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California Privacy Policy

MedSpeed Privacy Policy and Notice at Collection
Revision Date: 11/16/2023

MedSpeed (or “Company”) values your privacy and is committed to protecting your personal information in compliance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). This Privacy Policy explains how we collect and use your personal information.

California Notice at Collection
MedSpeed collects the personal information identified in the “Collection and Use of Personal Information” section for the purposes identified in that section and retains it for the period described in the “Retention of Personal Information” section. 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. To the extent you provide MedSpeed with personal information about your dependents, spouse, beneficiaries, or emergency contacts, you are responsible for providing this notice to them.

MedSpeed’s Protective Measures
MedSpeed maintains measures to protect your personal information, including protecting your personal information against unauthorized access, maintaining the confidentiality, integrity, and availability of your personal information, and training personnel on information security requirements.
MedSpeed has a limited number of authorized employees who have visibility of your personal information. Your information will not be accessible to those outside of direct management and Human Resources.

Assistance for the Disabled
Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact [email protected] for assistance.

Scope
This Privacy Policy informs employees about the categories of personal information MedSpeed has collected about you in the preceding twelve months as well as the categories of personal information that MedSpeed will collect about you in the future. 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 employee.
Personal information does not include:
• Publicly available information from government records.
• De-identified or aggregated information.
• Information excluded from the CCPA’s scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Collection and Use of Personal Information
MedSpeed collects the following personal information for the purposes listed below.

Additionally, MedSpeed will use your personal information for the following general purposes:

  • To administer the employment relationship, for example, human resources administration, payroll processing, benefits administration, leave programs, corporate travel and other business expenses, timekeeping, managing work supplies, grievance or disciplinary matters, diversity and inclusion, ascertaining your fitness to work, drug and alcohol screening, worker’s compensation administration, occupational health surveillance, direct threat analysis, and facilitating employee communication and collaboration.
  • To manage your performance as an employee, for example, talent management, periodic reviews, performance tracking, promotions, retention, discipline, education, training and development, and data analytics.
  • Protecting the rights or property of MedSpeed, including, but not limited to, detecting and prevent fraud or other types of wrongdoing, managing litigation involving MedSpeed, and other legal disputes and inquiries, crisis management, dispute resolution, reporting suspected criminal conduct to law enforcement and cooperating in investigations, short-term transient use of personal information, responding to requests or orders from governmental agencies, exercising MedSpeed’s rights under applicable law, and supporting any claim, defense, or declaration involving the MedSpeed in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.

Note on Inferring Characteristics

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

Sources of Personal Information
We collect personal information through the use of online platforms. The information is sourced directly from applicants and employees during the job application and onboarding processes. We may also collect personal information from the following sources:

    • Vendors and service providers, for example, background check vendors.
    • Affiliated companies, for example, clients of MedSpeed.
    • Third parties, for example, job references, business partners, professional employer organizations or staffing agencies, insurance companies.
    • Automated technologies on MedSpeed’s electronic resources, for example, to track logins and activity across MedSpeed’s network.
    • Surveillance/recording technologies installed by MedSpeed, for example, video surveillance in common areas of MedSpeed facilities, global positioning system (“GPS”) technologies, voicemail technologies, and audio recording technologies, any of these with consent to the extent required by law.
    • Government or administrative agencies, for example, law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department.
    • Acquired company, if MedSpeed acquired your employer, MedSpeed might collect personal information from that employer

    Disclosure of Personal Information
    Disclosure for Business Purposes
    MedSpeed generally maintains personal information related to employees as confidential. However, from time to time, MedSpeed may have a legitimate business need to disclose personal information. In that event, we disclose information within the categories of personal information listed 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 MedSpeed may disclose each of the categories of personal information listed above to the following categories of third parties for the following “business purposes”, as that term is defined under the CPRA:

    • Service providers and vendors: MedSpeed may disclose to service providers any of the categories of personal information listed above for the business purpose of performing services on MedSpeed’s behalf and, in particular, for the specific purposes described above.
    • Auditors, lawyers, consultants, and accountants engaged by MedSpeed: MedSpeed may disclose the categories of personal information listed above to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the MedSpeed’s behalf.
    • Affiliated companies: MedSpeed may disclose any of the categories of personal information listed above to other companies for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.


    Selling and Sharing of Personal Information

    MedSpeed does not sell or “share” (disclose to a third party for cross-context behavioral advertising) any of the personal information outlined above. In addition, we have no actual knowledge that we sell or share the personal information of individuals of any age in connection with the employment relationship, including the personal information of children under 16.


    Disclosures to Others
    MedSpeed may disclose personal information to the following additional categories of third parties although these disclosures may be for purposes 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.
    • Clients: This may include, for example, disclosing a sales representative’s contact information to clients.
    • Business partners: For example, MedSpeed might disclose your business contact information to a co-developer of a new product or service with which you will be working.
    • Government or administrative agencies: These may include, for example the Internal Revenue Service to pay taxes or the California Department of Industrial Relations as required to resolve workers’ compensation claims.
    • Public: MedSpeed may disclose your personal information to the public as part of a press release, for example, to announce promotions or awards. If you do not want your personal information in press releases, please contact [email protected] MedSpeed does not disclose sensitive personal information to the public.
    • Required Disclosures: We may be required to disclose personal information (a) in a court proceeding, (b) in response to a court order, subpoena, civil discovery request, other legal process, or (c) 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 MedSpeed, employees, or others.


    Retention of Personal Information
    MedSpeed will retain your personal information for the duration of your employment and for the period necessary to meet our legal obligations. MedSpeed will keep your personal information no longer than necessary for the purposes described above unless we are required to retain your personal information longer by applicable law or regulation, by administrative needs, by legal process, or to exercise or defend legal claims. The information is stored securely in the Company’s applicant tracking software and employee platform, which is protected by a multifactor authentication process.


    Your Rights
    The CCPA provides California residents with specific rights regarding their personal information. The sections below describe your CCPA rights and explain how to exercise those rights.


    Requests to Know
    You have the right to request that we disclose certain information to you about our collection and use of your personal information, as well as specific pieces of personal information, up to twice in a 12-month period. Please note that the CCPA’s right to obtain specific pieces of information does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information. Moreover, employees have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients.


    Requests to Delete
    You have the right to request that we delete your personal information that we collected from you and retained, subject to certain exceptions. For a list of these exceptions, please contact Human Resources.
    Upon receipt of a request, we will delete your personal information from our records, unless an exception applies. We will also notify any service providers or contractors to delete your personal information from their records. We may deny your deletion request if retaining the information is required by law or if another exception applies.


    Requests to Correct
    You have to right to request that MedSpeed correct any inaccurate information that the Company has on file, taking into account the nature of the personal information and the purposes of processing the personal information.

    Exercising Your Rights
    To exercise the rights to know, delete, and correct described above, please submit a verifiable request to us by either:

    • Contacting HR MedSpeed by phone at 866-901-4201.
    • Submitting a Contact Us request at medspeed.com
    • Emailing [email protected].
    • Submitting a written request for information to your local management team.


    You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another 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.

    In the alternative, you can provide a power of attorney compliant with the California Probate Code.
    The request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    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. MedSpeed cannot respond to your request or provide you with personal information if we cannot verify your identity, or authority to make the request and confirm the personal information relates to you. 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. MedSpeed will only use personal information provided in a verifiable request to verify the requestor’s identity.


    Responding to Requests
    MedSpeed will respond to verified requests within 45 days of receiving them. If additional time is needed to fulfill the request, Human Resources will inform you of such in writing, via email. The response will also explain the reasons MedSpeed cannot comply with a request, if applicable. We will not charge a fee to process or respond to your verifiable request.


    Non-Discrimination
    MedSpeed will not discriminate against you for exercising any of your CCPA rights.


    Changes to Our Privacy Policy
    MedSpeed reserves the right to amend this privacy policy at the Company’s discretion at any time. When changes are made to this privacy notice, you will be notified by email or through a notice on our employee platform, MedConnectHR.

    Contact Information
    If you have any questions or concerns regarding how your personal information is used, please contact Human Resources via email at [email protected].