California Workforce Privacy Notice

This California Workforce Privacy Notice (“Notice”) describes how Verizon and its family of companies (“Verizon”, “we”, “us”, and “our”) collect, use, and disclose Personal Information about California residents who are our current and former employees, job applicants and potential job applicants, and these individuals’ emergency contacts, spouses or domestic partners, dependents, and beneficiaries named under certain of the our benefit plans

“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 a particular individual or household. 

This Notice does not form part of any contract to provide services.  If you are not our employee, the points applicable to employees in this Notice do not apply to you.  If you provide your information to a third party directly, that company’s privacy policy applies.   If you are an independent contractor or contingent worker, please refer to the contractor notice.

This Notice does not apply to our information practices with respect to your interactions with Verizon as a consumer or customer.  When you interact with us as a consumer or customer, the privacy policy and/or terms of service associated with that product or service apply.   

We may provide you a separate privacy notice on specific occasions when we are collecting, using, or disclosing Personal Information about you, so that you are aware of how and why we are using such information. We may update this Notice at any time. You can review the current Notice at any time on VzWeb or by visiting this California Workforce Privacy Notice. This Notice does not apply to the information subject to the Health Insurance Portability and Accountability Act of 1996, including information that our health plans collect. Such information is subject to our HIPAA Notice of Privacy Practices, available on Benefits Connections.

This Privacy Policy explains: 

1. The categories of Personal Information we collect 
2. The categories of sources from which we collect Personal Information about you
3. The purposes for which we use Personal Information about you
4. How we may disclose Personal Information about you
5. How long we keep Personal Information about you
6. Your rights and how to exercise them

The types of Personal Information we collect from or about you depend on your role with us and may include:

• Identification, contact information and related identifiers, such as full name; date and place of birth; citizenship; permanent residence; home and business addresses; telephone numbers; signature; and email addresses.
• Professional or employment-related information, including: 
  • Recruitment, employment, or engagement information, such as application forms and information included in a resume; cover letter or other information provided through the application or engagement process; copies of professional or employment-related documents, such as educational institutions attended, degrees and certifications,  and references. 
  • Non-public education information, for example: academic transcripts.
  • Career information, such as job titles; work history; start and end dates; work locations; employment, service, or engagement agreements; information about skills and qualifications, experience, and training; absence and leave records; professional memberships and affiliations; termination details; and other information you may provide in an interview or as part of our hiring application process.
  • Performance information for employees, such as appraisal and performance information and disciplinary; seniority; and grievance information.
  • Compensation and benefits information for employees, such as salary; bonus and commission; equity compensation; information; hours and overtime; leave information; bank account details (for payroll and reimbursement purposes only); benefits in which you may be enrolled; payroll records; and tax information. 
  • Business travel and expense information for employees, such as travel itineraries; expense reports; and corporate credit card usage.
  • Union representation, including grievances and which collective bargaining agreement applies.
• Internet, electronic network, and device activity and device information and related identifiers, such as interactions with VzWeb; job application; or job advertisement; publicly available social media activity; information about your use of Verizon network information, and communication systems and concession devices, including user IDs, passwords, IP addresses, device IDs, web logs, audit trails of system access, call and text usage, email and text content, destination IP addresses, and location information.  
• Preferences and other details, for example, hobbies and leisure activities; membership in voluntary/charitable/public organizations; and preferences regarding work tools, travel, hours, food for Verizon events, etc.
• Audio or visual and security-related information, such as photos and CCTV footage; badge swipe data; as well as other information relating to the security of our premises and remote workspaces.
• Personal communications: the contents of mail, email, or text messages on accounts or services, not owned or subscribed-to, by Verizon only for purposes of legitimate company investigations.
• Login credentials, for example, login credentials to an online account owned or subscribed-to by Verizon or as necessary to review personal communications as described in the preceding bullet point.
• Biometric information, for example a fingerprint or facial recognition for access control to Verizon sites.
• Geolocation, such as the location of Verizon vehicles and concession devices.
• Legally protected classification information, such as, for employees: race and ethnicity, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations and to support diversity and inclusion programs; disability, medical condition, and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with Federal and California law related to leaves of absence and accommodation; and marital and familial status as necessary to provide benefits to employees and for tax purposes.  
• Government identifiers, for example, Social Security, driver's license, state identification card, visa, or passport number. 
• Religion, for example if volunteered by an employee in support of the employee’s request for a religious accommodation.
• Financial account access information, for example: payment card information with CVV and other information as needed for the individual to purchase from a Verizon store.
• Sex life: to the extent relevant and necessary for a legitimate Verizon investigation and only if permitted by law, for example, as needed to investigate allegations of sexual harassment.  
• Sexual orientation and gender identity to the extent volunteered by the individual, for example, for diversity and inclusion programs.
• Health-related information, such as, for example, disability status; or health and safety incidents or accidents 
• Information about your partner, spouse, beneficiaries, and dependents, such as name; address; Social Security number; date of birth; and relationship status. 

Note on emergency contacts, spouses or domestic partners, dependents, and beneficiaries named under certain Verizon benefit plans (collectively your “Related Contacts”): 

• Verizon only collects contact information about emergency contacts.   
• Verizon may collect the following categories of Personal Information about spouses or domestic partners, dependents, and beneficiaries: (a) Identifiers; (b) Commercial Information if, for example, Verizon arranges travel for a dependent to attend a Verizon event; (c) Internet Activity Information if the individual uses certain Verizon electronic resources and web sites; (d) Sensory or Surveillance Data if the individual enters company facilities; (e) § 1798.80 Personal Information, such as insurance policy numbers if the individual is covered by Verizon insurance or a beneficiary; (f) Protected Categories of Personal Information, for example, childbirth to administer parental leave; marital status to pay taxes; and familial status to administer benefits; (g) Health Information, for example, infectious disease testing when a Related Contact attends a company event or if needed to administer a leave of absence for you to care for a Related Contact; (h) sex life, for example, date of newborn delivery to administer parental, Family & Medical Leave Act, or California Family Rights Act leave; (i) Login Credentials to Verizon benefits portal or site; and (j) Sensitive Identifiers, for example, Social Security numbers for beneficiary designations; personal communications if communicating with a workforce member.  

Note on inferring characteristics: We do not collect or process sensitive Personal Information or characteristics of protected classifications for the purpose of inferring characteristics about the Individual.  

• You, for example, in your application; forms you fill out for us; assessments you complete; surveys you submit; and any information you provide during the course of your application and interview process and/or during the course of your relationship with us.
• Your spouse or dependent with respect to Personal Information about them.
• Internally generated, for example, we may generate performance ratings; evaluations; hours worked; and other information about you.
• Vendors and service providers, for example, companies that administer employee services or benefits.  
• Affiliated companies, for example, when an employee works on a cross-enterprise team.
• Third parties, for example, job references; business partners; professional employer organizations or staffing agencies; insurance companies.
• Public internet sources, for example, social media; job boards; public profiles; and other public online sources.
• Public records, for example, court records; and credentialing and licensing organizations.
• Automated technologies on the Verizon electronic resources, for example, to track logins and activity across our network.
• Surveillance/recording technologies installed by Verizon, for example, video surveillance in common areas of Verizon facilities; global positioning system (“GPS”) technologies; voicemail technologies; webcams; audio recording technologies; and blue-tooth technologies; any of these with consent to the extent required by law.
• Labor processes, including collective bargaining processes; National Labor Relations Board processes to determine union representation; and grievance and arbitration processes. 
• Union agreements, including collective bargaining agreements and other agreements between Verizon and a union. 
• Government or administrative agencies, for example, law enforcement; public health authorities; California Department of Industrial Relations; Employment Development Department. 
• Acquired company, if Verizon acquired your employer, we might collect Personal Information about you from that employer.

Note: This Notice does not cover background screening conducted by third-party background check vendors subject to the federal Fair Credit Reporting Act.  Verizon provides separate notices for such screening. 

A.  All HR Individuals

Managing Personnel:

(Not applicable to Related Contacts)

To administer the workforce, including to:

• manage personnel and workforce matters
• communicate with the workforce 
• plan and arrange work supplies and workspaces
• fulfill recordkeeping and reporting responsibilities
• recruitment of new HR Individuals
• resolve internal grievances and disciplinary issues
• make business travel arrangements
• manage workforce-related emergencies, including health emergencies

To develop the workforce, including to:

• screen workforce for risks to Verizon and continued suitability in their positions
• conduct surveys

For team-building purposes, including to:

• maintain an internal workforce directory and for purposes of identification
• facilitate communication, interaction, and collaboration among HR Individuals
• arrange meetings and manage Verizon-sponsored events and public service activities
• promote Verizon as a place to work
• conduct Workforce reporting and data analytics/trend analysis
• workforce satisfaction

For purposes of monitoring, security, and legal compliance, including to:

• monitor use of Verizon information systems and other electronic resources or information systems
• conduct internal audits
• conduct internal investigations
• administer Verizon’s whistleblower hotline 
• protect the safety and security of Verizon’s facilities, including preventing illicit activity 
• report suspected criminal conduct to law enforcement and cooperate in investigations
• control access to secure facilities
• monitor compliance with Verizon policies
• exercise Verizon’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

To conduct our business, including to:
(Not applicable to Related Contacts)

• engage in marketing, advertising, and promotion
• communicate with prospective, current, and former customers
• provide a directory and contact information for prospective and current customers and business partners
• provide customer service 
• enable Verizon to comply with client contractual obligations
• manage and fulfill orders
• manage business expenses and reimbursements
• engage in project management
• conduct product and service training
• conduct research and development
• conduct quality assurance and improvement
• plan events
• engage in crisis management

Miscellaneous other purposes: 

• To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning;
• To manage litigation involving Verizon, and other legal disputes and inquiries and to meet legal and regulatory requirements; 
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Verizon or any of its subsidiaries or affiliates; 
• To manage licenses, permits, and authorizations applicable to our business operations; and
• To protect the rights, property, or safety of Verizon, HR Individuals, customers or others

B. Employees

Generally applicable purposes
Unless separately covered in section 3.B.2, below, we may use personal information about employees for the following purposes:

Managing Employees:

• To administer the employment relationship, including to:
  • set up and manage a personnel file
  • manage performance 
  • administer compensation, bonuses, equity grants, other forms of compensation, and benefits (as permitted by law)
  • manage vacation, sick leave, and other leaves of absence
  • track hours and attendance
  • monitor compliance with our policies and administer discipline
• To develop employees, including to:
  • provide, evaluate, and manage training
  • evaluate job performance and consider employees for other internal positions or promotions
  • assist with professional licensing
  • develop a talent pool and plan for succession 
  • Provide career development activities
• For team-building purposes, including to:
  • develop and manage diversity and inclusion programs
  • arrange team-building and other morale-related activities
  • design employee retention programs

Purposes specific to certain categories of personal information about employees
We may use the categories of employees’ personal information listed in this Section 3.B.2 for the purposes stated below:  

Purposes for using employees’ biometric information:

• Verizon uses biometric technology for security purposes to verify the identity of an individual entering certain our facilities.

Purposes for using employees’ geolocation data:

• Certain Verizon vehicles and devices contain GPS to help us efficiently plan routes and deliver services and/or to help inform customers generally when a technician will arrive.  

Purposes for using health information about employees: 

• To the extent necessary to comply with Verizon’s legal obligations, such as to accommodate disabilities
• To conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law
• For workers’ compensation purposes
• For occupational health surveillance
• For occupational health and safety compliance and record-keeping
• To conduct fitness-for-duty examinations
• To administer leaves of absence and sick time
• To provide a wellness program
• To respond to an employee’s medical emergency

Note: This Notice does not cover health information governed by the Health Insurance Portability and Accountability Act (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH Act), or California’s Confidentiality of Medical Information Act (CMIA).

Purposes for using employees’ personal communications:

• For purposes of legitimate investigations and, to the extent required by law, with your authorization.

Purposes for using employees’ religion: 

• Verizon may use employees’ religion to respond to, and manage, an employee’s request for an accommodation on the basis of religion.

Purposes for using employees’ financial account access information:

• We may use employees’ credit card information, including CCV or CVV, when an employee uses a payment card to make purchases from Verizon stores, for example to buy company branded paraphernalia.

Purposes for using sex life: 

• We may use information about an employee’s sex life only to the extent relevant and necessary for a legitimate investigation and only if permitted by law, e.g., as needed to investigate allegations of sexual harassment.  

Purposes for using employees’ sexual orientation: 

• We will use an employee’s sexual orientation only if voluntarily provided by an employee in connection with our diversity and inclusion programs.

Purposes for using employees’ protected categories of information:
Verizon collects information about race and ethnicity, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including but not limited to the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act.  We also collect information about disability status to the extent an employee may need special assistance during emergencies from Verizon or from first responders. 

Verizon may also collect the following characteristics (in addition to those listed above) for its diversity and inclusion programs (including analytics): (a) religion, (b) sex, (c) gender, (d) pregnancy, (e) childbirth, (f) breastfeeding, or related medical conditions, (g) sexual orientation, (h) disability, (i) gender identity, (j) gender expression, (k) marital status, (l) age, (m) familial status, or (n) ancestry.

Verizon also uses this personal information for purposes including: 

• with respect to disability, medical condition, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions: as necessary to comply with Federal and California law related to leaves of absence and accommodation; 
• with respect to military and veteran status: as necessary to comply with leave requirements under applicable law and for tax purposes; 
• with respect to age: incidentally to the use of birth date for birthday celebrations and identity verification; 
• with respect to religion and pregnancy, childbirth, breastfeeding, and related medical conditions: as necessary for accommodations under applicable law; 
• with respect to protected classifications, such as national origin: to the extent this information is contained in documents that you provide in I-9 documentation; and 
• with respect to marital status and familial status: for Verizon events and as necessary to provide benefits and for tax purposes.

We collect personal information about membership in protected categories on a purely voluntary basis, except where required by law, and use the information only in compliance with applicable laws and regulations.

C. Applicants and potential applicants

Recruiting, including to:

• evaluate applicants’ qualifications or suitability for employment with Verizon
• communicate with applicants
• conduct a pre-employment or criminal history background check
• develop and manage a diversity and inclusion program
• arrange and manage Verizon-sponsored events
• create a talent pool for future job openings
• keep records
• demonstrate applicants’ agreement to, or acceptance of, documents presented to them, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
• evaluate and improve the recruiting process

Purposes for using applicants’ health information: 

• To the extent necessary to comply with Verizon’s legal obligations, such as to accommodate disabilities
• To protect the health and safety of our employees and facilities, for example, to take the applicant’s temperature 
• For occupational health and safety compliance and record-keeping
• To conduct pre-employment medical examinations 
• To respond to an applicant’s medical emergency

Purposes for using applicants’ protected categories of information:
Verizon collects information about race and ethnicity, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and state laws, and for purposes of diversity analytics.  

We also use this personal information for purposes including: (a) with respect to disability and/or medical condition, as necessary, to comply with federal and state law related to accommodation; and (b) with respect to age, incidentally to the use of birth date for identity verification.

D. Contingent workforce

To manage the contingent workforce, including to:

• evaluate the individual’s qualifications for engagements, including licensure and certifications
• negotiate and execute the agreement with the individual
• provide orientation and familiarization with Verizon’s working environment 
• administer the contractual relationship, including payments 
• evaluate the HR Individual’s deliverables or performance of the contract
• manage absences

For more information, please visit https://www.verizon.com/about/privacy/ca-nonemployee-notice.

E. Related contacts

Spouse and Dependents/Beneficiaries 

• To manage and administer benefits
• To administer the relationship
• To communicate with the individual
• To arrange travel to, and manage participation in, Verizon events 

Emergency Contacts

• To communicate in the event of an emergency involving the individual who provided the emergency contact’s information 

Deidentified Information
At times, we convert Personal Information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”).  We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual.  We prohibit vendors, by contract, from attempting to reidentify Deidentified Information.  

We disclose Personal Information within Verizon and to others as described below:

Within Verizon
We disclose Personal Information to people within Verizon to carry out the purposes described in this Notice, including personnel within the company such as management, human resources, payroll, IT, legal, and finance.  We disclose Personal Information and/or sensitive Personal Information about you only to the minimum extent necessary to achieve the purpose of the disclosure.

Outside Verizon

• Service providers and contractors: We disclose Personal Information about you to service providers and contractors to assist us in meeting our business needs and contractual and legal obligations, for example Personal Information: service providers and contractors, such as compensation and benefits providers; tax and other professional advisors; technology service providers; corporate card issuers; travel management providers; transport providers; HR management and administration suppliers; background check companies; and employment businesses. 

• Affiliated companies: Other companies within the Verizon and family of companies. 
• Enterprise Customers: This may include, for example, disclosing a sales representative’s contact information with clients. 
• Business partners: For example, we might disclose your business contact information to a co-developer of a new product or service with which you will be working. 
• Government or administrative agencies: These may include, for example: 
  • Internal Revenue Service to pay taxes;
  • Employment Development Department as required for state payroll taxes and to respond to unemployment or state disability insurance claims;
  • National Labor Relations Board, for example, to notify the NLRB that an employee is represented by a union;
  • OSHA/CalOSHA as required to report work-related death or serious injury or illness
  • Department of Fair Employment and Housing as required to respond to employment; charges; and 
  • California Department of Industrial Relations as required to resolve workers’ compensation claims.
• Public: We may disclose Personal Information about you to the public as part of a press release, for example, to announce promotions or awards. We do not disclose sensitive Personal Information to the public.
• Labor union: We may disclose workers’ Personal Information to a union if it represents the worker or with worker consent. 
• Required Disclosures: When required or authorized to do so by law, regulation, or court order.
• Legal Compliance and Protections: When we believe disclosure is necessary to comply with the law or to protect the rights; property; or safety of the company, our users, or others; or in in response to a request for assistance by the police or other law enforcement agency; or to seek legal advice from our external lawyers or in connection with litigation with a third party.
• Corporate Transactions: In connection with the sale, purchase, or merger of a business (provided appropriate contractual provisions are in place between companies).
• Charitable contributions and volunteer hours: For example, we might disclose your business contact information when we match your donation to charitable organizations. 

No sales and no “sharing,” i.e., disclosure for cross-context behavioral advertising:
We do not sell the Personal Information of any individuals nor disclose Personal Information about them for cross-context behavioral advertising.

For applicants, if Verizon hires you, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes.  We will retain this application information for the entire duration of your employment relationship with Verizon and for as long thereafter as permitted or required by applicable law.  

For all members of the Verizon workforce, our policies require that we retain records containing personal information for as long as they are needed for legal, tax, audit, investigative, and/or security purposes and then securely delete or destroy them. We incorporate personal information into different types of records; it is not always retained by distinct data elements.

Your California Privacy Rights
Subject to applicable law, individuals have the following rights:

• Right to know: You have the right to submit a verifiable request for copies of specific pieces of Personal Information about you collected dating back to January 1, 2022 and for information about Verizon’s collection, use, and disclosure of Personal Information about you during that time period.  Please note that the CPRA’s right to obtain copies does not grant a right to the whole of any document that contains Personal Information, but only to copies of “specific pieces” of Personal Information.  Moreover, California Residents have a right to know categories of sources of Personal Information and categories of external recipients to which Personal Information is disclosed, but not the individual sources or recipients.  We do not always track individualized sources or recipients.  When we respond to your request for access, we may exclude certain information as permitted by law, including information that is highly sensitive, privileged or work product; certain company information; information about other individuals; information that is not searchable or reasonably accessible; and information related to the security and integrity of our systems and network. 
• Right to delete: You have the right to submit a verifiable request for the deletion of Personal Information that you have provided to Verizon. 
• Right to correct: You have the right to submit a verifiable request for the correction of inaccurate Personal Information we maintain, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.
• Right to opt out of sale and sharing: You have the right to opt out of the sale of Personal Information and the disclosure of Personal Information for cross-context advertising. 
• Right to restrict use and disclosure of sensitive personal information: You have the right to restrict the company’s use and disclosure of sensitive Personal Information to purposes permitted under the CPRA, such as security; quality control; uses required by law; and disclosures to vendors in support of the permitted purposes.  This right only applies to sensitive Personal Information collected or processed by Verizon or for the purpose of inferring characteristics about you.  

How to exercise your rights
Verizon will respond to requests to know, delete, and correct in accordance with applicable law if we can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

• Call 1-888-892-0053 
• Complete the request form available here: Workforce Intake Form

How we will verify your request
The processes that we follow to verify your identity when you make a request to know, correct, or delete are described below.  The relevant process depends on how and why the request is submitted.

If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below: 

1. Requests to know categories or purposes:  We will match at least two data points that you provide with your request, or in response to your verification request, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity.  Examples of relevant data points include your employee enterprise identification number, date of birth, or last four digits of your Social Security number.
2. Requests to know specific pieces of personal information:  We will match at least three data points that you provide with your request, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request.   
3. Requests to correct or delete personal information:  Our process for verifying your identity will depend on the sensitivity of the Personal Information that you ask us to correct or delete.  For less sensitive Personal Information, we will require a match of two data points as described in 1 above.  For more sensitive Personal Information, we will require a match of three data points and a signed declaration as described in 2 above.

We have implemented the following additional procedures when verifying the identity of requestors:

1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information.  If we do so, we will not use that information for any purpose other than verification.
2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

Authorized agents
If an authorized agent submits on your behalf a request to know, correct or delete, the authorized agent must submit with the request either (a) a power of attorney, signed by you, that is valid under California law; or (b) another document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. 

Non-discrimination and non-retaliation policy 
We will not unlawfully discriminate or retaliate against you for exercising your rights under the California Privacy Rights Act.  

How to contact us about this notice
For questions or concerns about our privacy policies and practices, please complete the form available at https://www.verizon.com/about/privacy/privacy-inquiries.  

Last updated December, 2022