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PROSPECTIVE EMPLOYEE PRIVACY NOTICE

 

This Prospective Employee Privacy Notice (“Privacy Notice”) describes, among other things, how TRC Companies, Inc. and its subsidiaries and affiliates (“TRC,” “we,” “us,” and “our”) collects, processes, and uses your Personal Information (“Personal Information”) during your recruitment process with TRC.  Should you be selected for a position at TRC, during onboarding, you will receive additional information which further explains the processing of your Personal Information for purposes of entering into employment with TRC and processing during and after the expiration of the employment relationship.  To this end, we process your Personal Information to the extent that is necessary and in compliance with applicable data privacy laws.

TRC’s INFORMATION PROCESSING ACTIVITIES

We collect Personal Information, which may include sensitive personal information, from you when you provide it to us, such as when you submit a job application or communicate with us as part of the application process.  We may also collect your Personal Information from third parties authorized to share it with us, such as recruiters that share information about potential applicants.

Types of Personal Information Being Processed

Personal Information means information related to an identified or identifiable person.  TRC may collect and process the following categories of Personal Information about you during the recruitment process

  • Identifiers. Such as name, alias, mailing address, email address.
  • Personal Information, as defined by California Civil Code section 1798.80(e). Such as name, signature, address, telephone number, education, employment, employment history.
  • Such as race, ethnicity, gender, or other protected characteristics of classifications protected under applicable law.
  • Professional or Employment-Related Information. Such as salary expectation, employment history, and relevant certification information.
  • Education Information. Educational background including educational institution, degrees obtained, and year of graduation.
  • Geolocation Information. Information that identifies your precise geographic location.
  • Internet or Other Electronic Network Activity Information. Such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Other recruitment information, (including copies of right to work documentation, references, and other information included in a resume or cover letter or as part of the application process);
  • Any other information that you voluntarily provide to us.

SOURCES OF PERSONAL INFORMATION

The above information may be collected in the following methods listed below:

  • Resume(s)/curriculum(a) vitae;
  • Contact details for references and references feedback;
  • Information provided during job forums and recruitment events;
  • Information obtained through social media or networking sites;
  • Information forwarded by recruitment agencies; and/or
  • Pre-employment screening services.

Note, the above information is received by TRC in various forms including hard-copy and electronic form, delivered in-person or via email, fax, website, social media, etc.

Legal Basis for Personal Information Processing

During the recruitment process, we only process information that is necessary to assess your suitability for the position you are applying to and, in the case of a successful candidacy, to facilitate the hiring process.

The legal basis for the processing of your information during the recruitment and hiring process is to further TRC’s legitimate interest in finding the most suitable candidate(s) for applicable positions, and facilitate the hiring of selected candidates.

Any other processing of your Personal Information will only be undertaken if there is a legal basis for such processing (i.e., if processing is necessary to fulfill a legal obligation to which TRC is subject).

Additionally, we may further store your information for purposes of possibly considering you for future open positions at TRC.  If applicable, this processing will then be based on your explicit consent.  You are never obligated to give consent.  Consent can only be given freely, and consent can be withdrawn at any time.

Access to Your Information by TRC

Access to your Personal Information within TRC is limited to employees and staff who need to access the information for the performance of their work-related tasks and duties involving the recruitment process.  This is regulated in TRC’s internal policies and secured via technical access limitations.

During the recruitment and hiring process, your information will be accessed only by those staff members of TRC who are involved in the recruitment and hiring-related decision-making processes at TRC, including talent acquisition personnel and relevant department heads.

DISCLOSING YOUR PERSONAL INFORMATION

We will only transfer your information to third parties if it is necessary and if there is a legal basis for it.  For example, we may use third party service providers to host and facilitate our operations and business (including human resources operations), such as cloud services providers, accounting service providers, human resource providers, payroll service providers, benefits providers, and travel service providers.

Additionally, we may share your Personal Information with our professional advisors who have confidentiality obligations to us.  We may also share your Personal Information with third parties for purposes of fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as (i) preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; (ii) protecting the rights, property, or safety of you, us, or another party; (iii) enforcing any agreements with you; (iv) responding to claims; and (v) resolving disputes.

In any other case, if required under the applicable law, we will only transfer your Personal Information to third parties if you have given explicit, effective consent for us to do so.  You are never obligated to give consent.  Effective consent can only be given freely, and consent can be withdrawn at any time.

TRC does not sell or otherwise disclose Personal Information for monetary or other consideration to any third parties. TRC does not use or disclose sensitive personal information, other than for the business purposes permitted by law as described above.

Transfer of Your Information to Third Countries

Certain TRC affiliates and third-party service providers are located outside of the EU/EEA and UK.  In these limited circumstances, we may transfer your information to the US or other non-EU/EEA/UK countries (“Third Countries”) in accordance with this Privacy Notice and applicable local privacy laws in furtherance of our employment relationship with you.

We may transfer your Personal Information to our affiliates outside of the EU/EEA and UK, including to recruit personnel and department heads in the US, for review and processing in connection with your job application.  We may also transfer your Personal Information to third parties in the US for processing in connection with your job application.

TRC recognizes that the information protection laws in the Third Countries where the information is transferred to may not be as comprehensive as those of the country where your information was collected.  TRC takes commercially reasonable measures to confirm that Personal Information transferred to a Third Country is provided with adequate security measures and protected from unauthorized access.  Further, to the extent that TRC uses any third-party service providers that are located in a Third Country, TRC will enter into appropriate standard contractual clauses or other contractual arrangements to provide appropriate protection as required under applicable laws, including the EU GDPR and the UK GDPR.   Your Personal Information will primarily be stored in US for processing purposes but may also be stored in the EU/EEA/UK and Canada.

 

RETENTION of Your Information

TRC will not maintain your Personal Information, including any sensitive personal information, longer than is necessary for the purpose for which it was collected.  We will store your Personal Information until the end of the recruitment process (i.e., until a suitable candidate has been selected and an employment agreement concluded with said candidate), unless TRC maintains your information for consideration for future job openings. Should you be selected and onboarded for the position for which you applied, you will be provided with TRC’s Employee Privacy Notice.

Subject to your explicit consent (if applicable), we may store your information for a future job opening.  We may retain your information for this purpose for up to one (1) year from the date of the last hiring decision.

After the end of the lawful storage period of your information we shall delete, destroy, or anonymize your information.

Security of Your Information

To ensure the security of your information during the lawful storage period, we employ necessary technical and organizational security measures, taking into account (i) the current level of available technology; (ii) the cost-efficiency of current technology; (iii) the extent, scope, context, and purposes of processing; and (iv) the risks associated with specific processing activities.  Such measures include, for example, access limitations, training of all staff and employees, and confidentiality clauses in employment and service contracts.

YOUR PERSONAL INFORMATION RIGHTS

Under various information privacy regulations, subject to exceptions and derogations that might apply in certain circumstances, individuals may have various rights regarding the Personal Information that is processed by TRC, including the following:

  • Right to Know and Right to Access: Individuals have the right to know what Personal Information is being processed by TRC and right to access their Personal Information. Specifically, you have the right to access any Personal Information that TRC processes about you and to request Information about:
  • The purposes for processing your Personal Information;
  • The categories of Personal Information concerned;
  • The recipients or categories of recipients to whom the Personal Information has been or will be disclosed;
  • The length of time TRC intends to store your Personal Information;
  • The specific pieces of Personal Information TRC has collected about you;
  • The source of information if TRC did not collect the information directly from you;
  • Whether we use automated decision-making (including profiling); and, if so, the logic involved and the intended consequences of such processing; and
  • The safeguards we employ when transferring your information to a non-EU or non-UK country.

Upon your request, TRC will provide you with a copy of your Personal Information in a structured, commonly used electronic form.

  • Right to Rectification: If you believe that TRC holds any incomplete or inaccurate information about you, you have the right to ask TRC to correct and/or complete the Personal Information. TRC will then correct or complete the information, provided that TRC will notify you if it has a legal reason for being unable to do so.
  • Rights to Delete, Restrict, or Object: You also have the right to request erasure of your Personal Information or to restrict processing in certain circumstances in accordance with the information protection laws, as well as to object to any processing of Personal Information on grounds relating to your particular situation, if the processing is based on legitimate interests pursued by TRC.
  • Data Portability: If we are processing your Personal Information based on your consent, pursuant to a contract, or by automated means, you may request a copy of your Personal Information in a structured, commonly used, and machine-readable format.
  • Right to Limit: You have the right to limit certain uses or disclosures of Sensitive Personal Information. Our uses of Sensitive Personal Information are described above.
  • Right to Non-Discrimination:As defined under relevant law, you have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights. Note that TRC does not use automated processing in its review process.

Information Subject Requests

In order to exercise your rights under this Privacy Notice and applicable information protection laws, you may send an email to HR@trccompanies.com.

If TRC receives a request from you to exercise any of the above rights, TRC may ask you to verify your identity before acting on the request; this is to confirm that your information is protected and kept secure.

Information Subject Complaints

If you believe that TRC is failing to adequately meet any of the rights outlined above, you may file a complaint with a relevant Information Protection Authority.  TRC can identify this supervisory authority upon request.

Consequences of Not Providing Your Personal Information

You are not obligated to provide your Personal Information to TRC.  However, as this information is necessary for TRC to employ you, TRC may not be able to extend an offer of employment or employ you without the provision of certain Personal Information.

Changes to the Privacy Notice

We have the right to unilaterally modify this Privacy Notice if this should become necessary due to changes in corporate practices regarding information processing, or changes in relevant laws and regulations, or changes in guidance and best practice documents issued by relevant authorities.

Contact Information of the Information Controller

Personal Information is controlled by TRC’s Human Resources department:

If you have any questions regarding the Privacy Notice or regarding your rights as an information subject, or if you wish to exercise such rights, please contact us at:

E-mail address: HR@trccompanies.com

Address:
 
TRC Companies, Inc.
21 Griffin Road North
Windsor, CT 06095
USA
Attention: Human Resources

 

Last updated: January 2024

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