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Marsh McLennan California Candidate Privacy Notice

Effective: January 1, 2023

This privacy notice applies to all candidates to Marsh McLennan or one of our affiliated companies who reside in California.


What Personal Information Do We Collect?   

We collect the following categories of personal information and sensitive personal information (please note that the below categories are taken directly from the California Consumer Privacy Act, as required by the law): 

Category  

Examples  

Personal Identifiers  

Name, alias, postal address, unique identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.  

Any personal information listed in Cal. Civ. Code § 1798.80(e)  

Name, signature, social security number, address, telephone number, passport number, identification card information 

Protected Classifications under California or federal law  

Age, race, color, ancestry, national origin, citizenship, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, criminal records  

Internet or other similar network activity  

Browsing history, search history, interaction with a website, application, or advertisement, data from cookies or web beacons, and interactions with our emails, including when you read and respond to emails 

Geolocation Data  

Physical location (collected on a website)  

Sensory Data  

Call recordings, video and photographs  

Professional Information  

Job history and résumé information, work status (e.g., full-time/part-time), references, skills, professional qualifications, job preferences (such as willingness to relocate and salary expectations)  

Non-public education information per the Family Educational Rights and Privacy Act  

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records 

Inferences drawn from other personal information  

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes 

Government Identifiers (SPI)  

Social Security Number, Driver's license number, State ID card number, Passport number    

Sensitive Classifications (SPI)  

Racial/ethnic origin, union membership  

Personal information collected and analyzed concerning an individual’s health, sex life, or sexual orientation (SPI)  

Voluntarily provided information concerning sexual orientation or disability status  


What are our Business Purposes for Collecting and Disclosing Personal Information?   

We collect and use personal information for the following business purposes: 

  • Identifying and evaluating candidates for Company positions  

  • Record-keeping related to hiring processes  

  • Analyzing and improving the hiring process and outcomes, technology, service providers or other lawful analytics  

  • Diversity and inclusion initiatives  

  • Complying with legal, regulatory and corporate policy requirements or cooperate with law enforcement, subpoenas, or judicial process  

  • Consideration for other positions across the Marsh McLennan enterprise  

  • To perform background and criminal checks, as permitted by law  

  • If a candidate is hired, facilitating the completion of the employment file   

  • If candidate is hired, facilitating an application for a visa or work permit 

  • Engaging service providers and administering, assessing, debugging, securing and improving our talent acquisition technologies and websites 

  • Marketing employment opportunities to potential candidates 


We may also process or disclose de-identified information that is not reasonably likely to identify you for commercially legitimate and lawful business purposes.  Where we have de-identified data, we will maintain and use it without attempting to re-identify the data other than as permitted under law.  We do not collect any sensitive personal information for the purpose of inferring characteristics about candidates.


How Long Do We Keep Personal Information?    

Our retention periods for personal information vary based on the nature of the information and applicable laws.  We consider the following obligations when setting retention periods for personal information and the records we maintain: the need to retain information to accomplish the business purposes or contractual obligations for which it was collected; our duties to comply with mandatory legal and regulatory record-keeping requirements; and other legal impacts such as applicable statute of limitations periods. We may also retain personal information for other purposes delineated in applicable privacy laws.  


Sale of your Personal Information or Sharing for Cross-Context Advertising    

We allow certain third parties to use cookies and other online tracking technologies to collect personal information of visitors on our careers website, such as IP addresses or identifiers and listings searched/accessed.  These third parties analyze site activity and help us personalize outreach and content based on your interests, measure the performance of opportunity-marketing content, and derive insights about the audiences who saw our content.  These third parties may provide free or enhanced add-on services to our company, and they may use your personal information for purposes beyond the services they provide to our company (for example, building consumer profiles to help other clients with their targeted advertising or enriched analytics).  California law considers these types of online exchanges of personal information to be “sales” or “sharing” of personal information under the law, with some exceptions.   We sell or share the following categories of personal information to third party online analytics and advertising providers: Personal Identifiers; Internet or other similar network activity; Geolocation data; Professional Information (to the extent it can be derived from your activity on our website).  For the specific third parties that we sell or share information with, please click on the “Manage Cookies” link below for the names of Analytics and Advertising providers.  


You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross context behavioral advertising or targeting purposes. To do so, please click on the “Manage Cookies” link at the bottom of this webpage and ensure the toggles for “Advertising” and “Analytics” trackers are set to “No”.  


You may also implement a browser setting or extension to communicate your selling and sharing preferences automatically to the websites you visit.  Our websites process such “opt out preference signals” in a frictionless manner.  The current “opt out preference signal” with a defined protocol for companies to follow if they receive the signal is called the Global Privacy Control (GPC). GPC is available for an increasing number of browsers and browser extensions, listed here. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.  


Sources of Personal Information?    

We collect personal information from the following categories of sources:  

  • Directly from you or your representative 

  • Job search or career networking sites for whom you consented to making the information available to us 

  • Search engines, public databases, and/or your company or social media profile, and other publicly available sources  

  • External recruiters  

  • Indirectly from you or your representative via cookies, web beacons, pixels, and other online tracking technologies on our careers website.  

  • Information from another party or government entity with your consent (for example, for background screening, verification, and references, including education, past employment, criminal background, credit history, or E-verify confirmations) 


It is your responsibility to obtain consent from any references or family members/dependents before providing their personal information to us. 


Disclosures of Personal Information for Business Purposes  

We disclose personal information to various categories of third parties for the following business, commercial, and legal purposes: 

  • Intra-company consideration: To assist in evaluating you and to enable them to contact you regarding available roles.   

  • Services: We sometimes contract with other companies to perform functions on our behalf, such as hosting our careers site, conducting background checks or screening candidates, attracting and assessing candidates, supporting diversity and inclusion, and providing website analytics and marketing services. 

  • Business Transfers: As we continue to develop our business, we might sell or buy assets. In such transactions, personal information may be one of the transferred business assets to a successor. The Company could also be subject to bankruptcy proceedings, in which case personal information may be one of the covered assets.   

  • Legal Matters: The Company may preserve, and has the right to disclose any information about you to (a) protect and defend the rights, property, or safety of the Company or its affiliates, other users of this Site, or the public; (b) enforce the terms and conditions of our careers site (c) respond to claims that any content violates the rights of third parties; (d) respond to claims of suspected or actual illegal activity; (e) respond to an audit or investigate a complaint or security threat; or (f) comply with applicable law, regulation, legal process, or governmental requests.   

  • Employment: If you are hired as an employee of the Company, this information may be transferred into an employee record of the Company or its relevant affiliate/subsidiary.   

  • Security: To ensure the security of our systems, data, people, and property. 

We disclose personal information to the following third parties for our business purposes: 

Category  

Categories of Third Parties PI is Disclosed to for a Business Purpose  

Personal Identifiers  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors  

  • Affiliates/subsidiaries/successors  

  • Online analytics and advertising providers  

Any personal information described in Cal. Civ. Code § 1798.80(e)  

  • Background screening and other verification vendors.  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors  

  • Affiliates/subsidiaries  

Protected Classifications under California or federal law  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors  

  • Affiliates/subsidiaries/successors  

Internet or other similar network activity  

  • Vendors, service providers, and professional advisors 

  • Online analytics and advertising providers  

  • Affiliates/subsidiaries/successors    

Geolocation Data  

  • Vendors, service providers, and professional advisors 

  • Online analytics and advertising providers  

  • Affiliates/subsidiaries/successors  

Sensory Data  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors  

  • Affiliates/subsidiaries/successors   

Professional Information  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors   

  • Affiliates/subsidiaries/successors 

  • Online analytics and advertising providers   

Non-public education information (per the Family Educational Rights and Privacy Act  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Affiliates/subsidiaries/successors 

Inferences drawn from other personal information  

  • Search firms, recruiters and recruiting firms  

  • Affiliates/subsidiaries/successors  

  • Vendors, service providers, and professional advisors  

Government Identifiers (SPI)  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors  

  • Affiliates/subsidiaries/successors  

Sensitive Classifications (SPI)  

  • Background screening and other verification vendors  

  • Search firms, recruiters and recruiting firms  

  • Vendors, service providers, and professional advisors  

  • Affiliates/subsidiaries/successors  

Personal information collected and analyzed concerning an individual’s health, sex life, or sexual orientation (SPI)  

  • Affiliates/subsidiaries/successors  

*We may be required or compelled to produce any of the above categories of personal information that we have collected in response to valid legal process, subpoenas, or regulatory requests to authorized parties, including government entities, law enforcement, courts and tribunals, or litigants. 

Your Rights Under California Privacy Law 

Under California law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act, you may have the following rights regarding your personal information.  These rights are subject to a number of exceptions and limitations enumerated under the law.  


Right to Access Personal Information  

You can request to access either the specific pieces of personal information we have collected about you as of January 1, 2022, or the below descriptions about that personal information: 

  • The categories of personal information we have collected about you.  

  • The categories of sources for the personal information we have collected about you.  

  • Our business or commercial purpose for collecting that personal information.  

  • The categories of third parties to whom we disclose that personal information.  

  • If we sold your personal information for a business purpose, a list of the personal information types that each category of recipient purchased.  

  • If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.  


Right to Delete Personal Information  

You may have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is permitted or required under law.   

If no retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same.  


Right to Correct Personal Information  

You may have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will use commercially reasonable efforts to correct the inaccurate information.  


Right to Limit Processing of SPI   

We process sensitive personal information solely as reasonably necessary, expected, and attendant to our talent acquisition process, to ensure the security and integrity of the information, or as otherwise authorized under law or regulation.  Because we do not process your Sensitive Personal Information for other purposes, we do not provide any mechanism for you to limit our processing of such information.  

Right to Opt-out of Profiling   

We do not engage in automated processing of personal Information without human intervention to make decisions that produce a legal or other significant effect.  Because we do not engage in such automated processing, we do not provide a mechanism for you to limit our processing of personal information in such a manner.    

Right to Non-Discrimination  

You may exercise your privacy rights without discrimination.  For example, unless applicable law provides an exception, we will not deny you opportunities or services, or provide you a different level of or access to opportunities or services. 


How to exercise the above rights  

To exercise your rights to access, correction, or deletion described above, please visit our online privacy rights portal by clicking here.  Alternatively, you may call us at 1-866-374-2662.  Only you or a person legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. Agents must either provide a power of attorney demonstrating their lawful authority to act on your behalf or must submit both a written authorization from you as well as allow us to contact you to verify your consent. 
You may only submit two privacy requests every 12 months. During the request process you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, including via the provision of a copy of a valid photo ID and confirming other information we hold about you.  In order to safeguard the personal information in our possession, if we cannot verify your identity or authority to act on another’s behalf, we will be unable to comply with your request.  We will process and retain personal information you provide when submitting a verifiable request only to confirm your identity or authority, or to fulfill your request.  We will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time. 


How to appeal an action we have taken with respect to your request to exercise a right  

If we deny your privacy request in full or in part, please contact the email address for appeals provided in our written response to your request.  Our privacy team will consider your request and applicable law, and either agree to honor your appeal request or deny it.  


Direct Marketing and Do Not Track Signals  

Under California’s “Shine the Light” law, California residents may request a notice once a year about the personal information we disclosed to other businesses for their own direct marketing purposes in the prior year, including a list of the categories of personal information disclosed and the names and addresses of the recipients.  To obtain such a notice, please contact us at privacy@mmc.com.    

In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals.  Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.  Please see the section on Sales of Person Information for information about implementing the GPC signal.  


Minors  

We do not knowingly collect personal information from children under 13.  If we learn that we have collected any personal information from a child under the age of 13 without verifiable parental consent, we will delete that information from our files as quickly as possible.  If you believe that we may have collected information from a child under 13, please contact us at the email address provided below.  If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”).  However, we never knowingly sell or share the personal information of minors under 16 years of age and would not do so in the future without affirmative authorization of the consumer if between 13 to 16 years of age, or the parent or guardian of a consumer less than 13 years of age.  


Questions, Requests or Complaints  

To submit general questions, requests, complaints, or appeals regarding this Privacy Notice or our privacy practices, please contact us at privacy@mmc.com.