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Comprehensive Pharmacy Services, LLC Job Applicant Privacy Notice

This privacy notice (“Privacy Notice”) discloses the privacy practices by Comprehensive Pharmacy Services, LLC and affiliates (“CPS”, “we”, or “us”) in the context of your application for employment with CPS or a CPS affiliate (“application for employment”).

This Privacy Notice only applies to information collected in context of your application for employment. This Privacy Notice outlines the following:What is personally identifiable information (“PII”);

1. What categories of PII are collected in the context of your application for employment;

2. What categories of sources from which we collect your PII;

3. Why we collect your PII;

4.How do we share your PII outside of CPS;

5. How we protect your PII; and

6. How you can submit your requests to access or delete your PII, or opt out of the sale of your PII (applicable to California residents only).

What is PII?

CPS defines PII as information we collect that can either identify you or that can be reasonably linked to you.  Such information that CPS collects about you in the context of your application for employment to CPS includes your first name, last name, email address, postal address, phone number, professional license information, work and education experience.

What Categories of PII Are Collected in the Context of Your Application for Employment?

CPS may collect the following categories of PII in the context of your application for employment, although not all categories may be collected about every person:

  • Identifiers you provide to CPS such as first name, last name, email address, home mailing address, and/or phone numbers.
  • Characteristics of protected classifications you may provide to CPS such as gender, race, and citizenship.
  • Professional or employment-related information (such as information on your resume or curriculum vitae related to past employment, work experience, and information related to any legal issues or disputes that may arise, including disciplinary actions and history by state licensure boards or other government entities).
  • Education information (such as information on your resume related to your educational experience and records).
  • Audio, visual, or other sensory information (such as your recorded video interview or closed camera television footage, if applicable).

What are the Categories of Sources From Which We Collect PII?

You may share PII with CPS, either actively or passively, through the following categories of sources from which we collect personal information:

  • Provided directly to us by you; and
  • Collected by CPS from an external third-party source, such as social media or professional networking sites (e.g., LinkedIn).

Why Do We Collect Your PII?

CPS uses the PII we collect about you in order to evaluate your candidacy for the job opening(s) for which you have applied and other job openings at CPS that may be of interest to you.  We may also evaluate your PII using business analytics tools and algorithms internally and via service providers to discover ways to improve our business and job application tools, identify trends in our job applicants and workforce, and enhance our service offerings.

How Do We Share Your PII Outside of CPS?

We will not share your PII with any third party outside of CPS, other than for a business purpose, as described below. We also do not share your PII with third parties for such third parties’ direct marketing purposes. We do not sell or rent your PII for monetary consideration.

We may share your PII with service providers that help with our business activities, for example Human Resource service support vendors and similar companies. We require our service providers to keep your PII secure, and we do not allow our service providers to use or share your PII for any purpose other than providing the services for which we have contracted on our behalf.

We may share your PII in special circumstances, which include situations when such sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of CPS, our affiliates, our clients, employees, or other persons. Special circumstances in which we may be required, or in which we may share your PII for safety reasons, include: protecting the health or safety of our clients or employees, addressing crimes committed on or involving our property, identifying and addressing fraud or financial risk, responding to search warrants or other valid legal inquiries, and responding to investigatory or regulatory bodies in the case of a breach of an agreement or violation of law.

Additionally, in the event that all or a part of our business is merged, sold, or reorganized, your PII could be shared with the successor entity. We will work with the successor entity and use reasonable measures to treat your PII in accordance with this Privacy Notice.

Except for the situations described above, we will ask for your affirmative consent before sharing your PII outside our family of companies.

How do we protect your PII?

We value the trust you have placed in us to provide your PII. As such, we are committed to protecting your information and privacy. When PII is collected in the context of your application for employment, that information is protected through a series of internal administrative, physical, and technical controls that ensure the confidentiality, integrity, and availability of PII is not compromised. We require the same degree of care be taken by service providers with whom we share PII for business purposes.

While we use encryption to protect PII transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, Human Resources) are granted access to PII. The servers in which we store PII are kept in a physically secure environment.

How Do You Submit Requests to Access or Delete Your PII, or Opt Out of the Sale of Your PII (California Residents Only)?

If you are a California resident, you have certain privacy rights that permit you to submit to us certain requests regarding your PII, and we will fulfill your requests to the extent we are required by law. The process listed below should also be followed if you are an authorized agent of a California resident who wishes to submit to us certain requests regarding their PII. “California resident” has the same meaning as that in Section 17014 of Title 18 of the California Code of Regulations.

If you want to submit a request to access or delete your PII, or to opt out of the sale of your PII, you can contact our toll-free number, 1-833-450-4229, or email privacy@cpspharm.com with your first name, last name, home mailing address, preferred contact information (for example, your email address or telephone number), and your request. The information you provide when submitting your request will only be used to verify your identity and identify you in our data or the data of our service providers. We will send you a written confirmation that we have received your request via the communication method you choose (email or postal mail) along with any follow-up questions or instructions for us to complete your request, including requests for additional information in order to verify your identity. You must submit a separate request for each individual request to access or delete your personal information or to opt out of the sale of your personal information to ensure each request is handled properly.

Specifically, you may:

  • Request that we disclose to you the PII we have collected or shared within the 12 months prior to your request, including the list of categories of PII we have sold and/or shared with another company for a business purpose;
  • Request that we delete your PII, to the extent required by law; or
  • Request that we stop selling your PII.

If you request a disclosure of your PII, we will provide to you, to the extent required by law:

  • The categories of PII we have collected from or about you,
  • The categories of sources from which we collected your PII;
  • The business or commercial purpose for which we collected or sold your PII;
  • The categories of third parties with whom we shared your PII; and
  • The specific pieces of PII we have collected about you, including PII maintained by our service providers.

If you request that we delete your PII, we will, to the extent required by law:

  • Delete your PII from our records; and
  • Direct any service providers to delete your PII from their records.

As a California resident, you may request that we not sell, or stop selling, your PII. California law defines “selling” or “sell” as “selling, renting, disclosing disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. If you request that we stop selling your PII, we will, to the extent required by law:

  • Not sell your PII to third parties unless you subsequently provide express authorization for the sale of your PII;
  • Not require you to create an account in order to direct us not to sell your PII;
  • Use any PII collected from you in connection with your request for us to stop selling your PII solely for the purposes of complying with your opt-out request; and
  • Respect your decision to opt out of the sale of your PII for at least 12 months before requesting that you authorize the sale of your PII again.

We will not discriminate against you in your application for employment with CPS because you exercised any of the rights listed in this Privacy Notice.

CPS may still use any aggregated and de-identified information that does not identify any individual and may also retain and use your PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you believe that we are not abiding by this privacy policy, you should contact us immediately via telephone at 833-450-4229 or at privacy@cpspharm.com.

Date Reviewed: 2/5/2021