Notice at Collection for California Job Applicants

Neogene Therapeutics, Inc. (the “Company”) is providing you with this Notice at Collection for California Job Applicants (“Notice”) to inform you about: 

  1. the categories of Personal Information that the Company collects about applicants who reside in California; and
  2. the purposes for which the Company uses that Personal Information.

For purposes of this Notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its applicants, who reside in California, in their capacity as applicants for positions with the Company.

Assistance For Disabled Applicants: Alternative formats of this Notice are available to individuals with a disability.  Please contact privacy@neogene.com for assistance.

1. Identifiers and Professional or Employment-Related Information

  1. Personal Information Collected: The Company collects identifiers and professional or employment-related information, including the following:
    • Identifiers such as real name, nickname or alias, postal address, telephone number, e-mail address, Social Security number, signature, online identifier, Internet Protocol address, driver’s license number or state identification card number, and passport number.
    • Professional or Employment-Related Information such as evaluations, membership in professional organizations, professional certifications, and employment history.
  2. Purposes of Use:
    • Recruiting:
      • To evaluate applicants’ qualifications for employment with the Company
      • To communicate with applicants
      • For diversity and inclusion purposes
      • To arrange and manage Company-sponsored events
      • To create a talent pool for future job openings
      • For recordkeeping purposes
      • To demonstrate applicants’ agreement to and/or acceptance of documents presented to them (e.g., pre-employment arbitration agreement, employment application, offer letter, etc.)
      • To evaluate and improve the recruiting process 
    • Monitoring, Security, And Compliance:
      • To monitor use of Company information systems and other electronic resources
      • To conduct internal audits
      • To conduct internal investigations
      • To protect the safety and security of the Company’s facilities
      • To administer the Company’s whistleblower hotline
      • To report suspected criminal conduct to law enforcement and cooperate in investigations 

2. Personal Information Categories from Cal. Civ. Code § 1798.80(e)

The Company collects categories of Personal Information listed in Cal. Civ. Code § 1798.80(e) (other than those already listed as “Identifiers” above) as follows for the purposes listed below:

  1. Photograph and Physical Description: For security and internal identification purposes.
  2. Medical Information: (a) for occupational health surveillance; (b) for occupational health and safety compliance and record-keeping; (c) to conduct fitness-for-duty examinations; and (d) to respond to an applicant’s medical emergency.

3. Characteristics of Protected Classifications Under California or Federal Law

The Company collects information about race, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act.

The Company also collects the following characteristics (in addition to those listed above) for its diversity and inclusion programs:  (a) religion (includes dress and grooming practices and encompasses all aspects of religious belief, observance and practice); (b) sex (includes gender, pregnancy, childbirth, breastfeeding, or related medical conditions; also, sexual orientation); (c) disability; (d) gender identity; (e) gender expression; (f) marital status; (g) age, (h) familial status.

The Company also uses this Personal Information for purposes including: disability, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary to comply with the Family Medical Leave Act and California law; military and veteran status as necessary to comply with leave requirements under applicable law;  age incidentally to the use of birth date for birthday celebrations and identity verification; religion and pregnancy, childbirth, breastfeeding, and related medical conditions as necessary for accommodations under applicable law; national origin as necessary to comply with immigration laws; and marital status and familial status as necessary to provide benefits and for tax purposes.

The Company collects this category of Personal Information on a purely voluntary basis and uses the information only in compliance with applicable laws and regulations.

4. Commercial Information

  1. Personal Information Collected: The Company collects commercial information, including the following: records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.
  2. Purposes of Use: Reimbursement of travel expenses.

5. Internet or Other Similar Network Activity

  1. Personal Information Collected: The Company collects information about applicants’ use of the Internet or other similar network activity, including the following: browsing history, search history, log in/out and activity on the Company’s electronic resources, information regarding an applicant’s interaction with an Internet web site, application, or advertisement, and publicly available social media activity.
  2. Purposes of Use: To monitor use of the Company’s information systems and other electronic resources or information systems, to conduct internal audits, to conduct internal investigations, to protect the safety and security of the Company’s facilities, and to impose discipline.

6. Sensory or Surveillance Data

  1. Personal Information Collected: The Company collects sensory or surveillance data, including the following: audio/visual recordings of interviews and footage from video surveillance cameras.
  2. Purposes of Use: To protect the safety and security of the Company’s facilities and personnel through video surveillance, to evaluate the applicant’s suitability for employment, to monitor compliance with Company policies, and to provide training.

7. Education Information

  1. Personal Information Collected: The Company collects education information, including the following: academic transcripts, educational discipline records, and academic counseling records.
  2. Purposes of Use: To evaluate applicants’ qualifications for employment with the Company and to conduct a pre-employment background check.

8. Background Screening Information

  1. Personal Information Collected: The Company collects background screening information, including results of the following types of background screening: criminal history; sex offender registration; motor vehicle records; credit history; employment history; drug testing; and educational history.
  2. Purposes of Use: To evaluate applicants’ qualifications for employment with the Company.

Purposes Potentially Applicable to Any of the Categories of Personal Information Above

The Company also may use applicants’ Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:

  • to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
  • to manage litigation involving the Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
  • in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company or any of its subsidiaries or affiliates; and
  • to manage licenses, permits and authorizations applicable to the Company’s business operations.

The Company does not sell the Personal Information it collects. However, the Company may share this information with third parties for certain business purposes as detailed in the Company’s Privacy Notice, which is available at https://www.neogene.com/neogene-privacy-notice.

Information Retention

Personal information will not be kept for longer than is necessary for the business purpose for which it is collected and processed and will be retained in accordance with our internal document retention policies. In certain cases, laws or regulations require us to keep records for specific periods of time, including following termination of the employment relationship. In other cases, records are retained in order to administer the employment relationship or to resolve queries or disputes which arise from time to time.

If you have any questions about our collection or use of your personal information, please contact privacy@neogene.com