Last Updated: March 3, 2020
Privacy Notice at Collection: Categories of Personal Information that We Collect, Disclose or Sell
The table below identifies categories of personal information about California residents that we may collect or disclose for a business purpose. MSA does not sell the personal information of California residents.
|Categories of Personal Information1||Collect?||Disclose for business purpose?|
|Basic Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||Yes||Yes|
|Cal. Code 1798.80 Information such as signature, physical characteristics or description, telephone number, and education, employment, financial, medical, or health insurance information.||Yes||Yes|
|Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, and citizenship status.||Yes||Yes|
|Commercial Information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||Yes|
|Biometric information such as fingerprints, retina scans, or facial recognition.||No||No|
|Network activity information such as browsing history, search history, and information regarding interaction with an Internet Web site, application, or advertisement.||Yes||Yes|
|Sensory Information such as audio, electronic, visual, thermal, olfactory, or similar information.||Yes||Yes|
|Professional or employment-related information, such as corporate service dates, emergency contact information, and job information.||Yes||Yes|
|Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).||Yes||Yes|
|Inferential information drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||No|
|Note that the table above does not include information publicly available in government records, de-identified or aggregated California resident information, or information excluded from the CCPA’s scope, such as health or medical information coved by HIPAA or personal information covered by certain other privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.|
Sources of Personal Information
We may obtain the categories of personal information described above from the following categories of sources:
- Directly or indirectly from you or your agents. For example, from documents that you provide to us or from forms that you fill out.
- Directly or indirectly from activity at our facilities or on our website, intranet, MSA systems or MSA-issued or approved devices. For example, from submissions through our website portal or website usage details collected automatically.
Uses of Personal Information
We may use or disclose the types of personal information described above for one or more of the following purposes:
- To communicate with you or your company. For example, to provide email alerts and other notices concerning our company, products, or services, or events or news, that may be of interest to you.
- To provide or improve a product or service. For example, our Safety io Grid service allows customers to monitor geolocation of portable gas devices in real time, which may or may not be assigned to particular workers.
- To facilitate transactions. For example, for shipping, delivery, or distribution, or to make or receive payments.
- As part of ordinary business processes. For example, as part of Human Resources processes.
- To improve internal processes. For example, to improve our website and better present its contents to you.
- For research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of MSA, our customers, or others.
- In cooperation with law enforcement or as required or permitted by applicable law, court order, or regulation.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use previously collected personal information for materially different, unrelated, or incompatible purposes without providing you notice, except as required or permitted by law.
Disclosures of Personal Information
MSA may disclose the personal information described above to various third parties. Such disclosures may be made to service providers who use the information in compliance with our instructions, to companies and individuals as necessary to facilitate the operation of MSA’s business, and to other entities, such as government authorities, as required or permitted by law. For example, MSA may disclose certain personal information as part of due diligence, or as necessary to make or receive payments for goods or services or to actually provide our goods or services. MSA seeks to limit disclosures to only the information necessary to fulfill the legal or business purpose for which the information is being disclosed.
California Resident Rights2
California law grants certain rights to California residents and imposes restrictions on particular business practices. Depending on their relationship with MSA, a California resident may have the right to make the following requests:
Deletion: The right to request deletion of personal information that we have collected about them, subject to certain exemptions.3
Right to Know: The right to request that we disclose information about how we have handled their personal information in the prior 12 months, at no charge, up to twice in a 12-month period, including a copy of such personal information if requested, including the:
- Categories of personal information collected;
- Categories of sources of personal information;
- Business and/or commercial purposes for collecting and selling their personal information;
- Categories of third parties to whom we have disclosed or with whom we have shared their personal information; and,
- Categories personal information that we have disclosed or shared with a third party for a business purpose
A request to exercise copy, deletion, or right-to-know rights can be submitted via the below form, mailing a letter to MSA Safety Incorporated, 1000 Cranberry Woods Drive, Cranberry Township, PA 16066, Attention: Law Department, Privacy, or by contacting us at 1-800-532-9762 (toll free). We will attempt to respond to a California resident’s verified request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding our receipt of the verified request.
We cannot respond to your request or provide you with personal information if we cannot verify your identity and/or your authority to make the request and confirm the relevant personal information relates to you. We will only use personal information provided in a California resident’s request to verify the requestor’s identity and/or authority to make the request.
If you wish to use an authorized agent to submit a request, we will need to verify the authorized agent by confirming that the original requestor has given written permission. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
Incentives and Non-Discrimination.
The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information. MSA also does not discriminate against individuals for exercising rights under the CCPA.
1 Personal information is a defined term under the CCPA. To find out more about CA consumer rights and responsibilities under the CCPA, visit: https://oag.ca.gov/privacy/ccpa.
2 This section also does not apply to personal information we collect about job applicants, independent contractors, current or former full-time, part-time and temporary employees and staff (and/or their beneficiaries), officers, directors, or owners of MSA (collectively, “Business Associates”). For a full CCPA disclosure for our Business Associates, please see here: www.msasafety.com/ccpa.
3 For example, where MSA needs the personal information to provide goods or services, complete a transaction, perform a contract with you, retain within the context of our ongoing business relationship by reasonable expectation, or that we may otherwise retain under applicable law.