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CALIFORNIA APPLICANT

NOTICE ABOUT YOUR PERSONAL INFORMATION

LAST UPDATED DATE: JANUARY 1, 2023

OVERVIEW

The privacy and security of your Personal Information is important to us at HCA Management Services, L.P. and our affiliates and subsidiaries (“HCA”, the “Company”, us”, or “we”). This Applicant Notice About Your Personal Information (“Notice”) explains your rights under the California Consumer Privacy Act of 2018 (“CCPA”) as Amended by the California Privacy Rights Act (“CPRA”) and is intended to provide you with information about how the Company collects, uses, and secures your Personal Information.

WHO THIS NOTICE APPLIES TO

This Notice applies to the Personal information we collect about recruits, applicants, prospective employees, or other candidates who apply to work at HCA (“Applicants” or “you”).

WHAT WE COLLECT

HCA collects information that identifies, relates to, describes, or is reasonably capable of being associated with you, directly and indirectly (“Personal Information”). Please see more information about the categories of personal information we collect in the “How We Use Your Personal Information” section below.

Personal Information does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this paragraph, “publicly available” means: information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by you or from widely distributed media, or by you; or information made available by a person to whom you have disclosed the information if you have not restricted the information to a specific audience. Publicly available does not mean biometric information collected by a business about you without your knowledge. Personal Information does not include your information that is deidentified or aggregate information.

HOW WE USE YOUR PERSONAL INFORMATION

The following chart details the categories of Personal Information the Company collects and or uses about you, the categories of Personal Information that the Company has disclosed about you for a business purpose, and the categories of Personal Information that the Company has collected, sold or shared about you beginning January 1, 2022. We will not use your Personal Information for other purposes without first notifying you.

Recruiting and Hiring

We collect the following categories of information from your application and through the interview process when you apply to work at the Company

  • Personal identifiers, such as your name or government ID number;
  • Address including postal code;
  • Professional or employment-related information;
  • Education information; and
  • Characteristics of protected classifications under California or federal law, such as your citizenship, and veteran or military status.
Background Check and Pre-Employment Screening

Some applicants who are conditionally offered employment may be required to complete a background check or pre-employment physical, which include collection of the following categories of information.

  • Personal identifiers, such as your name or government ID number;
  • Your references’ personal identifiers;
  • Characteristics of protected classifications under California or federal law, such as your age and marital status;
  • Professional or employment-related information;
  • Health insurance information; and
  • Medical information.

WHERE WE GET YOUR PERSONAL INFORMATION FROM

We collect your Personal Information from the following sources:

  • You: Primarily, we collect Personal Information directly from you. For example, during the recruiting or hiring processes.
  • Third parties: When we collect your Personal Information from third parties, such as former employers or references, it is because you have provided consent either to us or to the third party. To the extent you use third-party websites, the sites may be governed by separate terms of use and privacy policies, which are not under our control and are not subject to this Notice. Please contact the third parties for questions regarding their privacy practices, and to exercise your rights.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose any of the Personal Information we collect to the following recipients:

  • Affiliates: We share information with other members of our group of companies.
  • Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include performing background checks, analyzing traffic on our online properties, providing legal services, assisting us with improving our business, providing security or information technology services, and performing marketing or recruiting functions.
  • Online advertising partners: We partner with companies that assist us in advertising our Company, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.
  • Social media platforms: If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us.
  • Government entities/Law enforcement: We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the safety of our employees, our customers, or other individuals.
  • Other businesses in the context of a commercial transaction: We may change our ownership or corporate organization while providing the Services. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information as described in this policy.

WHEN WE “SELL” OR “SHARE” YOUR PERSONAL INFORMATION

The Company does not and will not sell or share your Personal Information with third parties. Under California law, a business “sells” personal information when it discloses personal information to a “third party” company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising.

RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AS AMENDED BY THE CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

Effective January 1, 2023, you have the right to make certain requests about your Personal Information:

  • Right to request access to Personal Information collected about you and information regarding the source of that Personal Information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, and disclose it;
  • Right to correct inaccurate Personal Information;
  • Right to delete Personal Information we have collected directly from you;
  • Right to opt out of the sale of Personal Information, and the use of it for cross-context behavioral ads (“sharing”);
  • Right to restrict the use and disclosure of Sensitive Personal Information under certain circumstances; and
  • Right not to be retaliated against for exercising these rights.

To exercise these rights, you can submit your request by completing the Personal Information Request Form at https://hcahealthcare.com/about/legal/consumer-request-form.dot.

HOW WE RETAIN YOUR PERSONAL INFORMATION

To the extent permitted by applicable law, the Company will retain your Personal Information only for as long as the company believes it is necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. There are relevant Records Retention Schedules that can be viewed as needed.

DISCLAIMER

Nothing within this Notice shall restrict HCA’s ability to:

  • Comply with federal, state, or local laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law; or
  • Otherwise exercise or defend legal claims.

QUESTIONS ABOUT THIS NOTICE

If you have questions or concerns regarding this Notice or the handling of your Personal Information, please contact us at 844-422-3282 or email us at CORP.PersonalInformationRequest@HCAHealthcare.com.

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