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CCPA Privacy Policy - Employees
This employee privacy policy is different from the “notice at collection” (see item #5 above). This would be made available to current employees (such as by posting it on an internal portal or site where other employment policies are posted), as well as to former employees and the family members, dependents, and beneficiaries of current and former employees. Consult with your privacy counsel on how this policy should be made accessible to former employees and to employees’ family members, dependents, and beneficiaries.
CCPA Privacy Policy - Offline Policy Where Covered Business Has No Website
If your business does not have a website, you are not off the hook from the requirement to have and make a privacy policy available to your consumers.
CCPA Privacy Policy - Website or App
This goes hand-in-hand with your notice at collection to job applicants, independent contractors, individuals in the B-2-B context, and other consumers. The website or app privacy policy should describe all data collected online and offline, directly or indirectly (including when collected on your behalf by a vendor), from any source, about all “consumers” regardless of context in which you collected their data (even if you bought their data), with the exception of employees and the family members, dependents, and beneficiaries of employees.