California Job Applicant Privacy Notice

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Effective Date: January 1, 2024

New California Job Applicant Privacy Notice (“Job Applicant Notice”)

This Job Applicant Notice describes how Squire Patton Boggs (“Firm,” “we,” “us,” or “our”) processes personal information (“PI”) of California job applicants in the human resources (“HR”) context. This Job Applicant Notice is designed to meet obligations under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). In the event of a conflict between any other Firm policy, statement, or notice and this Job Applicant Notice, this Job Applicant Notice will prevail as to California job applicants, unless stated otherwise. Capitalized terms used but not defined in this Job Applicant Notice shall have the meanings given to them under the CCPA.

Section 1 of this Job Applicant Notice provides notice of our data practices, including our collection, use, retention, and disclosure of job applicant PI. Sections 2-5 of this Job Applicant Notice provide information regarding California job applicant rights under the CCPA and how you may exercise them.

Non-Applicability: This Job Applicant Notice does not apply to our consumer facing website(s), which are addressed in our general privacy notice available here, except when you submit a job application to us. It also does not apply to our current or former employees or independent contractors, which are addressed in our California Personnel Privacy Notice available from our Human Resources Department.

TABLE OF CONTENTS

1. Notice of Data Practices
   (a) PI Sources and Use
   (b) PI Collection, Disclosure, and Retention - By Category of PI
2. Your Rights and How to Exercise Them
3. Non-Discrimination / No Retaliation
4. Notice of Financial Incentive Programs
5. Our Rights and the Rights of Others
6. Contact Us

1. NOTICE OF DATA PRACTICES

The description of our data practices in this Job Applicant Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates, however, if materially different from this Job Applicant Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Job Applicant Notice serves as our notice at collection.

(a) PI Sources and Use

We may collect your PI directly from you, such as when you apply for a position or become employed or engaged by us (e.g., identification/identity data, contact details, educational and employment data), over the phone or through paper documents such as applications for employment and consents to perform employment screening, in our notes or records we create about you, from others through interactions in the course of employment or engagement, from third parties (e.g., references and recruiters), or from public sources of data.

Generally we use job applicant PI for HR Business Purposes and as otherwise related to the operation of our business, including for: Performing Services; Security; Debugging; Advertising & Marketing; Analytics; and Research and Development. For example, we use job applicant PI for the following purposes:

• Communicating with job applicants
• Processing job applications
• Employment eligibility screening
• Accommodation requests
• Recruitment
• Maintaining job applicant records
• Facilitating diversity and inclusion programs
• HR IT systems and security
• Security (including electronic and of premises)
• Auditing, investigations, and compliance

We may also use PI for “Additional Business Purposes” in a context that is not a Sale or Share under the CCPA, such as:

• Disclosing it to our Service Providers, Contractors, or Processors that perform services for us (“Vendors”);
• Disclosing it to you or to other parties at your direction or through your action (e.g., payroll processors, benefits providers, some software platform operators, etc.);
• For the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice);
• As required or permitted by applicable law;
• To the government or private parties to comply with law or legal process or protect or enforce legal rights or obligations or prevent harm;
• Where we believe we need to in order to investigate, prevent or take action if we think someone might be using information for illegal activities, fraud, or in ways that may threaten someone’s safety or violate our policies or legal obligations; and
• To assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”).

Subject to restrictions and obligations under the CCPA, our Vendors may also use your PI for Business Purposes and Additional Business Purposes, and may engage their own vendors to enable them to perform services for us.

(b) PI Collection, Disclosure, and Retention - By Category of PI

We collect, disclose, and retain PI as follows:

There may be additional information we collect that meets the definition of PI under the CCPA but is not reflected by a category above, in which case we will treat it as PI as required, but will not include it when we describe our practices by PI category.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We will not attempt to reidentify data that we maintain as deidentified.

Retention of PI: Because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We retain specific PI pieces based on how long we have a legitimate purpose for the retention, including as mandated by applicable laws.

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2. YOUR RIGHTS AND HOW TO EXERCISE THEM

California job applicants have the same rights to know/access, delete, correct, limit, and opt-out as traditional Consumers and may learn more about these rights and how to exercise them in Section 2 of our U.S. State Privacy Notice here.

Right to Limit Use and Disclosure of Sensitive PI

With regard to PI that qualifies as Sensitive PI under U.S. Privacy Laws, as of January 1, 2023, if you elect to provide us with that Sensitive PI, you will have consented to such Processing. However, you can limit certain types of Sensitive PI Processing by following the instructions in the How to Exercise Your Consumer Privacy Rights section of our U.S. State Privacy Notice.

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3. NON-DISCRIMINATION / NO RETALIATION

We will not discriminate or retaliate against you in a manner prohibited by the CCPA for your exercise of your privacy rights.

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4. NOTICE OF FINANCIAL INCENTIVE PROGRAMS

We do not offer programs requiring you to limit any of your Consumer rights, or otherwise require you to limit your Consumer rights in connection with charging a different price or rate, or offering a different level or quality of good or service, or that would otherwise be considered a financial incentive related to the collection of PI.

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5. OUR RIGHTS AND THE RIGHTS OF OTHERS

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your rights under the CCPA. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.

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6. CONTACT US

For general questions about this Job Applicant Notice, you may contact us as follows:

Office of General Counsel - Privacy
Squire Patton Boggs
1000 Key Tower 127 Public Square
Cleveland, OH 44114

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