Does an employee privacy notice need to be separate and distinct from a consumer privacy notice?


The CCPA requires that a business subject to the Act disclose the type of personal information that it collects about its California employees and the purpose of the collection “at or before the point of collection.”   The CCPA does not, however, require that such information be presented in a separate employee-specific privacy notice.

While some employers choose to create a stand-alone privacy notice that applies to employees, other employers choose to include disclosures concerning their collection and use of employee data as part of the broader privacy notice that they provide to clients, customers, and business partners, which discusses all of the business’s data-related practices.