Employee & Applicant Privacy Policy

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), Cal. Civ. Code § 1798.100 et seq.
Applies to ACE Consulting Company, Inc. employees, job applicants, and independent contractors who are California residents. This policy does not address personal information ACE collects from customers or website visitors.

1. Introduction

ACE Consulting Company, Inc. (“ACE,” “we,” “our,” or “us”) respects the privacy of our employees, job applicants, and contractors. This Employee & Applicant Privacy Policy (“Policy”) describes how we collect, use, disclose, and protect personal information in the employment context, and explains the rights available to California residents under the CCPA and CPRA. This Policy supplements, and should be read together with, the CCPA/CPRA Notice at Collection provided to you at the time your information is collected.

2. Personal Information We Collect

In the preceding 12 months, and on an ongoing basis, ACE has collected the following categories of personal information from and about employees, applicants, and contractors:

• Identifiers: name, address, phone number, email address, Social Security number, driver's license number, and BSIS security guard card number.
• Employment and education history: prior employment, job title, performance information, education records, and professional licenses or certifications.
• Background check and investigative information: criminal history (Live Scan/DOJ and FBI results), and federal background investigation results (including e-QIP submissions) where required for a specific position.
• Government identification and credentialing information: information required for VA personnel security clearance and PIV credentialing, including fingerprints.
• Financial and tax information: wage rate, fringe benefit elections, direct deposit information, and tax withholding elections.
• Protected classification and accommodation information: information you voluntarily provide regarding disability, pregnancy, religious accommodation, or other protected characteristics in connection with a request for accommodation or leave.
• Sensitive personal information: Social Security number, driver's license number, precise geolocation is not collected, and criminal background check results, each as defined under the CPRA (see Section 6 below regarding your right to limit use of this information).

3. Sources of Personal Information

ACE collects personal information from the following sources:

• Directly from you (applications, forms, and documents you submit)
• Background check and Live Scan vendors, acting on ACE's behalf
• Government agencies, including the California Department of Justice, the FBI, and the U.S. Department of Veterans Affairs (in connection with personnel security and facility access requirements)
• Prior employers and references you provide
• ACE's payroll and benefits administration vendors

4. How ACE Uses Personal Information

ACE uses personal information for the following business purposes:

• Administering employment, payroll, benefits, and licensing (including BSIS security guard licensing)
• Complying with federal contract requirements, including background investigations, PIV credentialing, and Service Contract Act wage/fringe compliance
• Workplace safety and security
• Complying with applicable federal, state, and local law
• Evaluating and responding to accommodation or leave requests

5. Disclosure of Personal Information

ACE does not sell or share (as those terms are defined under the CCPA/CPRA) personal information for cross-contextual behavioral advertising or any other purpose.

ACE discloses personal information to the following categories of service providers and government entities for the business purposes described in Section 4: background check and Live Scan vendors; payroll and benefits administration vendors; the U.S. Department of Veterans Affairs and other federal agencies, where required for facility access, security clearance, or contract compliance; and the California Bureau of Security and Investigative Services, where required for guard card licensing. These disclosures are made under written contracts that restrict the recipient's use of the information to the purposes for which it was disclosed.

6. Your Privacy Rights

If you are a California resident, you have the following rights with respect to your personal information, subject to certain exceptions under the CCPA/CPRA:

Right to Know

You may request that ACE disclose the categories and specific pieces of personal information ACE has collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties to whom it has been disclosed.

Right to Delete

You may request that ACE delete personal information collected from you, subject to exceptions such as ACE's need to retain information to comply with a legal obligation (including federal contract recordkeeping requirements) or to complete a transaction for which the information was collected.

Right to Correct

You may request that ACE correct inaccurate personal information ACE maintains about you.

Right to Limit Use of Sensitive Personal Information

You may request that ACE limit its use of your sensitive personal information (such as your Social Security number or background check results) to that which is necessary to perform the services or provide the benefits reasonably expected by an average employee in your position, or as otherwise permitted by law. ACE currently uses sensitive personal information only for such necessary purposes.

Right to Opt-Out of Sale or Sharing

ACE does not sell or share personal information, so there is no sale or sharing to opt out of.

Right to Non-Discrimination

ACE will not discriminate or retaliate against you for exercising any of these rights.

7. How to Submit a Request

You may submit a request to know, delete, correct, or limit the use of sensitive personal information by contacting Rachel Clemons, HR Director, at (859) 305-0895 or rclemons@ace-consulting.net.

ACE will verify your identity before responding to a request, generally by matching the information you provide against information already in ACE's personnel records. You may designate an authorized agent to submit a request on your behalf by providing ACE with written authorization signed by you; ACE may also require you to separately verify your own identity directly with ACE.

ACE will confirm receipt of your request within 10 business days and will respond substantively within 45 calendar days of receipt. This period may be extended once by an additional 45 days when reasonably necessary, in which case ACE will notify you of the extension and the reason for it.

8. Appeals

If ACE denies your request in whole or in part, you may appeal that decision by writing to Rachel Clemons, HR Director, at the contact information above within 30 days of ACE's response. ACE will respond to your appeal within 60 days. If your appeal is denied, you may file a complaint with the California Privacy Protection Agency (CPPA) at cppa.ca.gov.

9. Data Retention

ACE retains personal information only as long as reasonably necessary for the purposes described in this Policy. Because different categories of records are subject to different legal retention requirements, ACE applies the following retention periods rather than a single retention period for all personal information:

• General personnel records (applications, employment history, accommodation requests): 4 years from creation, or 4 years after termination or non-hire, whichever is later (Cal. Gov. Code § 12946).
• Payroll and wage records: 4 years, consistent with California's wage-claim statute of limitations (Cal. Labor Code § 226 sets a 3-year floor).
• Form I-9: 3 years after hire, or 1 year after termination, whichever is later — retained separately from other personnel records, per federal requirements.
• Sexual harassment prevention training records: 2 years.
• Employee Exposure and Medical Records (as described in ACE's OSHA-required notice): duration of employment plus 30 years (8 CCR § 3204).
• Service Contract Act wage/fringe compliance records: 3 years from completion of the applicable federal contract (29 CFR § 4.6(g)).

If ACE receives notice that a complaint has been filed regarding an employee or applicant under the Fair Employment and Housing Act, ACE will retain all records and files related to that individual until the later of the expiration of the applicable statute of limitations or final resolution of the complaint, notwithstanding the periods listed above.

10. Changes to This Policy

ACE may update this Policy from time to time. The “Last Updated” date above reflects the most recent revision. Material changes will be communicated to current employees.

11. Contact Us

Questions about this Policy may be directed to Rachel Clemons, HR Director, (859) 305-0895, rclemons@ace-consulting.net.