CALIFORNIA WORKFORCE PRIVACY NOTICE
This California Workforce Privacy Notice (“Notice”) supplements Precision Medicine Group’s (PMG) global privacy practices and applies to individuals who are California residents and who work for or seek work with PMG, including employees, interns, job applicants, independent contractors, emergency contacts, temporary workers, and other individuals who interact with PMG in an employment-related capacity (collectively, “Workforce Members”). This Notice explains how PMG collects, uses, discloses, and retains personal information in compliance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (“CCPA”).
Scope:
This Notice applies to PMG’s collection, use, and disclosure of personal information collected in the context of employment and only applies to residents of California.
Business Contact:
For California Workforce Members, the business responsible for your personal information is:
Precision Medicine Group, LLC (“PMG-US”)
2 Bethesda Metro Center, Suite 850
Bethesda, MD 20814
PMG affiliates may support processing for operational, administrative, or technical purposes. Questions may be directed to the PMG Privacy Office using the contact information provided at the end of this Notice.
What personal data do we collect?
In the past twelve months, PMG and its Service Providers (“We”) have collected personal information about Workforce Members. The specific pieces of personal information we collect about you depend on your application or employment status with PMG, and not all types of personal information listed below are collected for all Workforce Members. We may collect the following categories of personal information as defined under the CCPA:
- Identifiers and Contact Information (e.g., name, phone number, address, email address, SSN, employee ID, online identifiers, internet protocol (IP) address, or other similar identifiers)
- Professional or Employment-Related Information (e.g., work history, qualifications, performance records)
- Education information (e.g., academic information and records)
- Financial Information (e.g., salary, payroll, tax data, direct deposit details)
- Internet or Network Activity (e.g., system logs, badge access)
- Geolocation data (limited to device-level location)
- Audio, electronic, visual, or similar information, such as a profile photograph (if self-identified)
- Sensitive Personal Information, including personal information that reveals:
- Social security number, driver’s license, state identification card, or passport number; or
- Account log-in information in combination with any required security or access code, password, or credentials for allowing access to an account;
- Racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; or
- Personal information collected and analyzed concerning an individual’s health, such as information regarding an individual’s medical history, mental or physical condition, or treatment.
In certain circumstances, providing personal information is required by law (for example, under labor and employment laws, tax and social security laws, or other applicable regulations) or is necessary to enter into or perform the employment or engagement relationship.
If required personal information is not provided, PMG may be unable to administer employment, provide compensation or benefits, meet legal or contractual obligations, or otherwise manage workforce operations.
PMG collects and uses personal information only for the business and operational purposes described below.
For what purposes do we process your personal information?
PMG processes Workforce Members’ personal information for business purposes permitted under the CCPA, and other applicable U.S. laws. These purposes include supporting employment administration, payroll and benefits, workplace safety, compliance obligations, HR operations, and the other business purposes described in this Notice.
We process Workforce Members’ personal information for the following purposes:
- To administer the employment relationship, including processing compensation, managing payroll and benefits, supporting timekeeping and scheduling, and carrying out other necessary HR and workforce operations.
- To provide employees with compensation and benefits programs, including salary, incentive programs, healthcare, retirement, wellness, recognition, voluntary employee activities, and other benefits offered by the Employer.
- To carry out recruitment, including internal hiring processes, role placement, verification of qualifications, and onboarding.
- To perform employee appraisals and evaluations, support performance management, and document employee goals, development plans, training completion, and related HR processes.
- To collect and store employee records, including documentation necessary for employment administration, compliance, workforce planning, and operational needs.
- To ensure safe and appropriate working conditions, workplace safety compliance, and proper functioning of equipment and facilities.
- To fulfill the Employer’s obligations under applicable laws, including tax reporting, payroll requirements, equal employment opportunity reporting, benefits administration, leave entitlements, and other statutory workforce obligations.
- To comply with audit, regulatory, and contractual requirements, including internal controls, risk assessments, client audits, regulatory submissions, due diligence reviews, and certifications.
- To administer retirement, pension, health, and welfare plans, as applicable under U.S. and state law.
- To protect PMG systems and data by detecting and preventing cybersecurity threats, unauthorized access, and misuse of corporate resources, consistent with applicable laws
- To enforce PMG policies, support ethics and compliance reporting programs, and investigate potential violations of misconduct.
- To seek and defend against legal claims, including responding to subpoenas, audits, investigations, or disputes.
- To manage complaints, including internal HR complaints, workplace concerns, and compliance-related inquiries.
- To improve the effectiveness of our systems, processes, culture, and operations, including through voluntary employee surveys, workforce analytics, and process improvement initiatives.
- For corporate performance reporting and forecasting, including HR-related analytics, headcount planning, talent planning, trend monitoring, and business budgeting.
- For business development activities, including compiling anonymized or aggregated experience summaries for proposals, capability presentations, and client submissions.
- For employment-related analytics, including performance tracking, resource planning, and workforce optimization.
PMG does not process Sensitive Personal Information for purposes other than those permitted under the CCPA and does not use Sensitive Personal Information to infer characteristics about employees.
How long do we retain your personal information?
PMG retains personal information for the period necessary to support the business, operational, and legal purposes described in this Notice. Retention periods vary depending on the type of personal information and may include:
- Payroll, tax, and benefits records: retained for the period required under applicable federal and state law
- Employment records, including personnel files: retained for the duration of employment plus the period required under applicable law
- Workplace safety, compliance, and investigation records: retained as necessary to comply with legal and regulatory obligations
- Access logs, system logs, and security-related data: retained for reasonable operational and security purposes
- CCTV recordings: retained for a limited period unless needed for an investigation or legal requirement
When personal information is no longer required for these purposes, PMG deletes or de-identifies it in accordance with applicable law and PMG’s internal retention practices.
Do we sell or share your personal information?
PMG does not sell or share (as those terms are defined under the CCPA and CPRA) Workforce Members’ personal information. PMG has not sold or shared Workforce Members’ personal information in the preceding twelve months.
To whom do we disclose your personal information?
PMG discloses Workforce Members’ personal information to third parties when necessary to support employment administration, business operations, workplace safety, compliance obligations, or as required by law. PMG limits such disclosures to the purposes described in this Notice.
PMG may disclose Workforce Members’ personal information to:
- PMG affiliates that provide HR, IT, payroll, benefits, compliance, or operational support
- Service providers and contractors that support PMG’s business operations, including HR systems, payroll processors, benefits administrators, travel and expense platforms, IT support, cybersecurity vendors, training providers, and auditors
- Clients, where necessary to verify employee qualifications or meet project or contractual requirements
- Government authorities, when required for tax reporting, wage and hour compliance, benefits administration, workplace safety, or other legal obligations
- Courts, regulators, or law enforcement when responding to subpoenas, legal claims, investigations, or audits
- Financial institutions, when necessary for payroll, tax, or legally required reporting
- Professional advisors, such as legal counsel, auditors, and tax advisors
- Insurance carriers and benefit plan administrators, when required to manage health, welfare, and retirement benefits
- Internal compliance, ethics, or investigation teams, when needed to address complaints, workplace concerns, or potential violations
Where do we get your personal information?
PMG obtains most Workforce Members’ personal information directly from Workforce Members, including personal information about beneficiaries or dependents, or through information generated during the employment relationship. PMG may also receive personal information from temporary employment agencies, background check providers, payroll or benefits administrators, IT service providers, clients (for project or access verification), government agencies, or courts or law enforcement when required by law.
What are your rights in connection with our processing of your personal information?
Workforce Members in California have specific rights under the CCPA. These rights apply to the personal information that PMG collects, uses, or discloses in the context of employment or engagement with PMG. You have the right to:
- Request access to your personal information, including the categories of personal information collected, the sources from which it was collected, the purposes for which it is collected and used, the categories of third parties with whom it is disclosed, the categories of information that is sold or shared to third parties, and the specific pieces of personal information PMG maintains about you.
- Request correction of inaccurate personal information maintained by PMG.
- Request deletion of personal information, subject to exceptions under California law that may require PMG to retain certain data for legal, compliance, or operational purposes.
- Request to limit the use and disclosure of Sensitive Personal Information, where PMG uses such information beyond purposes permitted under the CPRA. (Note: PMG does not use Sensitive Personal Information to infer characteristics about employees.)
- Be free from retaliation for exercising any of the rights described in this Notice. PMG will not discriminate against you for exercising your rights under CCPA.
- Receive an explanation if PMG denies a request in whole or in part, including the legal or operational basis for the decision.
- Request to opt out of the sale or sharing of personal information, although PMG does not sell or share personal information as these terms are defined by the CCPA.
You may submit data rights requests or privacy-related questions by contacting the PMG Privacy Office. You may also authorize an agent to make a request on your behalf. In such instances, authorized agents may use the same methods as you to submit the request on your behalf. When you submit a request, please indicate the type of request you are making, so that we may properly process and respond to your request in accordance with applicable law.
Email: privacy@precisionmedicinegrp.com
Address: PMG Privacy Office
2 Bethesda Metro Center Suite 850
Bethesda, MD 20814
Depending on the type of request you submit, PMG may verify your identity before responding, as required or permitted under California Law. Verification is not required for certain requests, such as requests to opt out of the sale or sharing of personal information or to limit the use of Sensitive Personal Information. PMG will explain any applicable verification requirements when a request is submitted.
Other Disclosures
Disclosures about Direct Marketing for California Residents. California Civil Code §1798.83 permits California residents to annually request certain information regarding our disclosure of personal information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute Workforce Members’ personal information to other entities for their own direct marketing purposes.
Financial Incentives. Under California law, we do not provide financial incentives to California Workforce Members who allow us to collect, use, sell, or share their personal information. We will describe such programs to you if and when we offer them to you.
Changes to this Notice. We reserve the right to amend this Notice at our discretion and at any time. When we make material changes to this Notice, we will notify you by posting an updated Notice on our website and listing the effective date of such updates.
Last Updated Date: February 13, 2026