The CCPA defines the term “personal information” to include any information that “identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”1 Based upon the broad definition, employers often collect the following types of personal information about employees:
- Benefits elections.
- Correspondence to/from the employee and the employer.
- Correspondence to/from the employee and other employees.
- Correspondence to/from the employee and customers or clients of the employer.
- Complaints made about the employee.
- Complaints made by the employee.
- Disciplinary actions and related investigation files..
- Employment eligibility verification information (e.g., I-9, Social Security Number).
- Job application.
- Pay details (e.g., direct deposit information).
- Pay history.
- Performance reviews.
- Personnel files.
- Salary and salary history.
- Time and attendance.
1. CCPA, Section 1798.140(o)(1).
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