclose its practices with regard to Our collection, usage and sharing of the personally identifiable information of its employees, including past or present job applicants, current employees, medical staff members, directors, officers, temporary workers, seasonal workers, interns and independent contractors (“Employees”).

The term “Employee” is only used in this notice as defined by applicable data privacy law. It should not be construed as a definition applied to contractors and independent contractors for purposes of other labor and employment laws.

(“Leech Tishman Fuscaldo & Lampl”), Leech Tishman”, “we”, “our” or “us”) and our affiliates are required to provide its Employees who are California residents, or residents of a U.S. state with similar applicable law, a notice, at the point of collection, that includes: (1) the categories of personal information collected about you; (2) the purposes of such collection; (3) information about the disclosure and use of the information; (4) how long we keep your personal information; (5) the rights you have as a California resident under the CCPA or rights you have under applicable law; and (6) how to contact Us to exercise your rights.

1. Updates

This Notice will be updated periodically to account for changes in our business practices and regulatory changes in the law that impose additional requirements on us with respect to this Notice. Along with being provided a copy of this Notice, if it changes in any material fashion that affects the way in which your personal information is processed by us, we will provide you with an updated notice. You can also refer to our website for any new versions of this Notice.

2. Definitions

2.1 “Personal Information” has the meaning as defined in the CCPA and includes information that is collected by Us about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

2.2 “Process“, “processed” or “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.

2.3 “Employees“, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a Leech Tishman job applicant, employee, director, officer, medical staff member, temporary or seasonal employee, intern or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with Leech Tishman; “employee” refers to any person who is employed at Leech Tishman as a full-or part-time employee, temporary employee, seasonal employee or intern and “contractor” means a natural person who provides any service to a business pursuant to a written contract.

3. Personal Information We Collect About You

Listed below are the categories of personal information that Leech Tishman may process about employees:

3.1 Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social security number, driver’s license number, passport number, birth certificate or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an employee, or a device that is linked to an employee, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.

3.2 Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.

3.3 Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding an employee’s interaction with an internet or intranet website, application or advertisement, time and geolocation data related to use of an internet or intranet website, application or physical access to a Leech Tishman office location.

3.4 Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint, face, and voice recordings; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.

3.5 Education Information, including information about an employee’s educational background, such as education records, report cards, and transcripts that is not publicly available.

3.6 Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

4. Purposes for Collecting Your Personal Information

Leech Tishman collects the personal information identified in Section 3 above for the reasons listed below.

4.1 To Recruit Employees, including to conduct employment related background screening and checks.

4.2 To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

4.3 To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

4.4 To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.

4.5 To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

4.6 To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

4.7 To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements and populating the International Mobility global system.

4.8 To Maintain Your Contact Information, including altering your details across relevant entities within the Leech Tishman group of companies (for example personal, other employment and transferring roles) as well as maintaining personnel directories.

4.9 To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

4.10 To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

4.11 To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return-to-work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.

4.12 To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

4.13 To Ensure a Safe and Efficient Working Environment, which includes Leech Tishman actions relating to disciplinary actions, and code of conduct processes and investigations.

4.14 To Maintain Security on Leech Tishman Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Leech Tishman’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

4.15 To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

4.16 To create promotional and marketing materials, such as issuing press releases, providing website information and disclosures, providing public webinars and seminars, meetings, running public activities and speaking events.

5. Your rights under the CCPA as a California resident and other similar applicable law in your jurisdiction that grants similar rights:

California and other state law may permit you to request that we –

5.1 Provide you the categories of Personal Data 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 your Personal Data; and the categories of third parties with whom we shared Personal Data.

5.2 Provide access to and/or a copy of certain information we hold about you.

5.3 Provide your Personal Data to another entity to exercise your right to portability.

5.4 Update or amend your Personal data.

5.5 Delete certain information we have about you.

You have a right to non-discrimination. Subject to applicable law, we may not discriminate against you for exercising the above-listed rights.

We do retain the right to verify your identity or request before we can provide personal information to you, correct personal information, or remove personal information or otherwise process your request. To verify your request, we may require you to provide your name, physical address, phone number, email address, or other contact information that you previously provided to us.

We may also limit our response to your request as permitted by law. For example, some aspects of the CCPA and other applicable law have exceptions to the right to delete information such as, but not limited to, when your personal information is the subject of a court subpoena or litigation hold order.

All rights of access to data are subject to exceptions under the CCPA and applicable law. If you would like to exercise any of your enumerated rights under the CCPA or applicable law, please contact us at personnelprivacy@leechtishman.com or call us toll free at 1-888-890-0070.

6. Sharing of your personal Information

6.1 Leech Tishman may transmit your personal information to affiliates, contractors and service providers as we deem appropriate for any purpose set forth or contemplated in this notice.

6.2 We generally transmit personal information to:

• Our affiliates;
• Vendors, service providers, contractors and other business partners;
• Regulatory and government agencies, public authorities, local governments, law enforcement, courts and other public agencies.
• Third parties involved in a corporate transaction in the event our assets are transferred or sold to another entity;
• Advisers such as legal counsel, auditors and insurance brokers and carriers.

7. Data Retention

We will maintain your personal information, including sensitive personal information for as long as We are legally required to do so for Our legitimate business purposes as provided in this Notice.

8. Notice of Monitoring

Your role in Our company, or through your affiliation with Us, may require or provide you with access to computing devices, including computers, laptops, tablets, phones, devices, networks, websites or other applications owned or operated by Us or on Our behalf (“Systems”). Please note that We may monitor and record your use of these Systems, including activity you conduct while using the Systems, emails, telephone conversations, internet transmissions, chats, SMS and other electronic communications sent, received and stored to the extent permitted by applicable law in your jurisdiction for purposes of compliance, investigations, audit purposes as well as to protect Us from fraud, illegal activity, violation of Our policies and procedures or the misuse of Our systems and assets. Accordingly, you should not have any reasonable expectation of privacy in connection with your use of Our Systems.

8. Further Information

If you have any questions about this statement, please contact the Leech Tishman Privacy Office via email at personnelprivacy@leechtishman.com or by telephone using our dedicated toll free number: 1-888-890-0070.