Notice of Collection for California Residents – Applicants and Employees

December 11, 2023

This Notice at Collection (“Notice”) is directed to individuals applying for employment with G. H. Smart & Company, LLC (“ghSMART”) and to ghSMART employees (“Applicants and/or Employees”) who reside in California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, each as amended from time to time (“CCPA”). The Notice discloses the personal information that ghSMART may collect about you in the context of interacting with you in the context of an Applicant and/or Employee relationship.

Categories of Personal Information Collected

In the course of interacting with you, we may collect the following categories of personal information, whether directly from you or from someone else:

Your data

Purposes of Collection, Use and Disclosure

We collect personal information (including sensitive personal information) in order to assess Applicants and/or Employees who are under consideration for specific employment positions.  We also use personal information in order to administer employee benefits to you and your dependents and beneficiaries, to manage your compensation, to address requests you may make and issues you raise, in the context of your participating in affinity groups, to manage any immigration requirements, to file tax information, and to otherwise comply with applicable law.

With respect to gender, ghSMART may use such information to conduct and publish research.  Examples of research topics could include: (a) the manner in which females perform as compared to males in given scenarios, or; (b) the performance of categories of individuals in varying industries and/or private vs. public companies.   When using personal information for research, ghSMART implements appropriate safeguards to ensure we use only that personal information necessary to undertake the research underway.  Where possible, ghSMART conducts its research using personal information that is anonymised and/or aggregated.  ghSMART does not disclose personal information of any specific Candidate through such research.  Gender is not used in the assessment of Applicants or Employees.

ghSMART does not sell or share (as those terms are defined by the CCPA) any of the personal information we collect, including the sensitive personal information

Retention of Personal Information

ghSMART retains personal information as required by legal and accounting standards and in compliance with our corporate records retention policy. In some circumstances, we may aggregate or deidentify your personal information so that it can no longer be associated with you, in which case we retain such information indefinitely.

Changes to this privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

California Privacy Policy

You may read our California Privacy Policy for Applicants and Employees

Contact details

If you have any questions about this privacy notice or how we handle your personal information, please contact: or +1 877 294 3368.

Mail address:

G. H. Smart & Company, LLC
203 North LaSalle Street
Suite 2100
Chicago, IL 60601
The United States of America