California Employee Privacy Notice

Atria Senior Living, Inc., including our subsidiaries and affiliates (collectively, “Atria,” “us,” “we,” or “our”), provides this Employee Privacy Notice (“Notice”) to our California employees, contractors, and others who work for us (collectively, “Employees”). This Notice explains what Personal Information we collect about California Employees in the context of your employment, why we collect it, how we use and disclose it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as amended (the “CCPA”).

If you also interact with us as a consumer, please review our Privacy Policy for more information about our practices in that context.

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information includes “Sensitive Personal Information.” Personal Information does not include information that is publicly available, de-identified, or aggregated.

Unless otherwise noted, the disclosures that describe how and why we collect, use, and disclose Personal Information also describe how we have collected, used, and disclosed Personal Information in the preceding twelve (12) months.

How We Collect California Employee Personal Information

We collect the following categories of Personal Information about our Employees through various means, including when you directly provide it to us, automatically through your use of our electronic systems, created by us in the course of your employment, and from vendors that help us to run our business.

Identifiers, including real name, alias, postal address, unique personal identifier, nline identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Personal Information Described in Cal. Civ. Code § 1798.80(e), including your signature, physical characteristics or description, telephone number, insurance policy number, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information.
Characteristics of Protected Classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, and marital status.
Biometric Information, including fingerprints and facial scans, in limited circumstances where you are aware of the collection.
Internet or Other Electronic Network Activity Information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements.
Geolocation Data, including access-control data based on employee badge swipes and location data inferred from your device IP address.
Audio, Electronic, Visual, or Similar Information, including closed-circuit images, photographs, and video of you.
Professional or Employment-Related Information, including:

Recruitment information, such as skills, qualifications, references, recommendations, and other information included in a resume, application form, or cover letter;
Background information commonly used for onboarding and security screenings, such as results of background checks;
Employee profile information, such as employee status, organization information, performance and talent information, employment background, languages spoken, functional experience, leadership experience, honors or awards, education, training, professional certifications, evaluations, developmental planning, career interests and development information, and other talent management and team-based assessments;
Compensation, payroll, and benefits information, such as withholdings and tax information, (including information collected on IRS Form W-4 and California Tax Form DE 4); and information about births, adoptions, deaths, child medical support orders, loss of eligibility for medical coverage, and other life events that may trigger an opportunity to modify your benefits elections;
Emergency contacts/next of kin information, details about your spouse/partner, dependents and beneficiaries (such as their names, titles, relationship to you, addresses, telephone numbers, and email addresses);
Vehicle information (ex. year, make, model, color, and license plate) for parking assignments;
Medical, parental, family, vacation, and other leave and associated records, including details of the types of and reasons for leave being taken, duration of leave, and leave-related correspondence; and
Any termination of employment documentation, including resignation letters, dismissal letters, minutes of meetings, settlement agreements and related correspondence.

Non-Public Education Information, including school(s) attended and other information relating to your secondary and post-secondary education.
Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Some of the Personal Information we collect is considered Sensitive Personal Information under the CCPA, including: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or citizenship or immigration status; the processing of biometric information for the purpose of uniquely identifying a consumer; Personal Information collected and analyzed concerning a consumer’s health (i.e., drug-screening information); and Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

How We Use California Employee Personal Information

We may use the Personal Information we collect about you for various purposes related to your Employment, including:

To onboard and enroll you as an employee;
To manage job duties, evaluate performance, and operate our business;
To provide compensation and benefits;
To communicate with you;
To improve our business and internal operations, set default options, and provide you with a better Employee experience;
To manage corporate information technology;
To investigate, detect, identify, prevent, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our policies;
To manage the security of our premises and systems;
To comply with applicable laws, regulations, or legal processes, as well as industry standards and our policies; and
For any other purpose, with your consent.

How We Disclose California Employee Personal Information

We may disclose Personal Information, as described above, for any purposes not inconsistent with this Notice, our written statements at the point of collection, or applicable law. In general, we disclose Personal Information as follows:

Within our group of companies including with our affiliates, subsidiaries, locations, and brands.
With our agents, service providers, consultants, and other vendors in order for them to provide their services to us, including to provide benefits, communicate with you, and otherwise operate our business.
As necessary, for the following purposes: to comply with any legal process; to respond to requests from public and government authorities; to enforce our policies, terms, and agreements; to protect our operations and protect our rights, privacy, safety, or property, and/or that of you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.
With our insurers and professional advisers for the purposes of managing risks, exercising or defending against legal claims, and otherwise obtaining professional advice.
With third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

How Long We Keep Your Personal Information

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

The Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
The Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
The Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case);
The Personal Information may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes; or
We are otherwise required or permitted to keep the Personal Information by applicable laws or regulations.

Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information, please refer to our retention policies and schedules.

Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request to CAprivacyrequest@atriaseniorliving.com or call us at 800 928-9145.

Please note that, if you submit a request to know, request to delete, or request to correct, you may be asked to log into your account or to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

The categories of Personal Information we have collected about you, including:

The categories of sources from which the Personal Information was collected.
Our business or commercial purposes for collecting or disclosing Personal Information.
The categories of recipients to which we disclose Personal Information.
The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out of Sales and Sharing. We do not sell or share for cross-context behavioral advertising, as those terms are defined under the CCPA, the Personal Information of California Employees. For this reason, we do not offer a way for you to submit such a request.

We do not engage in automated decisionmaking, including profiling in furtherance of decisions that produces legal or similarly significant effects. If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate against you.

How to Contact Us

If you have any questions about how Atria handles your Personal Information or if you need to access this Notice in an alternative format because of a disability, please contact our Human Resources Department at:
Phone: 800 928-9145
Email: CAprivacyrequest@atriaseniorliving.com