California Consumer Privacy Rights
U.S. Privacy Policy and Notice
Pursuant to the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”), together referred to as “CCPA/CPRA”, we are providing the following notice to individuals who reside in the State of California.
Information we collect:
To allow ComPsych to provide employee assistance programs and behavioral health, work-life, wellness and FMLASource to provide HR administration services (“Services”), we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular Participant (“Personal Information”).
In particular we may collect the following categories of Personal Information for the purposes set out below:
| Personal Information Category | Types of information we may collect | How we may use the information collected |
|---|---|---|
| Identifiers | Your name, alias, postal address, email address, username, social security number or other similar identifiers | To identify you and authenticate your identity To communicate with you and for any purpose related to the services provided to you |
| Personal Information Categories listed in the relevant state law | Your name, social security number, education, employment, employment history, postal address, email address and telephone numbers | To communicate with you and for any purpose related to the services provided to you To allow us to manage our relationship with you, such as providing you with information we feel would be of interest to you or to facilitate responding to further requests or inquiries from you To inform you of new products or changes to products and services |
| Professional or Employment Related Information | Place of work, employment history, job title, leave of absence related information | To administer services to you |
| Sensory Information | Telephone recordings (FMLASource only) and transcripts, emails, letters, online chat or other records of communication with you | For quality assurance and training purposes To assist in providing services to you To retain a record of communications with you To assist in resolving any disputes and improve your experience |
| Internet or other similar network activity | Login data, browser type and version, time zone setting and location | To personalize your website experience To provide services tailored to you |
| Sensitive Personal Information Category | Types of information we may collect | How we may use the information collected |
|---|---|---|
| Health Information | Information related to your physical and/or mental health which we received in connection to your use of our services | To provide requested services to you |
| Protected classification characteristics under California or federal law | Age, marital status, gender | To provide requested services to you |
We may also collect and use your Personal Information for business and operational purposes, to address legal and regulatory requirements, including to enforce our legal rights, as described to you when collecting your Personal Information or as otherwise set forth in the CCPA/CPRA. We obtain the categories of Personal Information listed above directly from you and indirectly from you, i.e., from your employer.
Personal Information does not include de-identified or aggregated consumer information. De-identified personal information may be used to report aggregate utilization of services to your employer or group health plan. Such reporting is anonymous, meaning that your name or other personally identifying information will never be disclosed to your employer or group health plan in these reports.
Requests related to Protected Health Information (PHI) are subject to the Health Insurance Portability and Accountability Act (HIPAA) and, therefore, outside the scope of the CCPA/CPRA. If your request relates to PHI, please visit https://www.compsych.com/privacy/hipaa for more information.
We will not intentionally disclose your Personal Information to third parties without your permission. However, Personal Information may be provided to third party service providers related to the services provided to you. We do not disclose, and have not disclosed in the preceding 12 months, personal information to third parties for cross-context behavioral advertising.
For absence management services, FMLASource may disclose to your employer any Personal Information you disclose to FMLASource.
Data Subject Rights
Correct or Delete Personal Information: You have the right to request that ComPsych/FMLASource amend Personal Information that is inaccurate or outdated and delete any Personal Information about you that ComPsych/FMLASource has collected, subject to the limitations outlined in the CCPA/ CPRA. ComPsych/ FMLASource reserve the right to verify that any request for information, amendment or deletion originates from a California resident about whom the Personal Information pertains before disclosing or deleting the information. ComPsych/ FMLASource also reserve the right to request information from a requestor in order to allow us to investigate and respond to a request pursuant to this paragraph.
Access Personal Information: You also have the right to request the following information relating to the collection of your Personal Information by ComPsych/FMLASource in the 12-month period preceding your request, if applicable: (1) the categories of Personal Information ComPsych/ FMLASource has collected or disclosed about you; (2) the categories of sources from which your Personal Information is collected; (3) the business or commercial purpose ComPsych/FMLASource has for collecting your Personal Information; (4) the categories of third parties with whom ComPsych/FMLASource shares Personal Information; and (5) the specific Personal Information ComPsych/FMLASource has collected about you.
For requests subject to the CCPA/CPRA, ComPsych/FMLASource will provide the requested information, free of charge, within 45 days of receiving your request. To make a request, you can contact ComPsych/FMLASource via email at [email protected] or by calling 312- 660-1076.
ComPsych/FMLASource does not sell, and has not sold in the preceding 12 months, Personal Information that it has collected to any third parties.
Since we do not sell or share your information with third parties (other than as necessary to provide you with services), the Right to Limit selling or sharing of your Personal Information and the Right to Limit the disclosure of Sensitive Personal Information is not applicable.
ComPsych/FMLASource does not discriminate against individuals on the basis of that individual’s exercise of their rights pursuant to the CCPA/CPRA as described above.
ComPsych/FMLASource reserves the right to change its privacy practices at any time and any such change shall apply to all Personal Information ComPsych/FMLASource maintains, including information created or received by ComPsych/FMLASource prior to issuing a new Notice. If ComPsych materially changes its privacy practices, this Notice shall be amended.
Updated 2023