PRIVACY NOTICE TO CALIFORNIA EMPLOYEES, JOB APPLICANTS, AND CONTRACTORS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT REGARDING THE COLLECTION OF PERSONAL INFORMATION

Updated January 1, 2023

Dear Employee, Job Applicant, or Contractor:

For Interstate Group, LLC / TrailersPlus (the “Company,” “we” or “us”), respecting the privacy of our employees, applicants, and contractors, past and present, is an essential part of our privacy program.  We are committed to the proper handling of the Personal Information collected or processed in connection with your employment with us.  As a preliminary matter, we do not sell or otherwise disclose your personal information for monetary or other consideration to third parties.  We provide the following notice to all Company employees, job applicants, and independent contractors residing in California.

This disclosure describes the categories of Personal Information we collect and the purposes for which we process that information in accordance with California Civil Code § 1798.100(a) of the California Privacy Rights Act (“CPRA”).  The CPRA defines Personal Information as categories of information that identify, relate to, describe, or are reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to a particular individual or household. 

In connection with your application for employment or your employment with the Company, the Company may collect the following categories of Personal Information (as set forth in California Civil Code sections 1798.140(v)(1)(A) through (L), effective January 1, 2023): 

•  Please note that the CCPA’s definition of Personal Information does not include: publicly available information lawfully made available to the general public from federal, state, or local government records (publicly available does not mean biometric information collected by a business about a consumer without the consumer’s knowledge) (information is not publicly available if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained); de-identified or aggregated consumer information; information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accessibility Act of 1966 (HIPAA), the California Medical Information Act (CMIA) or clinical trial data, or personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
  

Category

• A. Identifiers. (Cal. Civ. Code 1798.140(v)(1)(A))

Examples

• Name, postal address, email address, social security number, driver’s license or state identification card number, date of birth, or other similar identifiers.
  

Collected Y/N

• Y

Sources of Collected Personal Information

• -

Sold or Shared?

• N

Category

• B.  Personal information described in California Civ. Code § 1798.80(e) (the Customer Records statute)
  

Examples

• Name, signature, social security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.  Some personal information in this category may overlap with other categories.
  

Collected Y/N

• Y

Sources of Collected Personal Information

• -

Sold or Shared?

• N

Category

• C. Characteristics of protected classifications under California or federal law. Cal. Civ. Code 1798.140(v)(1)(C))

Examples

• Age (40 years or older), marital status
  

Collected Y/N

• Y

Sources of Collected Personal Information

• -

Sold or Shared?

• -

Category

• F.  Internet or other electronic network activity information. (Cal. Civ. Code 1798.140(v)(1)(F))

Examples

• Browsing history, search history, and information regarding a consumer’s/resident’s interaction with an Internet Web site, application, or advertisement.
  

Collected Y/N

• Y

Sources of Collected Personal Information

• Automatically Collected

Sold or Shared?

• -

Category

• H.  Sensory data. (Cal. Civ. Code 1798.140(v)(1)(H))

Examples

• Audio, electronic, visual, thermal, olfactory, or similar information.
  

Collected Y/N

• Y (some worksites have public surveillance, and we may record calls)
  

Sources of Collected Personal Information

• Automatically

Sold or Shared?

• -

Category

• I.  Professional or employment related information. (Cal. Civ. Code 1798.140(v)(1)(I))

Examples

• Current or past job history or performance evaluations
  

Collected Y/N

• Y
  

Sources of Collected Personal Information

• Provided by employee / job applicant; Employer
  

Sold or Shared?

• -

Category

• K. Inferences drawn from other personal information. Cal. Civ. Code 1798.140(v)(1)(K))

Examples

• Information used to create a profile reflecting the consumer/resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  

Collected Y/N

• Y
  

Sources of Collected Personal Information

• -
  

Sold or Shared?

• -

Category

• L.  Sensitive Personal Information. (Cal. Civ. Code 1798.140(v)(1)(L))

Examples

• Social security number, driver’s license number, contents of e-mails or texts to others, health information
  

Collected Y/N

• Y
  

Sources of Collected Personal Information

• Provided by employee / job applicant; Employer
  

Sold or Shared?

• -

We use this information for the purposes stated below:  

For Job Applicants:

• To recruit employees, including evaluation of marketing and job offering services, website traffic, and referral sources; 

• To process your application for employment;

• To conduct employment-related background screening and/or reference checks; 

• To send you correspondence and information relating to your application or your employment with the Company; 

• To verify your identity, citizenship, or legal right to work for the Company, or to assist or cooperate with obtaining relevant immigration documents;

• To verify your educational background and/or degrees, certifications, or qualifications for the position you apply for; 

• To verify your prior employment; 

• To offer you employment with Company; 

• For testing, evaluation and/or reporting metrics, including but not limited to aggregating or anonymizing such information for workforce analytics, data analytics, and benchmarking; 

• To comply with applicable law or regulatory requirements, including legal requirements under state and federal law, law enforcement investigations or inquiries, as well as internal company reporting obligations, such as diversity, equity and inclusion initiatives and/or Equal Employment Opportunity Act reporting obligations; 

• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity;

• For quality assurance purposes, including call monitoring or customer service, and debugging to identify and repair errors that impair existing intended functionality; 

• For auditing related to a current interaction with the applicant or employee and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with this and other standards; 

• To analyze the effectiveness of placement of job listings and job descriptions; 

• For fraud prevention; and

• For internal research for technological development and demonstration.

For Employees, Contractors, and Past Employees/Contractors:

All of the above, plus: 

• To track time and attendance; 

• To administer employee benefits, such as medical, dental, commuter and retirement benefits, including the recording and processing of eligibility of dependents and beneficiaries, absence and leave monitoring, insurance and accident management, and rewards or discount programs offered to employees; 

• To provide healthcare-related services, such as accommodations and/or services based on eligibility (e.g., disability, worker’s compensation, medical condition); 

• To provide payroll, invoice, and tax services, including reimbursement for expenses, salary administration, payroll management, payment of expenses, payment of state and/or federal income taxes (if applicable), social security and unemployment taxes, and to administer other compensation-related payments, including bonuses and equity, if applicable; 

• To conduct performance-related reviews, including performance appraisals, professional development, career planning, skills monitoring, job moves, promotions and staff re-structuring; 

• To monitor work-related licenses and credentials and ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies or governing agencies; 

• To provide employees with other employment-related services, such as handling of employees’ claims, travel for the Company, moving or relocation services, or administration of separation from employment;  

• To assist you in case of an emergency, including maintaining contact information for you, your partner or spouse, and/or your dependents in case of personal or business emergency; 

• To maintain the safety and security of our employees, residents, tenants, contractors, visitors and others, including maintenance of security on Company websites, apps, intranets and/or extranets (such as monitoring email and internet access, and ensuring secure network access and data integrity), maintenance of physical security (including controlled entry to Company worksites and/or real estate assets), monitoring of worksite locations and/or real estate assets, including using biometrics or location monitoring for keys, key fob or key card entry to Company property, ensuring that employees, contractors and visitors comply with all applicable safety regulations; 

• In connection with audiovisual surveillance of public spaces; 

• For internal company directories; 

• For video presentations, interviews, training materials, and/or web conferences within the scope of your employment or contract;

• For the tracking of Company-owned or Company-leased vehicles, computers, equipment, and devices, including, but not limited to, remote deletion of Company data on business or personal devices; 

• For verification of proper use of Company resources;

• To facilitate a better working environment; 

• To maintain commercial insurance policies and overages, including for workers’ compensation and other liability insurance; and 

• For other purposes stated at or before the time of the collection of the information. 

Further, please note that under the CPRA, we may use your personal information for Company business or other notified purposes, provided that the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed. 

We retain your information as follows:

We keep your personal information for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as permitted or as may be required by law, or as otherwise communicated to you.

Your Rights Under the CPRA

Under the CPRA, you have several rights concerning the personal information collected by us. Upon the receipt of a verifiable employee request, we will use commercially reasonable efforts to honor your exercise the rights below, unless there is a business reason exception, or if your exercise of the rights is impossible or otherwise involves a disproportionate effort.  We will let you know in writing if we are unable to process your request. 

California residents have the following rights:

• To know the categories of personal information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;

• To know if sensitive personal information is being collected about you, the categories of sensitive personal information being collected, the purposes for which the categories of sensitive personal information are collected or used, and whether the sensitive personal information is sold or shared; 

• To know the length of time we intend to retain each category of personal information; 

• To know whether your personal information is sold or disclosed and to whom;

• To access your personal information;

• To delete the information you have provided to us, with certain exceptions; 

• To correct your personal information if it is inaccurate;

• To limit the use of your sensitive personal information;

• To reject automated decision making and profiling;

• To access information about automated decision making;

• To opt out of the sale or sharing of your personal information; and

• Not to be discriminated against, even if you exercise your privacy rights.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

If you are a current employee, you are required to keep your personal information updated by contacting Amanda Zoubi:  [email protected]; (208) 442-7637.  

If you have any questions regarding the collection of your Personal Information, please visit our website and review our Privacy Policy at https://www.trailersplus.com/privacy-policy/ or contact TrailersPlus Privacy, [email protected],  (208) 442-7637.