Privacy Policy

InnovaSystems Employee Privacy Policy

 

This Privacy Policy applies to InnovaSystems International, LLC (“InnovaSystems.” “Innova,” “We”, “Our”, “Us”). This Privacy Policy explains how we collect, use, and share the personal information that we gather including subdomains and websites on www.inspiresoftware.com, www.innovasi.com & https://innovanet.innovasi.com (“Websites”) or through your use of any and all other InnovaSystems corporate software or tools, Innova third party processors and Inspire cloud-based leadership software services (the “Services”).

 

1.      The Basics

As an employee, InnovaSystems collects data from you during all phases of your employment lifecycle. This lifecycle includes data collected as a prospective employee or job applicant, as a current employee, and as a separated employee. You have rights as it relates to this data.

 

We recommend that you read this Privacy Policy in full to ensure that you are fully informed. If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact information provided at the end of this Privacy Policy.

 

2.      Privacy for Employees

This section applies to the personal information that we collect and process from employees who utilize InnovaNet, Inspire, and all other systems related to the performance of that support your employment.

 

2.1          Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with your household or device (“Personal Information”). In addition, in the year before the date this policy was issued or last updated, we may have collected the following categories of personal information from our California workforce:

 

Category

Examples (not all inclusive)

A. Personal Identifiers

Name, alias, Social Security Number, date of birth, signature, home address, e-mail address(es), telephone number(s), driver’s license or state identification card number, passport number, and other similar identifiers.

B. Demographics & Family

Age, race, ethnicity, gender identification, medical condition, disability status, citizenship, veteran or


 

 

Category

Examples (not all inclusive)

 

military status, marital status, family member information.

C. Professional or Employment Information

Salary/compensation, benefits, beneficiary designations, talent management, disciplinary action, employment contract(s), employment history, performance reviews, professional designations, personnel files, training, visa status, business expenses, use of company products, and pre-hire documents (such as job applications, resumes, background check information, drug test information, and candidate evaluations).

D. Education Information

School records, school(s) attended, dates attended, degree(s) earned, academic achievements.

E. Financial Information

Retirement account information, bank accounts, investment or brokerage accounts, information on personal property and real estate, student loans, insurance, information regarding estate or tax planning, debts, trusts, credit or debit card number(s), legal issues (e.g., child support, alimony, wage garnishments and subpoenas), and benefits information.

F. Medical Information

Medical history, medical questionnaires, information regarding physical, mental and/or behavioral health, genetic information, wellness activities and subsidies, health insurance information, information regarding payment for healthcare services.

G. Biometric Information

Fingerprints

H. Internet or Network Activity

Browser history, search history, IP address, mobile device identifier, cookies, use of IT resources, interaction with websites, network activity, use of internal applications, access to company resources, advertisements.

I. Geolocation Data

Static physical work location, work travel itineraries.

J. Profile Information

Profiles reflecting a person’s preferences, such as interests, hobbies, physical characteristics or description, characteristic tendencies, behaviors, attitudes, or aptitudes, including inferences drawn from any Personal Information.

K. Product Information

Policy/account number(s), policy/account values, beneficiary, ownership arrangements, transaction history.


 

 

Category

Examples (not all inclusive)

L. Audiovisual Information

On-site security cameras, pictures, video and audio recordings.

 

2.1.1     Information You Give Us

You give us information about you when you apply for employment to InnovaSystems and throughout the course of your employment.

 

        Please See Appendix A

 

2.1.2     Information We Automatically Collect

Like many website operators, we collect information that your browser sends whenever you visit our Websites or Services. We use cookies and other tracking technologies to collect some of this information.

 

        Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.

        Log data: Our web servers keep log files that record data each time a device accesses those servers, and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.

        Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services.

        Account and Network Behavior: Our security products track user and network activity and create a baseline of user and network behavior.

 

2.1.3     Information We Collect from Third Parties

We may use third party information resources to collect information about you for privileged access required to perform your duties. Examples of this may include:

 

       Background Check

       INS Check

       Clearance Investigation


 

3.      Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

       Workforce Management such as:

o   To evaluate individuals for a position with us when applying for a position or we receive the individual’s information related to a position

o   To comply with state and federal laws requiring employers to maintain certain records

o   To process payroll and manage applicable tax withholding and reporting

o   To administer and maintain group health insurance benefits, additional wellness programs, 401(k) and/or retirement plans, life insurance, disability insurance, leave programs and additional fringe benefit programs

o   To manage and/or analyze all aspects of employee performance of their job duties and employment, including, but not limited to, training, talent management, periodic reviews, performance tracking, promotions, and discipline

o   For surveys, research, analysis and strategic development to implement, maintain and promote an engaging work experience

o   To review and audit employee interactions with the customers and product users, and business partners

o   For employee and facility security

o   To support information technology services to the workforce

o   For emergency training and emergency response

       Research and Strategic Development such as:

o   Information collected for business, product, strategy, and technological development, excluding Marketing and advertising activities

       Detecting and Protecting such as:

o   Detecting and protecting against security incidents and malicious, deceptive, fraudulent, or illegal activity, or violations of policies or the law

o   For fraud and crime prevention

o   For information protection and cybersecurity

       Legal/Compliance/Regulatory such as:

o   To meet additional legal, compliance, and regulatory requirements and to defend InnovaSystems rights and property


 

 

       Online Auditing such as:

o   Auditing related to a current interaction with our California workforce and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with standards

       Debugging such as:

o   To debug errors in systems

       Backups and Archives such as:

o   For disaster recovery, business continuity and record keeping obligations

3.1          How We Share the Personal Information

3.1.1     Affiliates and Service Providers

We share your information with our third-party service providers and any subcontractors as required to offer you employment and benefits including health care, insurance, retirement and other benefit-related services. These service providers are bound by legal constraints and follow the required security frameworks to ensure the protection of your personal data. For a list of providers please contact Human Resources.

 

3.1.2     Disclosures Required by Law

We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share personal data in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.


 

4.      Your Privacy Choices

4.1          General

4.1.1     Exercising Your Privacy Rights

We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

 

4.2          California Residents

4.2.1     California Consumer Privacy Act (CCPA)

If you are a California employee, you have the following rights:

 

        The right to know what categories of Personal Information is being collected about you.

        The right to know whether your Personal Information is sold or disclosed and to whom.

        The right to say no to the sale of Personal Information.

        The right to access your Personal Information.

        The right, in certain circumstances, to delete the information you have provided to us.

 

4.2.2     Requests for Deletion and Information

In certain circumstances, California employees have the right to request that we delete their information. In addition, California employees have the right to request, up to twice in a 12- month period, that a business that collects Personal Information about the employee disclose to the Employees the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information and requests can and will be denied where law or corporate policy conflicts with the request.

 

(1)  The categories of Personal Information it has collected about that employee.

 

(2)  The categories of sources from which the Personal Information is collected.

 

(3)  The business or commercial purpose for collecting or selling Personal Information.

 

(4)  The categories of third parties with whom the business shares Personal Information.

 

(5)  The categories of Personal Information that the business sold about the employees and the categories of third parties to whom the Personal Information was sold, by


 

category or categories of Personal Information for each third party to whom the Personal Information was sold.

 

(6)  The categories of Personal Information that the business disclosed about the Employees for a business purpose.

 

(7)  The specific pieces of Personal Information it has collected about that Employees.

 

To make such a request, please contact us at the contact information below.

 

Do Not Sell My Personal Information. California Employees have the right to opt out of the sale of the Employee’s personal information. To make such a request, please contact us at the contact information below. InnovaSystems does not currently sell employee information.

 

Email: Privacy@innovasi.com

 

5.      Change of Control

Personal information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control of InnovaSystems. If we sell, merge, or transfer any part of the business, part of the sale may include your Personal Information.

 

6.      Data Retention

For Employees, we retain the information we receive for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements, and comply with applicable laws.

 

7.      Security Protections

We take appropriate and reasonable technical and organizational measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, considering the risks involved in the processing and the nature of the personal information.

 

However, please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, locking your computer when you leave it unattended, keeping your log-in and password private and following the stringent guidelines established by the company for protecting your data, account, and information systems. You agree that we are not responsible for lost, stolen, or compromised passwords or for any activity via unauthorized password activity.


 

8.      Policy Changes & Implementation

This policy is reviewed and updated annually. We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. This policy is implemented under the supervision of the organization’s appointed Data Protection Officer (DPO). The DPO works closely with the organization to ensure that privacy principles and required privacy controls are implemented and maintained on an ongoing basis. The DPO negotiates a budget for privacy operations and implementation with CIO/CISO annually.

 

We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Websites.

 

9.      Contact Information

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact us at:

 

Email privacy@innovasi.com

 

Data Protection Officer:

Robin Evans, CPO/DPO InnovaSystems Int’l, LLC evansrp@innovasi.com