Effective Date: January 1, 2023

Gelfand, Rennert & Feldman LLC (“GRF” or the “Firm”) respects, and is committed to protecting, the privacy and security of all Personal Information provided to us by job applicants and that we collect about them.

This Job Applicant Privacy Policy (“Policy”) outlines the following:

• the types of Personal Information the Firm might collect, use, or disclose about you;
• the reasons for collecting, using, or disclosing your Personal Information;
• the duration for which your Personal Information is maintained;
• your options for how we use your Personal Information;
• how we protect your Personal Information; and
• your rights if you are a California resident;
• how to get in touch with us to exercise your rights or learn more about our privacy practices.

EEO Statement

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

GRF 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.

Assistance For The Disabled

Alternative formats of this Policy are available to individuals with a disability. Please contact HRSupport@grfllp.com for assistance.

Personal Information Collected

The Firm collects, and has collected in the past twelve months, the following categories of Personal Information for the purposes described below, in accordance with applicable law. “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.

Note on inferring characteristics:

GRF does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the applicant.

Sources of Personal Information Collected

The Firm collects Personal Information that you voluntarily give us when you apply for a job or otherwise get in touch with us in the context of recruitment.

The Firm may combine the Personal Information you voluntarily provide to us with the Personal Information obtained from other sources, such as:

• Services providers, for example, recruiters
• Third parties, for example, prior employers (e.g., for references), professional business references you provide to us, educational institutions, and pre-employment screening services
• Public records, for example, credentialing and licensing organizations
• Publicly available sources, such as your social media profile (e.g., LinkedIn, Twitter, and Facebook)
• Surveillance/recording technologies installed by GRF, for example, video surveillance in common areas of GRF’s offices, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law.
• Other sources as directed by you

How We Use Your Personal Information

The Firm uses the categories of Personal Information listed above for the following purposes:

• Process and manage your application: The Firm utilizes your Personal Information to process job applications, create applicant profiles for open positions, determine your suitability for a particular position with us and arrange and conduct interviews. We may collect audio and visual information of job applicants for identification purposes. With your consent, we may record video of you in connection with the application process. Additionally, if you are hired by us, we may use your Personal Information in the employee onboarding process.
• Provide immigration support: If applicable, we may collect your Personal Information to assist with immigration support, such as applying for visas or work permits as permitted by applicable law.
• Meeting legal requirements and enforcing legal terms: To comply with any applicable law, regulation, court order, or other legal process, the Firm must collect and use your Personal Information for specific purposes. These include preventing, detecting, and investigating security incidents and potentially unlawful or prohibited activities; defending the rights, property, or safety of you, us, or another party; verifying employment eligibility; enforcing any agreements with you; responding to claims; and settling disagreements. Additionally, we may use information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.

Record Retention

The Firm maintains your Personal Information in compliance with our record retention policies and as mandated by law. Application materials from hired candidates will be kept in the employee’s personnel file. The Firm will retain Personal Information of applicants who are not hired for four (4) years after the record is collected. 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 Personal Information to consider you for positions in addition to the position(s) for which you initially applied.

Disclosure of Personal Information

A. Disclosures for Business Purposes

The Firm may disclose each of the categories of personal information listed in the “Personal Information Collected” section, above, to the third parties listed below for the following “business purposes” as that term is defined under the California Privacy Rights Act (“CPRA”).

• Service Providers: Our hiring and recruitment process is run, hosted, and facilitated by service providers. These include recruiters, hiring process management tools, security and fraud prevention consultants, analytics providers, hosting, technology, and communication providers. The Firm discloses the categories of personal information listed in the “Personal Information Collected” section, above, to these services providers for the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in the “How We May Use Your Personal Information” section, above.
• Auditors, lawyers, consultants, and accountants engaged by Company: Company may disclose the categories of personal information listed in the “Personal Information Collected” section, above, to these service providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.

B. Disclosures To Others

For the purposes outlined in this Policy, the Firm may disclose, and/or during the past 12 months has disclosed, your Personal Information as needed to the following categories of external recipients:

• Government authorities and law enforcement: We might need to turn over Personal Information to respond to valid requests from government agencies, like those relating to maintaining the country’s security or enforcing the law.
• Business transfers: If the event of a merger, acquisition, bankruptcy, or other transaction where that third party takes over control of our Firm, your Personal Information might be transferred (in whole or in part) to that third party
• Legal advisors: Your Personal Information might be disclosed to our legal counsel.
• 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 the Firm, our clients, or others.
• Your direction: We may disclose your Personal Information to third parties at your direction.

GRF does not, and will not, sell or otherwise disclose your Personal Information to third parties for monetary or other consideration. GRF also does not share Personal Information for cross-context behavioral advertising. In addition, we have no actual knowledge that we sell or share the personal information of individuals of any age in connection with the application process, including the personal information of children under 16.

California Notice at Collection: The Firm collects the Personal Information identified in the “Personal Information Collected” section above for the purposes identified in the “How We Use Your Personal Information” section and retains it for the period described in the “Record Retention” section above. The Firm does not sell your Personal Information or disclose it for cross-context behavioral advertising. The Firm also does not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Your Rights as a California Resident

Subject to applicable law, California residents have the right to submit certain requests relating to their Personal Information as described below.

Right to Know:

You have the right to submit a verifiable request that we disclose the information to you about our collection and use of your Personal Information, including the following:

• The categories of Personal Information we collected about you
• The categories of sources for the Personal Information we collected about you
• Our business or commercial purpose for collecting that Personal Information
• The categories of third parties with whom we disclose that Personal Information
• The specific pieces of Personal Information we collected from or about you

You may also submit a verifiable request to know the specific pieces of Personal Information that we collected from or about you.

Right to Delete:

You have the right to submit a verifiable request for the deletion of Personal Information that you have provided to the Firm.

Right to Correct:

You have the right to submit a verifiable request for the correction of inaccurate Personal Information maintained by the Firm, considering the nature of the Personal Information and the purposes of processing the Personal Information.

Non-Discrimination:

We will not discriminate or retaliate against you for exercising any of your rights under the California Privacy Rights Act.

How to Exercise Your Rights:

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

• Call 833-479-0336 or
• Complete the request form available here: https://www.grfllp.com/privacy-policy-california/#scriptInit

How We Will Verify Your Request:

We match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

Authorized Agents:

If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request a 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. You can obtain the “Authorized Agent Designation” form by contacting us at privacy@grfllp.com

Changes To This Policy

The Firm reserves the right to update this Job Applicant Privacy Policy at any time. If we change this Policy, we will post those changes on this page and update the Job Applicant Privacy Policy modification date above. If we materially change this Policy in a way that affects how we use or disclose your Personal Information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

Contact Information:

If you have any questions or comments about this notice, please do not hesitate to contact us at:
Phone: 833-479-0336
Website: www.grfllp.com
Postal Address:
Privacy and Information Security Office
Gelfand, Rennert & Feldman, LLC
1880 Century Park East, #1600
Los Angeles, CA 90067