Do Not Sell My Personal Information

Last Updated: December 23, 2019
Effective Date: January 1, 2020

You’ve arrived at our Do Not Sell page. In its efforts to help you find a job, recruit a candidate for a vacancy at your company or provide you with information via this website, Frank Recruitment Group Inc. and its affiliates (collectively “FRG” or “we” or “us”) may sell your personal information to third parties.  Your  opt-out or opt-in choices are very important so please read this notice carefully and let us know if you have any questions.

If you would like to exercise any of your other California Consumer Privacy Act rights, please email us at privacy@frankgroup.com, use the interactive webform located here, or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717.

Here is a summary of your CCPA rights:

I. You have the right to know, to the extent applicable:

1. The categories of sources from which we collected personal information about you.

2. The categories of personal information we collected about you.

3. The categories of personal information that we disclosed about you for a business purpose.

4. The categories of third parties with whom we share personal information.

5. The categories of personal information we sold about you.

6. The categories of third parties to whom we sold your personal information, by category, for each third party to whom we sold the information.

7. Our business or commercial purposes for collecting or selling personal information.

8. The specific pieces of personal information we collected about you.

II. You have the right to request, to the extent applicable:

1. That we do not sell your personal information to third parties.

2. That we delete your personal information.

3. That we provide you with a copy of your personal information that we collected.

Before we can respond to your request, we’ll need to verify your identity.

See our  California Privacy Addendum under the caption “California Consumer Privacy Act Disclosures” for more information about the CCPA.

III. Why is this page here?

The California Consumer Privacy Act (“CCPA”) requires businesses subject to the law to provide consumers residing in California (“consumer” or “consumers”) with the right to opt out of the sale of their personal information through a clear and conspicuous link on their main homepage called “Do Not Sell My Personal Information.”

If a business maintains a separate webpage dedicated to California consumers rights, it can put the Do Not Sell link on that page instead of on its main homepage as long as it takes reasonable steps to direct California consumers to that page.

The California Attorney General may also develop a “recognizable and uniform opt-out logo or button” for all businesses to promote consumer awareness of the right to opt out. If the AG develops this, businesses should use it instead of a text link.

Businesses may not require a consumer to create an account in order to opt out of sales of personal information, and they may only use the information collected during the opt-out to comply with the opt-out.

When a consumer opts out, businesses must not sell their personal information and cannot ask them to opt-in again for 12 months from the date of opt out.

IV. Does FRG need to train its employees and vendors about the CCPA?

Yes. Businesses also need to train their staff who handle consumer requests about privacy, including making sure they:

  • Know about the CCPA generally
  • Can inform consumers about how to exercise their rights
  • Understand how to access the “Do Not Sell My Personal Information” page and how it works
  • Do not sell the personal information of consumers who opt out (or who have not opted in, in the case of children aged 16 or younger)
  • Wait 12 months before asking consumers who opted out to opt in again
  • Use any personal information collected as part of an opt out only to process the opt out
  • Respect opt outs made on behalf of another person per details to be provided by the  California Attorney General’s office

V. Does FRG need to update its privacy policy for CCPA?

Yes. Businesses need to update their privacy policies to comply with the California Consumer Privacy Act. For CCPA, FRG has added a special addendum to its global privacy notice which you can find here.

VI. Disclosures Required Under CCPA:

1. A link to FRG’s “Do Not Sell My Personal Information” notice.

a) Please visit frankgroup.com/donotsell.

2. A description of a consumer’s rights pursuant to CCPA Section 1798.120:

a) Your Right to Opt Out. If you’re a consumer residing in California and we sell your information to third parties, you can tell us at any time not to sell your personal information. This right to opt-out applies if we do not know your age or if we know you are older than age 16.

b) Your Right to Opt In. If we have actual knowledge that you are between ages 13 and 16 (e.g., based information we collect, or because someone informed us), we will never sell your personal information without your affirmative authorization. If we have actual knowledge that you are younger than 13, we will never sell your personal information without your parent or guardian’s affirmative authorization. This is your right to opt in.

c) Do We Sell Your Personal Information? At this time, we may sell your personal information and you can opt out at any time. If you opt out, or for children 16 and younger, if you have not opted in, we will not sell your personal information to third parties unless you expressly authorize us to do so.

3. A description of a consumer’s rights pursuant to CCPA Section 1798.110: California consumers have the right to request that we disclose to you:

a) The categories of personal information it has collected about you.

b) Personal information is information that identifies or relates to a particular consumer or household including name, postal address, email address, IP address, social security number, personal property records, purchasing histories, biometric information, internet activity such as browsing or search history, geolocation data, employment information, education information and inferences drawn from this information, in so far as it is not publicly available information. In addition to the above types of personal information that we may collect, FRG may collect personal information. Personal information also includes any of the following:

i) Name;

ii) Contact details e.g. street address, email address, telephone number;

iii) Work Experience;

iv) Job Title;

v) Professional Certifications;

vi) Education & Qualifications;

vii) Skills;

viii) Career History;

ix) Salary Range;

x) Right to work status \ citizenship;

xi) Other information relevant to help us provide recruitment services;

xii) References from past employers; and

xiii) IP address

c) For Contract Candidates Only (consumers/individuals who are employed by, consult with and/or own an entity recruited by FRG to provide contract or temporary technical professional services to an FRG client (or an FRG client’s client))

i) In addition to the personal information listed above, FRG may collect the following from you:

1. Tax details and proof of payment and submission;

2. Commercial insurance information; and

ii) Bank and payment details.

1. While this information may relate to your company or your employer rather than being your personal information, we have listed this information for transparency.

2. If your provision of personal information to FRG is necessary to enter into a contract with your company or your employer, your failure to provide us with accurate personal information may result in FRG not being able to offer or render recruitment services to you, your company or your employer.

4. The categories of third parties with whom the business shares personal information.

a) All users of the websites and/or our services

i) To third parties where we have retained them to provide services that we or you have requested or that FRG clients have requested including references, qualifications and background reference checking services and to verify the details you have provided from third party sources.

ii) To third parties to provide data storage, CV/resume parsing, data cleansing and marketing (via email & SMS, standard SMS and text rates may apply) services to FRG where such third parties have agreed to maintain the confidentiality of, and to protect, your personal information in accordance with applicable law.

iii) To third parties to assist with credit control and payment management.

iv) To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, in connection with legal proceedings or other similar cause or circumstance.

v) To FRG affiliates, whose locations can be found at https://www.frankgroup.com/contact in order that they may process your personal information in accordance with the Privacy Addendum.

vi) In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets, or a controlling interest in the equity, of FRG (or any of its group companies) provided that such counterparty(ies) to any such transaction agrees to adhere to the terms of the Privacy Addendum (or a similar document) and applicable law.

b) Actual or Prospective Candidates

i) To FRG clients in order for them to determine if you (permanent hire candidate) or your company or employer (contract candidate) are or may be qualified to fill a vacancy.

c) Individuals who work for FRG clients (i.e. a client contact)

i) To candidates in the course of providing your company or employer with recruiting services and to further the recruitment process.

ii) To third parties where we have retained them to provide services that you have requested including candidate skill tests and other testing.

5. The categories of sources from which the personal information is collected.

i) We collect personal information from you actively when you enter it into our services (e.g., your name, your CV/resume, etc.).

ii) We collect personal information passively when you access our services, to the extent your web browser provides this information to our servers (e.g., your operating system) and also based on your service usage (e.g., when and from what IP address you log on to our services).

iii) We collect personal information when it is provided to us by either yourself or a third party (for example, LinkedIn, Jobboard, CV databases, etc.).

6. The business or commercial purpose for collecting or selling personal information.

a) Why do we process your personal information?

i) Generally, we use your personal information for our business and activities, and in our efforts to expand and improve our business. Examples include:

1. All users of the Websites and/or our services

a) To provide our recruitment services to you, your employer or your company;

b) To facilitate the recruitment process, including but not limited to:

i) Qualifying and submitting candidates;

ii) For clients, negotiating FRG terms of business;

iii) Arranging interviews and obtaining feedback;

iv) Negotiating compensation packages; and

v) Providing post placement follow up.

c) To assess data about you against vacancies which we judge may be suitable for you;

d) To third party vendors to assist us in hosting, managing and operating our websites;

e) To third party vendors who provide data analysis and data updating services to us;

i) To third party vendors who provide email and other communications related services to us

f) To enable you to submit your CV/resume to FRG, apply online (including through the Websites) for jobs or to subscribe to alerts about jobs we think may be of interest to you;

g) To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;

h) To improve our customer service and to make our services more valuable to you (including tailoring the Websites when you log on to enrich your personal online experience);

i) To send you electronically or by post surveys, reports, FRG event details, promotions, offers, networking and client events and general information about relevant industry sectors which we think might be of interest to you, where you have consented to being contacted for such purposes (and we will provide you with an opportunity to opt out);

j) To identify you, and respond to and process your requests for information and provide you with a product or service;

k) To amend records to remove personal information;

l) To use your information on an anonymised basis to monitor compliance with our equal opportunities policy, other FRG policies and any legal or compliance requirements;

m) To use your information on an anonymised basis to create marketing materials such as a salary survey; and

n) To carry out our obligations arising from any contracts entered into between you and us, and for other everyday business purposes that involve use of personal information.

2. Actual or Prospective Candidates

a) To help find you or your company a job;

b) To contact you (permanent hire candidates), your employer or your company (contract candidates) about jobs that FRG is filling or may fill for FRG clients;

c) To provide you or your company with information about the job market;

d) To communicate with you (permanent hire candidates), your employer or your company (contract candidates) after you or it has started a job to make sure all is going well or to remedy, or attempt to remedy, any problems;

e) To answer any questions you have about a job or the job market;

f) To fulfill any aspect of your employer’s or your company’s contract with FRG (for contract candidates only);

1. To third party vendors who provide customer relationship management database services to us;

2. To third party vendors who provide data analysis and data updating services to us

3. To third party vendors who provide document execution, transmission and storage services to us

4. To third party vendors who provide email and other communications related services to us

g) To collect any money due, or allegedly due, to FRG or any FRG client (or FRG’s client’s client);

h) To obtain or inquire about any property (including computers and confidential business information) owned, or allegedly owned, by FRG or any FRG client (or FRG’s client’s client);

i) To establish, exercise or defend any legal claims; and

j) To assist you (permanent hire candidates), your employer or your company (contract candidates) if you are dissatisfied or dislike the job, or any aspect of it.

3. Individuals who work for FRG clients (i.e. a “client contact”)

a) To fill an open vacancy at your company or employer;

b) To contact you about candidates for jobs with whom FRG has a relationship;

c) To provide you with information about the job market;

1. To third party vendors who provide customer relationship management database services to us.

2. To third party vendors who provide data analysis and data updating services to us

3. To third party vendors who provide document execution, transmission and storage services to us

4. To third party vendors who provide email and other communications related services to us

d) To communicate with you after your company or employer has hired/retained an FRG candidate to make sure all is going well and to remedy, or attempt to remedy, any problems;

e) To negotiate and fulfil any aspect of your company’s or employer’s contract with FRG;

f) To answer any questions you have about a job or a candidate or your company’s or employer’s contract with FRG;

g) To resolve any issue with the issuance, payment, collection or enforcement of an FRG invoice;

h) To collect any property owned by FRG or any FRG candidate;

i) To establish, exercise or defend any legal claims.

 

7. The specific pieces of personal information it has collected about that consumer.

a) Please email us at  privacy@frankgroup.com, use the interactive webform located here, or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 to request this information. Before we can respond to your request, we’ll need to verify your identity.

8. A description of a consumer’s rights pursuant to CCPA Section 1798.115:

a) If we sell your personal information or disclose it for a business purpose, you have the right to know:

i) The categories of personal information that the business collected about the consumer.

1. See Section VI 4) above (e.g., web log data, registration data, resume/CV data, etc.).

ii) The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.

1. See Sections VI 4), VI 5) and VI 6) above.

iii) The categories of personal information that the business disclosed about the consumer for a business purpose.

1. See Section VI 6) above.

b) If we sell your personal information or disclose it for a business purpose, you have the right to request that we disclose to you (1) the categories of personal information that we collected about you, (2) the categories of personal information we sold about you and the categories of third parties to whom we sold it, by category of personal information for each third party to whom we sold your personal information and (3) the categories of personal information that the business disclosed about the consumer for a business purpose. We are required to verify your identity before providing you with this information if the information would constitute your personal information. To exercise these important rights, please: mail us at privacy@frankgroup.com or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 to request this information. Before we can respond to your request, we’ll need to verify your identity.

c) If we sell your personal information to a third party or disclose it for a business purpose, we are required to disclose:

i) The category or categories of consumers’ personal information we sold, or if we have not sold your personal information, we shall disclose that fact.

1. If we sell your personal information, it will be in the form of your CV/resume, anonymized or pseudonymized.

ii) The category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information for a business purpose, it shall disclose that fact.

1. We rely on vendors to operate our infrastructure, and accordingly for each category of personal information that we disclosed above as a category that we collect, we disclose it to one of our third-party vendors for a business purpose (i.e. to develop, market, provide and support our business services). Those categories are: web log data, registration data, payment data, service usage data, customer content, consumer content and marketing data.

d) If we sell your personal information to a third party, it is not allowed to resell it unless we notified you explicitly and provided you with a chance to opt out.

1. We do not allow third parties to whom we sell your personal information to resell the personal information, so no opt-out choices apply. See frankgroup.com/privacy-notice/#ccpa for details.

9. A description of a consumer’s rights pursuant to CCPA Section 1798.125:

a) Businesses, including us, may not discriminate against you because you exercised any of your consumer privacy rights such as by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including via discounts or other benefits or penalties; (3) providing you a different level or quality of goods or services or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Businesses may however discriminate where any difference is reasonably related to the value provided to you by your data.

b) Businesses, including us, may offer you financial incentives, including payments as compensation, for the collection, sale or deletion of your personal information. If we offer any incentives we will (1) notify you about them in our privacy policy and in any California-specific descriptions of consumer privacy rights we post and (2) only enroll you in them with you opt-in consent after disclosing all material incentive program terms to you. Incentive programs may never be unjust, unreasonable, coercive, or usurious.

i) We do not currently offer any financial incentives.

10. A description of a consumer’s rights pursuant to CCPA Section 1798.105:

a) You have the right to request that we delete any personal information about you that we have collected. Before we delete any information, we’ll need to verify your identity. If we delete your information, we’ll also instruct our vendors (aka service providers) to delete it. The CCPA does not obligate us to delete information under all circumstances, including where we need the information to provide our services to you, to detect security incidents, to identify errors in our services, or to comply with legal obligations. If you request that we delete information, we’ll let you know if we are deleting it or if we are not deleting it based on exemptions provided by the CCPA.

11. One or more designated methods for submitting requests (at minimum, a toll-free telephone number):

a) You may submit any consumer privacy requests by emailing us at privacy@frankgroup.com, use the interactive webform located here, or by calling us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and entering Service Code 717. Before we can respond to your request, we’ll need to verify your identity.