1. Scope
This Privacy Policy applies to personal information Procon collects through:
- Procon-operated websites and webpages;
- contact, subscription, registration, and other web forms;
- business development and client communications;
- events, conferences, webinars, and other programs;
- social media and other digital platforms;
- recruiting and employment application activities;
- interactions with business partners, vendors, and service providers; and
- other online or offline interactions that reference this Privacy Policy.
Third-party websites, platforms, and services are governed by their own privacy practices.
2. Personal Information We Collect
he personal information we collect depends on how you interact with Procon. Generally, we collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:
- Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience;
- Lawfully obtained, truthful information that is a matter of public concern;
- Deidentified or aggregated consumer information; or
- Information excluded from the CCPA’s scope, including:
- health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.
The chart below identifies the categories of information we collected from our consumers within the last 12 months and the expected retention period:
| Category | Examples | Collected | Retention Period |
|---|---|---|---|
| A. Identifiers | Name, mailing address, email address, telephone number, online identifiers, IP address, account information, and similar identifiers | Yes | Generally retained for at least the period required by applicable employment recordkeeping laws and thereafter only when reasonably necessary for legal, compliance, recruiting, or recordkeeping purposes |
| B. Personal information described in California Civil Code § 1798.80(e) | Name, address, telephone number, education, employment history, and other personal information | Yes | Same criteria described above |
| C. Protected classification characteristics under California or federal law | Where permitted or required by law, information such as age, race or ethnicity, sex or gender, disability status, veteran status, or other legally protected characteristics | Yes | Retained as required by applicable employment and recordkeeping laws and, where appropriate, maintained separately from materials used to make hiring decisions |
| D. Commercial information | Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | No | N/A |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data | No | N/A |
| F. Internet or other similar network activity | Browser type, device information, operating system, referring pages, pages viewed, website interactions, access dates and times, and similar information concerning use of our digital services | Yes | Retained for the period reasonably necessary for system operation, security, analytics, or legal compliance |
| G. Geolocation data | General or approximate location derived from an IP address or device information | Yes | Retained for the period reasonably necessary for the applicable technical or security purpose |
| H. Sensory data | Photographs, video, audio recordings, virtual meeting recordings, or other similar information when appropriate | Yes | Retained as required for recruiting records and legal compliance |
| I. Professional or employment-related information | Resumes, employment history, certifications, licenses, professional qualifications, references, security or work-authorization information, and other information provided in connection with recruiting or employment | Yes | Generally retained for a minimum of four years where required by California employment recordkeeping law, or longer when another legal requirement, litigation hold, or legitimate business need applies |
| J. Non-public education information | Education records such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records | Yes | Generally retained for the legally required recordkeeping period |
| K. Inferences drawn from other personal information | Information derived from other information that may reflect professional interests, qualifications, preferences, or suitability for a particular position or business relationship | Yes | Generally retained with the underlying record for the legally required recordkeeping period |
| L. Sensitive personal information | Further identified in Section 3 below | Yes | Further identified in Section 3 below |
3. Sensitive Personal Information We Collect
Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.
Procon uses sensitive personal information only for legitimate and lawful purposes associated with the reason for which it was collected, including recruiting, legal compliance, security, employment eligibility, accommodation requests, or other appropriate employment and business purposes. Procon does not use sensitive personal information to infer characteristics about consumers.
We ask that you not provide sensitive personal information through general Website forms unless specifically requested. Where the CCPA provides a right to limit the use or disclosure of sensitive personal information and that right applies to Procon’s processing, Procon will honor that right.
The chart below identifies which sensitive personal information categories we have collected from consumers to infer characteristics about them in the last 12 months.
Sensitive Personal Information Category | Collected to Infer Characteristics? | [Retention Period] |
L.1. Government identifiers | No | N/A |
L.2. Complete account access credentials | No | N/A |
L.3. Precise geolocation | No | N/A |
L.4. Racial or ethnic origin | No | N/A |
L.5. Citizenship or immigration status | No | N/A |
L.6. Religious or philosophical beliefs | No | N/A |
L.7. Union membership | No | N/A |
L.8. Mail, email, or text messages not directed to Procon | No | N/A |
L.9. Genetic data | No | N/A |
L.10. Neural Data | No | N/A |
L.11. Unique identifying biometric information | No | N/A |
L.12. Health information | No | N/A |
L.13. Sex life or sexual orientation information | No | N/A |
L.14. Children’s personal information (under age 16) | No | N/A |
4. Sources of Personal Information We Collect
We may collect the categories of personal information listed above from the following categories of sources:
- directly from you;
- indirectly from you, such as from your interactions with our Website and digital services;
- employers, clients, business partners, or professional contacts;
- recruiting agencies and professional networking platforms;
- applicant tracking, recruiting, and background-screening providers;
- event and conference organizers;
publicly available sources; - social media and professional networking services; and
- vendors and service providers acting on our behalf.
5. How We Use Personal Information We Collect
Procon may use the personal information we collect to advance our business and commercial purposes, including to:
- respond to inquiries and requests;
- provide and improve our professional services;
- communicate with clients, prospective clients, partners, vendors, and other stakeholders;
- administer events, webinars, and other programs;
- distribute newsletters, insights, company news, event information, and other communications;
- understand Website use and improve Website functionality;
- measure the effectiveness of communications and marketing activities;
- maintain and protect our Website, systems, and facilities;
- recruit, evaluate, interview, and communicate with job candidates;
- verify candidate qualifications, references, work authorization, and other employment-related information;
- comply with equal employment opportunity and other employment laws;
- conduct lawful background screening where appropriate;
- establish and maintain business records;
- prevent fraud, misuse, or security incidents;
- comply with applicable laws, regulations, contractual obligations, and legal processes; and
- establish, exercise, or defend legal rights.
We may use aggregated or de-identified information for purposes permitted by law.
6. How We Use Sensitive Personal Information We Collect
Procon may use sensitive personal information for the following statutorily approved reasons:
performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at Procon.
ensuring physical safety.
short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
disclose the sensitive personal information to another third party; or
use it to build a profile about you or otherwise alter your experience outside your current interaction with Procon.
services performed for Procon, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for Procon.
activities required to:
verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled; and
collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.
7. How We Disclose, Sell, or Share Personal Information We Collect
Disclosure of Personal Information
Procon may disclose personal information we collect to service providers and contractors for the business purposes identified in Section 5. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors. The chart below identifies the personal information categories we disclosed to certain cateogries of service providers or contractors over the preceding 12 months and the specific business purpose for disclosing that information:
Category of Business Purpose Disclosure Recipients | Personal Information Categories Disclosed | Sensitive Personal Information Categories Disclosed | Business Purpose Disclosures |
Website hosting and information technology services | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Cybersecurity services | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Data analytics | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Email and communications platforms | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Customer relationship management systems | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Event management services | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Applicant tracking and recruiting systems | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Background screening services | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Legal, accounting, insurance, and other professional services | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
Other administrative or operational support | [IDENTIFY THE PERSONAL INFORMATION CATEGORIES] | [IDENTIFY THE SENSITIVE PERSONAL INFORMATION CATEGORIES, IF ANY] | [IDENTIFY THE SPECIFIC BUSINESS PURPOSE(S)] |
We may also disclose information when necessary to comply with law, respond to lawful governmental requests, protect Procon or others, investigate unlawful conduct, enforce agreements, or facilitate a merger, acquisition, restructuring, financing, or similar business transaction.
Sale or Sharing of Personal Information
Procon does not sell personal information for monetary consideration and has not sold it in the preceding 12 months.
Procon does not sell or share job applicant personal information for cross-context behavioral advertising and has not sold or shared it in the preceding 12 months.
Procon may disclose personal information to service providers or contractors for legitimate business purposes as described in this Privacy Policy.
An opt-out from marketing communications does not prevent Procon from sending administrative, contractual, transactional, employment-related, or other non-marketing communications when appropriate.
Procon’s Website and professional services are not directed to consumers under 18, and Procon does not knowingly collect personal information from consumers under 18 through the Website.
If Procon learns that such information has been collected inappropriately, we will take reasonable steps to delete it.
8. California Privacy Rights
If you are a California resident and the CCPA applies to Procon’s processing of your personal information, you have the following rights, subject to applicable exceptions:
Right to Know and Data Portability Requests
You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”), including the specific pieces of personal information we have collected about you (a “data portability request”). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2022 unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see Exercising Your California Privacy Rights below), we will disclose to you:
- the categories of personal information we collected about you;
- the sources from which we collected your personal information;
the business or commercial purposes for collecting, selling, or sharing your personal information; - the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we disclosed, sold, or shared; and
- if your request includes a data portability request, a copy of your personal information, subject to any permitted redactions.
For more on exercising this right, see Exercising Your California Privacy Rights below.
Right to Delete
You have the right to request that we delete any of your personal information that Procon collected from you and retained, subject to certain exceptions and limitation provided by law (the “right to delete”). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.
For more on exercising this right, see Exercising Your California Privacy Rights below.
Right to Correct
You have the right to request correction of personal information maintained by Procon about you that you believe is inaccurate (the “right to correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.
For more on exercising this right, see Exercising Your California Privacy Rights below.
Right to Limit Sensitive Personal Information Use and Disclosure to Statutorily Approved Purposes
You have the right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s approved purposes (the “right to limit”). Once we receive your valid request, we will limit the use and disclosure of your sensitive personal information to the statutorily approved purposes.
For more on exercising this right, see Exercising Your California Privacy Rights below.
For more on the statutorily approved purposes and our additional use purposes, see Section 6.
Right to Opt Out of Sales or Sharing and Opt-In Rights
You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in”).
We cannot sell or share your personal information after we receive your request to opt-out unless you later consent to the sale or sharing of your personal information. Procon does not sell or share job applicant personal information for cross-context behavioral advertising.
For more on exercising this right, see Exercising Your California Privacy Rights below.
ADMT RightsRight to Non-Discrimination
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights provided by the CCPA.
Exercising Your California Privacy Rights
California residents may submit requests to know, delete, or correct personal information through the following methods:
Online: info@proconconsulting.com
Telephone Number: 703-527-7059
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. Requests to know, including for data portability, may only be submitted twice in a 12-month period.
California residents may submit requests to limit or opt-out through the following methods:
Online: info@proconconsulting.com
Telephone Number: 703-527-7059
You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.
You may also contact Procon regarding privacy questions at:
Email: info@proconconsulting.com
Procon may take reasonable steps to verify your identity before fulfilling a request. Information requested for verification will be used for verification and fraud-prevention purposes.
Procon will respond to verified requests in accordance with applicable law.
Authorized Agents
You may designate an authorized agent to submit a CCPA request on your behalf.
Procon may require an authorized agent to provide evidence of authorization and may contact you directly to verify your identity or confirm that you authorized the request, except where applicable law provides otherwise.
9. California Job Applicant Notice at Collection
This section applies to California residents who apply for employment with Procon or otherwise provide personal information to Procon in connection with a potential employment relationship.
Procon provides this Notice at Collection pursuant to the CCPA.
Procon collects and uses candidate personal information, including sensitive personal information, for the recruiting, employment-related, and other business-related purposes listed in the chart below. We are committed to properly handling the personal information collected or processed in connection with your employment relationship with us. The categories described below reflect information that may be collected depending on the position, recruiting process, and information voluntarily provided by the candidate.
We will not sell the personal information, including any sensitive personal information, we collect about our employees or applicants for employment or share it with third parties for cross-context behavioral advertising.
CCPA Personal Information Category | Examples of Candidate Information | Purposes | Retention Period |
Identifiers | Name, postal address, email, telephone number, online identifiers, IP address, and, where legally appropriate, government-issued identification | Communicating with candidates; administering applications; verifying identity, qualifications, employment eligibility, or background information; maintaining recruiting records | Generally retained for at least the period required by applicable employment recordkeeping laws and thereafter only when reasonably necessary for legal, compliance, recruiting, or recordkeeping purposes |
Personal information described in California Civil Code § 1798.80(e) | Address, telephone number, education, employment history, and other information included in an application or employment record | Recruiting, candidate evaluation, verification, background screening, employment administration, and legal compliance | Same criteria described above |
Protected classification characteristics under California or federal law | Age, race or ethnicity, sex or gender, disability status, veteran status, or other characteristics where voluntarily provided or legally required | Equal employment opportunity compliance, regulatory reporting, accommodations, and other lawful employment purposes | Retained as required by applicable employment and recordkeeping laws and, where appropriate, maintained separately from materials used to make hiring decisions |
Internet or other similar network activity | Career-site activity, applicant-portal logs, IP address, browser information, device information, and related technical information | Operating and securing recruiting systems, preventing fraud, troubleshooting, analytics, and improving the applicant experience | Retained for the period reasonably necessary for system operation, security, analytics, or legal compliance |
Geolocation data | Approximate location derived from IP address or similar technical information | Website functionality, security, fraud prevention, and recruiting administration | Retained for the period reasonably necessary for the applicable technical or security purpose |
Sensory data | Video interviews, photographs, audio recordings, virtual meeting recordings, or other materials provided or created during recruiting | Conducting interviews, evaluating qualifications, documenting the recruiting process, and facilitating communication | Retained as required for recruiting records and legal compliance |
Professional or employment-related information | Resume, work history, skills, qualifications, certifications, licenses, references, compensation expectations, work authorization, professional memberships, and security-clearance information where applicable | Evaluating qualifications; determining suitability for a position; contacting references; verifying credentials; making hiring decisions | Generally retained for a minimum of four years where required by California employment recordkeeping law, or longer when another legal requirement, litigation hold, or legitimate business need applies |
Non-public education information | Schools attended, degrees, transcripts, certifications, academic history, and training | Evaluating qualifications and verifying education or credentials | Generally retained with the candidate’s recruiting record for the legally required recordkeeping period |
Inferences drawn from other personal information | Interview assessments, recruiter or interviewer observations, skills assessments, and conclusions regarding qualifications for a role | Evaluating candidacy and making recruiting and hiring decisions | Generally retained with the underlying recruiting record for the legally required recordkeeping period |
We may also collect or use information that falls within the sensitive personal information cateogries listed in the table below, but the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.
| CCPA Sensitive Personal Information Category | Purposes | Retention |
| Government identifiers | Employment eligibility, legal compliance, equal employment opportunity obligations, accommodation requests, background screening, or other lawful employment purposes | Retained only as long as reasonably necessary and consistent with applicable employment, privacy, and recordkeeping requirements |
| Racial or ethnic origin | Legal compliance, equal employment opportunity obligations, or other lawful employment purposes | Retained only as long as reasonably necessary and consistent with applicable employment, privacy, and recordkeeping requirements |
| Health or disability information | Employment eligibility, legal compliance, equal employment opportunity obligations, accommodation requests, background screening, or other lawful employment purposes | Retained only as long as reasonably necessary and consistent with applicable employment, privacy, and recordkeeping requirements |
California candidates may exercise the CCPA rights described in Section 8 of this Privacy Policy, including rights to know, delete, and correct personal information, subject to applicable legal exceptions.
Certain applicant records may be retained notwithstanding a deletion request where Procon is required to maintain the information under applicable employment, civil rights, recordkeeping, litigation, or other laws.
Procon will not retaliate against or disadvantage a candidate for exercising rights under the CCPA.
Procon may use automated decision-making technology (ADMT) to process your personal information. For more information, see Section 10.
10. Automated Decision-making Technology
Procon may use technology to assist with recruiting administration and candidate management.
If Procon uses automated decision-making technology, as defined by applicable California law, to make or substantially make a significant hiring decision, Procon will provide any additional notice and rights required by applicable law before using candidate personal information for that purpose.
Where required, such notice may include information regarding the purpose of the technology, how it affects the hiring decision, and applicable rights to access information about or opt out of the technology or to obtain human review.
11. Cookies and Similar Technologies
Procon and service providers acting on our behalf may use cookies, pixels, tags, analytics tools, and similar technologies to operate the Website, understand Website usage, maintain security, remember preferences, and measure the effectiveness of Website content and communications.
Browser and device settings may allow users to control or disable certain cookies. Disabling certain technologies may affect Website functionality.
Where required by applicable law, Procon will provide appropriate choices regarding non-essential cookies or similar technologies.
12. Security
Procon maintains reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, misuse, or disclosure.
No information system or transmission method can be guaranteed to be completely secure. Accordingly, Procon cannot guarantee the absolute security of information transmitted to or maintained by us.
13. Marketing Communications
You may unsubscribe from Procon marketing emails by using the unsubscribe link contained in the communication.
14. External Websites and Social Media
The Website may link to third-party websites, social media services, recruiting systems, or other external platforms.
Procon does not control and is not responsible for the privacy or security practices of those third parties. Information provided directly to a third party is governed by that third party’s privacy policies and terms.
15. Changes to this Privacy Policy
Procon may update this Privacy Policy periodically to reflect changes in our business practices, technology, legal requirements, or information-processing activities.
When changes are made, Procon will update the Last Updated date above and provide additional notice where required by law.
16. Contact Procon
Questions concerning this Privacy Policy or Procon’s privacy practices, including California privacy rights requests, may be directed to:
Procon Consulting, LLC
Attn: Privacy / Marketing
1800 Tysons Boulevard, Suite 620
McLean, VA 22102
Email: info@proconconsulting.com
Privacy Number: 703-527-7059