Workforce Privacy Notice

Careers

Effective Date July 2024

PKF O’Connor Davies LLP and PKF O’Connor Davies Advisory LLC (collectively, “PKFOD,” “us, “our,” or “we”) understand the importance of protecting the privacy of our job applicants and workforce. This Workforce Privacy Notice (“Privacy Notice”) explains our information collection practices and the rights and choices that you have in relation to how we collect, use, retain, and disclose your Personal Information during your recruitment, including when you apply for a specific job or submit a resume via a PKFOD website, recruiting platform, email account, or job fair, as well as during and after your employment. This Privacy Notice applies to prospective, current, and former employees and interns, contractors, and other temporary workers of PKFOD who reside in the United States (collectively, “Workforce Members”).

If you are a California resident, please see the section below titled Your Privacy Rights and Choices; California Residents for our Notice at Collection and additional information provided pursuant to California law.

Information We Collect and How We Collect It
How We Use Your Information
Disclosures of Your Information
Your Privacy Rights and Choices; California Residents
Data Security and Retention
Services From Other Parties
Children’s Information
Changes to this Privacy Notice
Contact Us

1. Information We Collect and How We Collect It

For purposes of this Privacy Notice, 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 consumer or household, and may include Device, Internet and Network Information. Device, Internet and Network Information refers to device, internet, and network activity information that we and our Service Providers may collect about your device or your online activity when you interact with our websites or platforms. Personal Information does not include anonymous or de-identified data that is not associated with a particular individual, or information that is outside the scope of state consumer privacy laws, such as information protected by the Health Insurance Portability and Accountability Act or the Gramm-Leach Bliley Act.

We may collect one or more categories of Personal Information, including Sensitive Personal Information (as defined by California law) listed below. We will collect most of this Personal Information, including any Sensitive Personal Information, directly from you. In some circumstances, third parties may provide your Personal Information to us. These third parties may include your current or former employers; recruiters and recruiting agencies; job boards, such as Indeed or LinkedIn; government agencies; courts; and/or background check Service Providers. Depending on your interactions with us, we may also obtain information about you from advertising networks, internet service providers, data analytics providers, operating systems and platforms, or social media platforms.

We may collect the following categories of Personal Information and Device, Internet and Network Information about you in the course of business and during your recruitment and employment at PKFOD:

Identifiers and contact information, such as your full name, address, telephone number, email address, internet protocol (IP) address, emergency contact information, signature or similar identifiers.
Demographic data, such as date of birth, gender, race, ethnic origin, marital status, family composition, disability, health and welfare or retirement benefits-related information, or veteran or military status.
Educational and professional background information, such as your work history, and academic and professional qualifications.
Employment screening, background check and hiring information, such as resume, employment application, educational records, criminal history, references, interview notes and summaries of your characteristics, attitudes, intelligence, abilities, and aptitudes.
Personnel file information, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and leave records.
Financial information, such as banking details, tax information, payroll information, and withholdings.
Health and safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
Geolocation data, such as time and physical location related to use of a company-owned device or application, access the company network, or visit to a PKFOD office location.
Information systems (IS) information for devices (including personal devices) within PKFOD’s information systems and networks, such as search history, browsing history, login information, and IP addresses.
Surveillance information, such as internet access and usage, including the use of a computer, telephone, voice, electronic, instant message, wire, radio or other system, and video surveillance.
Facial images and personal details, such as those used for building access badges, published employee biographies, and corporate marketing materials.
Dependent or beneficiary information, such as their full name, address, date of birth, Social Security numbers (SSN), and their relationship to you.
For temporary workers such as independent contractors, contract engagement details, such as your title, service dates, and compensation under the contract or engagement.

We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as our staff or personnel; Service Providers; including professional advisers, partners, and agents of PKFOD; other external parties with whom we interact to facilitate our recruitment and employment processes; and publicly available sources.

We may also collect the following categories of Sensitive Personal Information about you:

Government identifiers, such as your Social Security number, driver’s license, state identification card, passport and visa information, and immigration status and documentation.
Demographic information, such as racial or ethnic origin or gender required for equal opportunity reporting, as well as for use in diversity, equity and inclusion initiatives.
Health information, including job restrictions and workplace illness and injury information.
Religious or philosophical beliefs, such as records related to a reasonable accommodation request.
Precise geolocation, such as any data that is derived from a device and that is used or intended to be used to locate an individual within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations.
In limited circumstances, complete account access credentials, such as usernames, PKFOD email address and content, account numbers, or card numbers combined with required access/security code.

We do not collect, use, or disclose Sensitive Personal Information to infer characteristics about individuals.

2. How We Use Your Information

We use your Personal Information, including Sensitive Personal Information, for our internal business purposes, including human resources, employment management, benefits administration, health and safety, to prevent fraud and other criminal activity, to maintain legal compliance, and for other purposes about which we may notify you.

Personal Information about job applicants is collected and processed for purposes of identifying, screening, and evaluating candidates for positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where and to the extent permitted by applicable law. If you are hired by PKFOD, this data may be transferred to our employee record files for the purpose of administering your employment relationship with us. In addition, Workforce Member information may be used as necessary to comply with legal, regulatory, and corporate governance requirements.

The following table depicts how we use the Personal Information we collect from our Workforce Members:

Personal Information Use/Purpose	Employees	Job Applicants	Temporary Workers
Comply with all applicable laws and regulations.	X	X	X
Recruit and evaluate job applicants, candidates, and independent contractors for employment or potential contractor engagements.	X	X	X
Conduct background checks.	X	X	X
Manage your employment relationship with us, including for: the onboarding processes; timekeeping, payroll, and expense report administration; benefits enrollment and administration; training and development requirements; the creation, maintenance, and security of your online employee accounts; reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill; workers’ compensation claims management; job performance, including goals and performance reviews, promotions, discipline, and termination; facilitating diversity, equity and inclusion efforts, and employee resource groups; and other human resources and administrative purposes.	X		X
Solicit and manage client relationships and engagements including: staffing client projects; marketing our services, capabilities, and areas of expertise; and responding to diversity, equity, and inclusion data inquiries, such as in RFPs.	X		X
Manage your relationship with us, including for: payment administration; the creation, maintenance, and security of your online accounts; and reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill.	X		X
Manage and monitor an individual’s authorization to access to PKFOD facilities, equipment, and systems.	X		X
Conduct internal audits and workplace investigations.	X		X
Investigate and enforce compliance with and potential violations of PKFOD policies and procedures.	X		X
Engage in corporate transactions requiring the review of Workforce Member records, such as for evaluating potential mergers and acquisitions.	X	X	X
Maintain commercial insurance policies and coverages, including for life and health, workers’ compensation, general liability, errors and omissions, cyber and other liability insurance.	X		X
Perform aggregate Workforce Member data analytics and benchmarking.	X	X	X
Administer and maintain PKFOD’s operations, including for safety purposes.	X		X
Respond to client requests for aggregate statistics regarding the demographic composition of our employees and contractors.	X		X
Exercise or defend the legal rights of PKFOD and its employees, affiliates, customers, contractors, and agents.	X	X	X

3. Disclosures of Your Information

We will only disclose your Personal Information to external parties where required by law or to our employees, designated agents, Service Providers, or other external entities who require such information to assist us with administering recruitment and employment-related processes. We may use Service Providers for various purposes, including, but not limited to, obtaining employment verification and background checks, payroll and benefits administration, chat or messaging providers, file sharing, data storage, or hosting providers. These Service Providers may be located outside of the United States.

Our Service Providers must implement appropriate security measures to protect your Personal Information consistent with our policies, applicable regulations, as well as any information security obligations applicable to us. We do not permit Service Providers who process your Personal Information on our behalf to use your Personal Information for their own purposes. We only permit them to process your Personal Information for specified purposes in accordance with our instructions.

We may also disclose your Personal Information for the following additional purposes where permitted or required by applicable law:

To other Workforce Members across our offices (including outside of your home state) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process and/or the employment relationship.
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your Personal Information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Information necessary for the specific purpose and circumstances.
To government entities in response to employer accountability and discrimination audits.
To protect our legal rights and property.
During emergency situations or where necessary to protect the safety of persons or to notify emergency contacts.
If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will use and disclose your Personal Information consistent with this Privacy Notice, including providing prior notice of any new or changed practices that materially impact your Personal Information, when applicable, and we will anonymize the Personal Information where possible.
Where the Personal Information is publicly available.
To other parties with your consent where such consent is required by law.
To other parties where permitted or required by law.

4. Your Privacy Rights and Choices; California Residents

Workforce Members in California may have certain rights with respect to Personal Information. These rights include:

Your Right to Access Information. You may have the right to request access to your Personal Information and, where technically feasible, request a copy of your Personal Information. You may also have the right to obtain information about how we process or disclose your Personal Information.

Your Right to Review and Correct Information. You may have the right to request that we correct any inaccurate or incomplete Personal Information we have about you.

Your Right to Delete Information: You may have the right to request that we delete your Personal Information. Please note that we may not be able to delete certain information depending on legal exceptions or obligations. Please see the Data Security and Retention section below for more information about why we may retain your information.

Your Right to Restrict the Use and Disclosure of Information. You may have the right to restrict how we use your information, including your Sensitive Personal Information. Note that PKFOD collects, uses and discloses Personal Information solely for the operational purposes described in this Notice. PKFOD does not collect, use, or disclose Sensitive Personal Information to infer characteristics about you.

Your Right to Revoke Consent. You may have the right to withdraw your prior consent to the processing of your Personal Information, including disclosing your Personal Information to external parties (other than our Service Providers).

Your Right to Opt-Out of Marketing Communications. You may request that we not use your Personal Information to send you certain emails or other marketing communications. You may also unsubscribe from receiving marketing emails from us by clicking on the “Unsubscribe” link found in those emails.

Your Right to Non-Discrimination. In California, you have the right not to receive discriminatory treatment by us for exercising your privacy rights and choices.

Exercising Your Rights

If you would like to exercise any of these rights, please contact us at privacy@pkfod.com or 914-381-8900. PKFOD employees may exercise some of the above rights, including your rights to access, review and correct the Personal Information we have about you, through our workforce management platform, UKG. In order to protect your Personal Information, we may ask you to provide additional information to verify your identity. You may also submit a request to exercise your rights through an authorized agent, in which case your agent must present signed written permission to act on your behalf. You may be required to independently verify your identity with us and confirm that you have provided authorization to the agent.

In the preceding 12 months, PKFOD has disclosed the categories of Personal Information in the below chart to our Service Providers for specific, limited business purposes, including the purposes listed in the How We Use Your Information section of this Privacy Notice. PKFOD does not “sell” or “share” the Personal Information of our Workforce Members, as those terms are defined by the California Consumer Privacy Act (CCPA).

Categories of Personal Information Collected	Purpose for Collection, Use and Disclosure to Service Providers	Shared or Sold?
Identifiers and Contact Information (such as your name, address, Social Security number, driver’s license or state identification information, passport and visa information, immigration status and related documentation, IP address, email address, mailing address, phone number, signature, and similar identifiers).	Communicating with you To evaluate and process your application for employment To comply with applicable laws For our business purposes as described in this Privacy Notice	No
Demographic Data (such as your date of birth, gender, race, ethnic origin, marital status, family composition, disability, health and welfare or retirement benefits-related information, or veteran or military status).	To administer your employment To comply with applicable laws For our business purposes as described in this Privacy Notice	No
Internet or Network Activity Information (such as PKFOD network-connected device information, including your browser type and language, IP address, device type, unique device identifiers, mobile network information and operating system, and website interactions, such as the pages visited on the website, time spent on each page, whether you’ve clicked on a hyperlink and search queries).	Data security incident detection Debugging and repair of technical systems For our business purposes as described in this Privacy Notice	No
Inferences (preferences, such as which employment opportunities you are interested in).	Communicating with you To evaluate and process your application for employment	No
Educational and Professional Information (such as your educational transcripts and other information relevant to hiring qualifications, including your resume, current or previous employer(s), job title, function, and the nature of your duties and responsibilities).	To evaluate and process your application for employment	No
Employment screening and background check Information (such as your professional and educational records, criminal history, references, interview notes and summaries of your characteristic, attitudes, intelligence, abilities, and aptitudes).	To evaluate and process your application for employment	No
Personnel File Information (such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and leave records).	To administer your employment For our business purposes as described in this Privacy Notice	No
Financial Information (such as your banking, tax and withholdings, and payroll information).	To administer your employment For our business purposes as described in this Privacy Notice	No
Health and Safety Information (such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information).	To administer your employment To comply with applicable laws For our business purposes as described in this Privacy Notice	No
Protected Classification Characteristics (such as age, gender, religion, and disability information, which you may provide to us in connection with an application for employment).	To evaluate and process your application for employment To comply with applicable laws For our business purposes as described in this Privacy Notice	No
Photographic or Biometric Information (such as facial images and personal details, including those used for building access badges, published employee biographies, and corporate marketing materials).	To administer your employment For security purposes For our business purposes as described in this Privacy Notice	No
Geolocation Data (such as the time and physical location related to use of a company-owned device or application, access the company network, or visit to a PKFOD office location); and Precise Geolocation Data (such as any data that is derived from a device and that is used or intended to be used to locate an individual within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations).	To administer your employment For security purposes For our business purposes as described in this Privacy Notice	No
Audio, Electronic, Visual, or Similar Information (such as audio and/or video recordings of your interview for employment with us).	To evaluate and process your application for employment To comply with applicable laws For our business purposes as described in this Privacy Notice	No
Sensitive Personal Information (such as your Social Security number, driver’s license, state identification card, or passport information; veteran status; racial or ethnic origin, religious or philosophical beliefs, or union membership; or certain information in the content of your written communications with us).	To evaluate and process your application for employment To administer your employment To comply with applicable laws For our business purposes as described in this Privacy Notice	No

California “Shine the Light” Notice. California law requires us to inform California residents who have provided us with personal information that they may request information from us about our disclosures to third parties for their direct marketing purposes. We do not disclose Personal Information of Workforce Members to third parties for their direct marketing purposes.

5. Data Security and Retention

We have implemented appropriate physical, technical, and organizational safeguards designed to protect your Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to Personal Information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider our statutory obligations, the amount, nature, and sensitivity of the Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means. We specify the retention periods for your Personal Information in our document retention policy. If you are a PKFOD employee, you can access our Document Retention Policy in order to identify the appropriate retention period.

If you are offered and accept employment with us, the Personal Information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with this Privacy Notice or applicable law. If you do not become an employee, or, once you are no longer an employee of ours, we will retain and securely destroy your Personal Information in accordance with our policies, applicable laws and regulations. Unless you have consented or there is a contractual or regulatory requirement that specifies otherwise, we generally retain Personal Information about applicants for no more than two (2) years.

6. Services From Other Parties

Please note that this Privacy Notice does not apply to the practices of third parties, including the information collection practices associated with the websites of our workforce recruitment, background investigation, health and employment benefits, and independent contractor management vendors. When you access a third party’s website or services through links on our website, information collected from you by others on those third-party websites, is governed by those entities’ privacy policies. PKFOD is not responsible for and does not control the security or privacy of your information when you visit those sites or use those services. We encourage you to read the privacy policy of every website you visit.

7. Children’s Information

We do not recruit or employ, or intend to collect Personal Information from anyone we know to be under the age of 16. If we learn that we have unknowingly collected or received Personal Information from an individual under the age of 16, we will make reasonable efforts to delete such information from our records. If you believe that we might have any information from or about a child under the age of 16, we ask that a parent or guardian contact us at privacy@pkfod.com.

8. Changes to This Privacy Notice

Please review the Effective Date at the top of this page to determine when this Privacy Notice was last revised.

From time to time, we may modify this Privacy Notice. If we update this Privacy Notice, we will notify you by posting a new Privacy Notice on this page. If we make any material changes to this Privacy Notice, we will notify you as required by law, which may include by email to the email address you provided to us, if available. We encourage you periodically to check this page for updates.

9. Contact Us

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to disability, please contact us at privacy@pkfod.com and 914-381-8900.

If you have any questions about our practices with respect to your Personal Information or would like to make an access or other request, please contact us at privacy@pkfod.com and 914-381-8900.