California Applicant Privacy Notice

Last Updated: April 2024

Path CCM, Inc. d/b/a Rula Health (“Rula”) takes your privacy seriously.  SUD Specialty Group – CA, Mental Health Specialty Group, P.A., Mental Health Specialty Group NJ, PC, and Mental Health Specialty Group KS, P.A. (collectively, “Group”) contracts with Rula for management and administrative support services.  Each entity within the Group and Rula are referenced herein, collectively, as “Company”.  We want you to know how we collect, use, and disclose, your personal information.  

California Notice at Collection:  The Companies collect the personal information identified in Section 1 for the purposes identified in Section 3 and retains it for the period described in Section 5. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”).  We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you. 

EEO Statement
Company is an equal employment opportunity employer.  Company’s policy is not to unlawfully discriminate against any applicant or employee on the basis of race, color, sex, religion, national origin, age, disability, or any other consideration made unlawful by applicable federal, state, or local laws.  Company also prohibits harassment of applicants and employees based on any protected category, characteristic or status. It is also Company’s policy to comply with all applicable state, federal and local laws respecting consideration of unemployment status in making hiring decisions.

Company complies with the ADA, the ADAAA and applicable state law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job. Hire may be contingent upon a post-offer medical examination, and to skill and agility tests, as appropriate for the position.

This Privacy Policy explains: 

1. The categories of personal information we collect about you
2. The categories of sources from which we collect your personal information
3. The purposes for which we use your personal information  
4. How we may disclose your personal information
5. How long we keep your personal information
6. Changes to this Privacy Policy 

Scope:

This Privacy Policy applies to the personal information of California residents in their capacity as applicants for either employment by or independent contractor work with the Company (“Applicants”). 

Except where the Privacy Policy specifically refers only to a specific category of Applicants, e.g., employee applicants, this Privacy Policy refers to all categories of Applicants collectively. 

“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 Applicant.

“Personal information” does not include:

• Information publicly available from government records or made publicly available by you or with your permission;
• Deidentified or aggregated information;
• Information excluded from the CPRA’s scope, such as:
  • Protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”) or the Health Information Technology for Economic and Clinical Health Act (“HITECH”) or medical information covered by California Confidentiality of Medical Information Act (“CMIA”); or
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“FIPA”).

1.  THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect the following categories of personal information. Not all categories may be collected about every Applicant. 

• Identifiers, for example: real name, nickname, telephone number, postal address, social security number, date of birth, e-mail address, and signature. 
• Professional or Employment-Related Information, for example: payroll information, educational institutions attended, degrees and certifications, licenses, work experience and previous employers, work eligibility and visa sponsorship requirements, and professional memberships and affiliations.
• Commercial Information, for example: travel expense records for an interview.   
• Internet or Other Electronic Activity Information, for example: interactions with Company’s Internet web site, application, or advertisement, and publicly available social media activity.
• Sensory or Surveillance Data, for example: voice-mails.
• § 1798.80: personal information described under Cal. Civ. Code § 1798.80 to the extent not already included in other categories in this section, such as a photograph or health information.
• Other details, for example, personal pronouns, emergency contact, hobbies and leisure activities or membership in voluntary/charitable/public organizations, for example, as stated on the Applicant’s resume.
• Inferences, for example, Company might infer characteristics from a personality assessment completed by the Applicant. 
• Characteristics of Protected Classifications Under California or Federal Law for Applicants, collected on a purely voluntary basis, except where collection is required by law, and used only in compliance with applicable laws and regulations, for diversity and inclusion reporting and related purposes.

Note on inferring characteristics: Company does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the Applicant.

2.  THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

We may collect the following categories of personal information. Not all categories apply to every Applicant. 

• You, for example, in your application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
• Vendors and service providers, for example, recruiters.
• Third parties, for example, references, affiliated companies, professional employer organizations or staffing agencies, publicly available social media activity.
• Automated technologies on Company’s electronic resources, for example, to track logins and activity on Company’s careers page.
• Government or administrative agencies, for example, law enforcement or public health authorities.  

3.  THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We may use the personal information we collect for one or more of the following purposes:

A. Generally Applicable Purposes

Unless stated otherwise in section 3.B, below, we may use Applicants’ personal information for the following purposes:

Recruiting, including:

• To evaluate Applicants’ qualifications or suitability for employment with Company
• To verify the identity and employment authorization of individuals hired for employment
• To communicate with Applicants
• To conduct a pre-employment or criminal history background check
• For identification purposes
• For diversity and inclusion purposes
• To arrange and manage Company-sponsored events
• To create a talent pool for future openings
• To demonstrate Applicants’ agreement to, or acceptance of, documents presented to them, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
• To evaluate and improve the recruiting process
• To promote Company as a place to work

Monitoring, Security, and Compliance, including:

• To monitor and protect Company facilities and information systems 
• To ensure compliance with applicable laws and Company policies
• To administer Company’s whistleblower hotline  
• To report suspected criminal conduct to law enforcement and cooperate in investigations
• To exercise Company’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

Conducting Our Business, including:

• For training purposes or quality assurance with respect to Company employees conducting the interviews or otherwise assisting with the recruiting and hiring process
• For travel and event planning
• To engage in crisis management
• To manage travel reimbursements

Miscellaneous Other Purposes: 

• To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
• To manage litigation involving Company, 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 Company or any of its subsidiaries or affiliates; and  
• To protect the rights, property, or safety of Company, Applicants, customers or others.

B. Purposes Specific To Certain Categories Of Personal Information:

We may use the categories of Applicants’ personal information listed in this Section 3.B for the purposes stated below:  

Purposes For Using Applicant Health Information: 

• To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities
• 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:

Company collects information about race, 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 Office of Federal Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act, and for purposes of diversity analytics.  

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

Company collects protected categories of personal information on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.

C. Deidentified Information

At times, Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”).  Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that Company 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. 

4.  HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION 

Company generally maintains personal information related to Applicants as confidential.  However, from time to time, Company may have a legitimate business need to disclose Applicants’ personal information.  In that event, Company discloses your personal information listed in Section 1, above, only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CPRA and other applicable laws.

Company may disclose personal information to the following additional categories of third parties although these disclosures may be for purposes in Section 3, above, other than a business or commercial purpose as defined by the CPRA:

• Your direction: We may disclose your personal information to third parties at your direction.
• Affiliated companies: Other companies within the Group, for example, to evaluate an applicant for a cross-enterprise team. 
• Government or administrative agencies: These may include, for example, the Equal Employment Opportunity Commission as required for reporting. 
• Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law. 
• Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, Applicants, or others. 

5.  HOW LONG WE KEEP YOUR PERSONAL INFORMATION

If Company hires you, the information collected about you during the 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.  Company will retain this application information for the entire duration of your employment relationship with Company and for as long thereafter as permitted or required by applicable law.  Company makes its document retention schedule available to hired employees and contractors for review upon request to privacy@rula.com.

We will retain information of applicants who are not hired in accordance with our established data retention schedule. In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations. These records will be retained for our internal recordkeeping and reporting purposes in compliance with California Government Code § 12946.  During that time, we may use your information to consider you for positions in addition to the position(s) for which you initially applied.

Company may retain personal information longer than described above if required by law, for example, for a litigation hold.

6.  CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. 

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact us at privacy@rula.com.