(California Consumer Privacy Act)

Issued December 16, 2022

Introduction:  This Privacy Policy describes the practices of Morrow-Meadows Corporation and Cherry City Electric (“the Company”) concerning the collection and use of personal information from candidates, employees, and customers.  This Policy is issued pursuant to the California Consumer Privacy Act and California Privacy Rights Act (“CCPA.”) 

The CCPA provides individuals in California with new rights concerning the collection and sale of their personal information (“PI”) by employers and other businesses.  Personal information means information in any format that identifies a specific person or household, such as an individual’s name, address, social security number, and email address, but does not include information from public sources.  The rights protected by the CCPA include the following: 

Notice:  The CCPA gives individuals certain rights to receive notice and disclosure by a covered business of the categories of PI that the business collects and sells, and the purposes for which the information is collected and sold. 

Access and Portability:  The CCPA gives individuals certain rights to request access to the PI that the business has collected about that individual.

Correction and Deletion:  The CCPA gives individuals certain rights to request that a covered business correct or delete certain PI that the business had collected about that individual.

Opt-Out and Limited Use: The CCPA gives individuals certain rights to instruct a business that sells or shares PI about individual to third parties not to sell or share that individual’s PI, or to use their PI only for specific purposes.

Non-Discrimination/Retaliation:  The CCPA forbids certain forms of discrimination (such as pricing, quality, or quantity of goods sold, etc.) or retaliation by a business against any individual for exercising their CCPA rights.

Opt-Out of Automated Decision-Making Technology:  The CCPA gives individual certain rights to up out of the use of decision-making technology with respect to the individual’s PI.  

Financial Incentives:  The CCPA requires disclosure of any financial incentives the Company provides to individuals relating to the use or disclosure of their PI.  

However, many of these provisions in the CCPA do NOT apply to the Company because Morrow-Meadows and Cherry City Electric are not in the business of collecting and selling or sharing PI with others.  Nor do we use automated decision-making technology or offer financial incentives relating to the use or disclosure of PI.  Instead, the Company is engaged in the business of designing and building electrical and data systems for commercial and industrial projects such as office buildings, hospitals, schools, and stadiums.  The Company does collect some PI in the ordinary course of its business, but this information is used for legitimate purposes such as hiring and employing personnel and enabling the Company to provide design and construction services to our corporate clients.

This Privacy Policy describes the categories of PI that the Company collects , and the purposes for which the PI is collected, and summarizes the rights of candidates and employees under the CCPA.  This Notice will be updated each year and as the law changes. 

For further information, contact Human Resources in person or via HR@morrow-meadows.com. You may also consult the California Attorney General website: https://oag.ca.gov/privacy/ccpa

What Categories of Personal Information Does Morrow-Meadows Collect?

There are two basic categories of PI that the Company collects:  (A) employment-related information concerning employees and candidates for employment, and (B) customer-related information concerning the employees and contractors of customers and prospects for the Company’s services.

            A.        Employment-Related PI:

The Company collects PI about employees and candidates for employment for the purposes of employing, compensating, and providing benefits to employees and complying with the Company’s legal obligations under federal, State, and local employment laws.  The PI that Morrow-Meadows collects from candidates and employees includes any or all the following information:

Account Type

Alien Expiration Date

Alien Registration Number/USCIS Number

Amount (ex: entire pay, or split)

Apprenticeship #

Authorization for Electronic Paystubs

Bank Account #

Bank Account Routing #

CA State Certification Expiration Date (if applicable)

CA State Certification Number (if applicable)

CA Trainee ID Number (if applicable)

Certifications (if applicable)

Children’s Name(s) with Age(s)

Citizenship Status

City

Country

County

Covid 19 Vaccination record

Date and place of birth

Degrees and certificates

Dependents and other family members

Dispatch slip including classification/title, union, pay rate

Driver’s License Expiration Date

Driver’s License Number

Email Address

Email Address

Emergency Contact First Name

Emergency Contact Home Phone #

Emergency Contact Last Name

Emergency Contact Mobile Phone #

Emergency Contact Relationship

Emergency Contact Work Phone #

Employment Type (full time, part time, seasonal)

Federal Filing Status (single, married, head of household)

Federal Filing Status (single, married, head of household)

Federal Tax Withholding

Financial Institution

Foreign Passport Country of Issuance

Foreign Passport Number

Form 1-94 Admission Number

Form(s) of Identification (ex: Driver’s license and SSC or Passport)

Gender

Hiring Manager

Home Phone #

Home Address

If a preparer or translator was used when completing the Immigration documents and Form I-9

Job Title

Licenses and permits

Marital Status

Mobile Phone #

Name First

Name Last

Name Middle

Name Other

Name Preferred (voluntary)

Oregon Electrical License #

Pay Rate

Payroll Distribution Form (how/where to deliver paychecks/stubs)

Personal characteristics such as marital status, gender, age, and ethnicity

Photos and Photo Release

Primary State Living

Prior work experience

Race/Ethnicity

Resume

Safety Orientation initials and electronic signature

Social Security Number

Spouse’s Full Name

Spouse’s Preferred Name

State

State (Working)

State Tax Withholding

Street Address

Suffix (Jr., Sr., II, etc.), if applicable

T shirt size

Thumbprints and other biometric data

Union ID Number (if applicable)

Username

Various Acknowledgments of Company Policies

Veteran Status

Voided Check or bank statement

Wage garnishments including for spousal or child support deductions

State Electrical License #

Work Location

Zip/Postal Code

Not all this information is considered PI under the CCPA.  For example, the CCPA may not apply to (A) personal information that is collected through a background check by a third-party agency, (B) personal information that is available from public governmental records, and (C) personal information including patient health information that is collected solely to administer the Company’s employee benefit plans and leave of absence policies.  

            B.        Customer-Related Information:

The Company collects limited amounts of personal information from customers and prospects for purposes of delivering the Company’s services.  Specifically, in negotiating and performing contracts for data and electrical contracting services, the Company will collect some PI about the employees and contractors engaged by the prospect or customer who will be involved in completing the project, including:

Names

Title

Work phone number

Work email address

Work address

From What Sources Does Morrow-Meadows Collect This Personal Information?

Most of the employment-related information the Company collects for employment purposes comes from the applicants or employees, but it also collects some PI from other sources such as (A) previous employers of an applicant or employee, (B) labor unions who have or will represent the employee; (C) schools that provided education and training to applicants or employees, and (D) courts and litigants in legal proceedings involving applicants or employees.

The source of customer-related information is the prospect or customer for the Company’s services.  

Why Does The Company Collect This Personal Information?

The Company collects employment-related information from applicants and employee for the purposes of (A) employing them in compliance with applicable federal, State, and local laws concerning employment, wages and hours, employee benefits, equal employment and no-discrimination, taxation, immigration, and other subjects; (B) complying with the Company’s obligations under collective bargaining agreements with unions representing its employees; and (C) providing coverage under employee benefit plans offered by the Company and the unions (including group medical, dental, vision, disability, and life insurance) or by governmental agencies (including workers compensation, State Disability Insurance, Paid Family Leave, and unemployment insurance.)

The Company collects customer-related information from the prospect or customer for the purpose of delivering the services the Company has agreed to provide.  

Does The Company Sell or Disclose My Personal Information to Third Parties?

No.  Morrow-Meadows does not sell any of the personal information that it collects from applicants and employees to third parties, and it has no intention of doing do.  This is true with respect to both employment-related information and customer-related information. 

The Company does disclose some employment-related information to third parties for the purposes of complying with the employment laws mentioned above.  For example, the Company discloses PI about its employees to:

(A)      Local and international labor unions that represent the Company’s employees and to the National Association of Electrical Contractors (NECA) of which the Company is a member to assure that employees are provided with the wages, benefits, and other terms and conditions of employment as required by applicable collective bargaining agreements. 

(B)       Companies that provide personnel services to the Company such as payroll, COBRA and unemployment administration, and employee training to assure that employees are paid all wages and benefits due from their employment.

(C)       Group medical insurers, health care providers, and government agencies to enable employees to participate in employee benefit plans offered by the Company or by government agencies; and

(D)      Government agencies, courts, arbitrators, and other parties in legal or administrative proceedings when such evidence is relevant to the proceeding. 

The Company also discloses some customer-related information to third parties for the purpose of performing contracts for the Company’s services.  For example, with each construction project, the Company, the customer, and other contractors working on the project will exchange the contact data for the personnel that each of them has assigned to the construction project so that they can coordinate and manage all activities required to complete the project.

Other than as described above, the Company has not sold or share any personal information with any third parties in the past 12 months, for any purpose. 

How Does the Company Keep My PI Safe?

The Company has organizational and technical processes and procedures in place to protect personal information from unauthorized use or disclosure.  In general, only authorized employees can access and use personal information relating to candidates and employees, and only for proper purposes.  The Company also obtains assurances from each of its third party providers that they will use any PI only for proper purposes and will maintain proper safeguards for protecting the privacy of all PI.

However, no information storage technology is 100% secure, and the Company cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat the Company’s security measures and improperly collect, access, steal, or modify PI.

Do I Have the Right to Know What Personal Information Morrow-Meadows Has Collected About Me? 

Yes.  Most of the PI that the Company collects relating to applicants and employees comes from the applicants and employees themselves through job applications, resumes, interviews, and other phases of recruitment.  But employees and candidates can also request the Company to disclose the personal information that it has collected concerning the individual.  In addition, employees have certain rights under California law to inspect and obtain a copy of their personnel files, time and payroll records, records relating to any grievance, and any document they signed in connection with obtaining or holding employment, all of which contain employment-related personal information. 

Do I Have the Right to Require The Company to Correct My Personal Information?

Yes.  All employees have the right to update or correct any errors in any PI concerning them in the Company’s possession, and are expected to notify the Company of any change in their name, marital status, spouse or dependents, beneficiaries, residence, social security number, immigration status, and tax withholding. 

Do I Have The Right To Limit the Company’s Use of My PI?

In most cases, no.  Since the Company uses personal information only to comply with its legal and contractual obligations and does not sell or share personal information for any other purposes, the CCPA does not require the Company to limit the use of any individual’s personal information.  Nonetheless, any individual may request the Company to limit the use of their personal information the Company has relating to that individual by submitting a written request to Human Resources in person or via HR@morrow-meadows.com.  The Company will then review and respond to the request as provided in the CCPA. 

Do I Have the Right to Delete any of My PI?

In most cases, no.  The CCPA does not require the Company to delete PI that is necessary to comply with applicable laws such as the various employment laws noted above.  For example, the Company cannot delete the name, social security number, address, pay rate, benefit enrollments, tax exemptions, or immigration documents relating to a current or former employee because the Company is legally required to maintain and utilize that information under various employment and tax laws.  Nor does the CCPA require the Company to delete PI that is necessary to provide the Company’s services and is used only for that purpose, such as the contact data for personnel engaged by the customer or another contractor to work or oversee each construction project.

The CCPA also contains various other exceptions to the right to request deletion of PI.  Nonetheless, any individual may request the Company to delete or correct any PI the Company has relating to that individual by submitting a written request to Mike Berkley.  The Company will then review and respond to the request as provided in the CCPA. 

Do I Have The Right To Opt-Out of The Company’s selling or Sharing of My PI?

No, because the Company does not sell PI to third parties, and it shares PI only for the lawful purposes outlined in this Policy from which there is no right to opt out.

How Long Does the Company Keep PI?

The Company complies with all laws relating to the length of time for which specific records must be kept.  With respect to employment-related information concerning applicants and employees, the Company maintains personnel, payroll, time, and benefit records for the period of the individual’s employment plus an additional 4.5 years.  The time period for which other records are maintained depends on the nature of the record and applicable laws. 

With respect to customer-related information, the Company typically retains all such records for each project until the project is fully completed plus a period of at least 4 years thereafter. 

Does the Company Sell or Share PI with others?

No.  The Company is not in the business of selling the PI in its possession to any third party for any purpose.  As noted above, the Company does share some employment-related and customer-related personal information to third parties such as unions, payroll services, insurers, benefit plans, prospects, and customers as necessary for the Company to employ personnel and comply with its legal and contractual obligations. 

Does the Company Use Automated Decision-Making Technology in Processing PI?

No.

Does the Company Provide and Financial Incentives for the use or disclosure of PI?

No.

Can the Company Discriminate or Retaliate Against Me For Exercising My Rights under the CCPA?

No.  The CCPA forbids any form of discrimination or retaliation against any individual because they have exercised their rights under the CCPA.  Any individual who believes they have been discriminated or retaliated against may file a complaint with Human Resources either in person or via HR@morrow-meadows.com.  The Company will investigate and take corrective action if appropriate. 

How Can I Learn More About The Company’s Policies and Procedures Concerning the Privacy of My Personal Information? 

For further information, contact Human Resources either in person or via HR@morrow-meadows.com, or also consult California Attorney General website: https://oag.ca.gov/privacy/ccpa