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TSIA ("we" or "us" or "our" or "TSIA") has issued this Privacy Notice ("Notice") to describe how we handle Personal Data we collect and process about our job applicants and staff members (collectively referred to as "you" or "your") applying for a job or working for TSIA. The term "staff member" includes employees and those who work on a non-permanent basis (contingent workers, contractors, temporary workers, and interns).
We respect the privacy rights of individuals and are committed to handling Personal Data responsibly and in accordance with applicable law. This Notice describes the Personal Data we collect and process about you, the purposes of the processing, and your rights.
This Notice should be reviewed along with our other corporate policies and procedures. When appropriate, we will provide notices to address additional processing activities not mentioned in this Notice. If you are a California resident, please see the CCPA Addendum for additional disclosures regarding the information we collect and any rights you may have under California law.
In the course of your employment at TSIA, or when submitting an application for employment, we may process Personal Data about you and your dependents, beneficiaries and other individuals whose Personal Data has been provided to us.
We use the term "Personal Data" (also called "personal information" or "personally identifiable information" in the laws of some jurisdictions) to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been de–identified, anonymized, or aggregated, or that otherwise cannot reasonably be related back to a specific person is not considered Personal Data. The precise definition of Personal Data may vary depending on your state, province, or country of residence, but we take the same approach to protect your privacy. As a general rule, we try not to collect or process any Personal Data about you, unless authorized by law or where necessary to comply with applicable laws or to provide benefits. We do not sell Personal Data collected under this Notice.
The types of Personal Data we may process include, but are not limited to:
Typically, you will have provided the information we store about you, but there may be situations where we collect Personal Data or Sensitive Personal Data from other sources. For example, we may collect the following:
If you are applying for a position at TSIA, we collect and use your Personal Data primarily for recruitment purposes (specifically, to determine your qualifications for employment and to reach a hiring decision). This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying out reference checks or background checks (where applicable) and to manage the overall hiring process and communicate to you regarding it.
If you are accepted for a position at TSIA, the information collected during the recruitment process will form part of your ongoing staff member record.
If you are not successful, we may still keep your application for internal reporting, and to allow us to consider you for other suitable openings within TSIA in the future.
Once you become a TSIA staff member, we collect and use your Personal Data for the purpose of managing our employment and working relationship with you. For example, we may collect the following:
We process our staff member Personal Data through our human resources system ("HR System"), which provides tools that help us to administer HR and staff member compensation and benefits, and allows staff members to manage their own Personal Data in some cases. This will involve transferring your Personal Data to our HR System provider's servers. TSIA may host these servers or utilize third party servers, but in either case will be responsible for the secure access of Personal Data on the HR System servers.
We maintain a directory of staff members which contain your professional contact details (such as your name, location, photo, job title and contact details). This information will be available to everyone in TSIA to facilitate cooperation, communication and teamwork.
We may also collect and use Personal Data when it is necessary for other purposes, including:
TSIA also uses video cameras and recording equipment for its premises and offices, and stores information captured by this equipment, in order to secure its networks, systems, and property, and may monitor access and use of its systems using this equipment.
TSIA may also request or require you to enable your device used for work, whether personal or issued by TSIA, to recognize facial or fingerprint IDs. Your biometric information will be stored on the device itself, and TSIA will never transfer this data to its servers or to any third party. With respect to your personal device, this means that TSIA will never collect or possess your biometric information. For company issued devices, we will only store biometric information on the device itself and only with your explicit consent, and only for the period of time that such device is issued to you. TSIA will adhere to any obligation it has under law to notify and negotiate with the applicable representative before imposing such a requirement on represented employees.
We also may retain and use your Personal Data where we consider it necessary for complying with laws and regulations, including collecting and disclosing staff member Personal Data as required (e.g. for tax, health and safety, anti-discrimination and other employment laws), under judicial authorization, to protect your vital interests (or those of another person), or to exercise or defend the legal rights of TSIA.
We take care to allow access to Personal Data to only those who require such access to perform their tasks and duties, and to third parties who have a legitimate business purpose or other lawful reason for its access. Whenever we permit a third party to access Personal Data, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice, and that the security and confidentiality of the information is maintained.
We will share your Personal Data with other members of TSIA in order to administer human resources and staff member compensation at an international level on the HR System, as well as for other legitimate business purposes such as IT services/security, tax and accounting, and general business management.
In addition, we make certain Personal Data available to third parties who provide services to us. We do so on a need-to-know basis and in accordance with applicable data privacy laws.
For example, some of this information will be made available to:
We may also disclose Personal Data to third parties on other lawful grounds, including:
We never sell the Personal Data we collect from and about you.
If you are a job applicant or staff member in the United Kingdom, European Economic Area, or Switzerland (collectively, "Europe"), our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
However, we will normally collect Personal Data from you only where:
Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time.
When we collect Sensitive Personal Data, we normally do so only:
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided at firstname.lastname@example.org.
Where we request Personal Data or Sensitive Personal Data from you, you can choose not to provide it to us. However, unless otherwise indicated, the information we request from you is required in order to enter into our employment relationship with you or in order to comply with our legal obligations. Failure to provide your data in such circumstances prevents us from effectively administering our employment relationship with you (including any related employment benefits) and/or complying, which may mean we are unable to offer you, or to continue your employment.
As TSIA operates at a global level, we may need to transfer Personal Data to countries other than the ones in which the information was originally collected. Our recruitment and staff data is hosted in the United States. When we export your Personal Data to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer Personal Data from Europe to a country outside it, such as the United States, we will implement an appropriate data export solution such as entering into standard contractual clauses (SCC) with the data importer, or taking other measures to provide an adequate level of data protection under European law. In all cases, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Notice.
If you are in Europe, you may exercise the rights available to you under applicable European data protection laws as follows:
We respond to all requests we receive from individuals in Europe wishing to exercise their data protection rights in accordance with applicable European data protection laws. TSIA will need to verify your identity consistent with applicable data protection laws before processing any such request. This may require you to provide additional information to verify your request.
This Notice may be updated periodically to reflect changes in our privacy practices. In such cases, we will indicate at the top of the Notice when it was most recently updated, and if we make a material change, we will inform you, for example, on our intranet or by company-wide email. We encourage you to check back periodically to ensure you are aware of the most recent version of this Notice. Please note that TSIA does not discriminate or retaliate against those who exercise their rights under applicable data protection laws.
Please address any questions or requests relating to this Notice to email@example.com or alternatively, you can contact your manager or HR. If you have disabilities, you may access this notice in an alternative format by contacting firstname.lastname@example.org.
If you are located in Europe and wish to speak with our Data Privacy Officer, please contact email@example.com.
These provisions apply only to California consumers and supplement the Privacy Notice for Staff and Job Applicants. The California Consumer Privacy Act of 2018 ("CCPA"), including the California Privacy Rights Act ("CPRA") of 2020 and any regulations put into effect thereunder, provides California consumers with specific rights regarding their Information. This CCPA Addendum describes your rights, explains how you may exercise your rights, and provides an overview on the types of Personal Information TSIA collects.
General information regarding our collection, use, and disclosure of your data is detailed in the Notice above.
The CCPA defines "Personal Information" as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. To help consumers make informed privacy decisions, the CCPA classifies Personal Information into defined categories, and our practices regarding Personal Information are outlined in the below table. Please note that some types of Personal Information may apply to multiple categories.
TSIA collects some or all of the categories of Personal Information described below, which describes the business or commercial purpose(s) for which the Personal Information was collected and the entities to whom such information can be disclosed.
Name, alias, home and business address, unique personal identifier, online identifier, internet protocol (IP) address, device, browser, email address, account name, or other similar identifiers.
Recruitment; employment or work-related purposes; inclusion in the TSIA directory; other business purposes set forth above in the Notice.
TSIA; service providers; public or governmental authorities.
Customer records information
Name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, or other similar information (some personal information included in this category may overlap with other categories).
Recruitment; employment or work-related purposes; inclusion in the TSIA directory; other business purposes set forth in Section 4 of the Notice.
Characteristics of protected classifications under California or federal law
Age, race, color, ancestry, national origin, citizenship, marital or familial status, medical condition, physical or mental disability, sex, veteran or military status, and other similar information
Recruitment; employment or work-related purposes.
Fingerprints, facial or hand imagery, or voice recordings.
**We may at a later date collect facial or fingerprint IDs from you on TSIA devices and/or personal devices used for work purposes, and we would do so strictly for security and fraud prevention purposes (however, we have not collected this information from employees within the past 12 months).
Internet or other similar network activity information
Browsing history, search history, information regarding consumer's interaction with a website, application, or advertisement.
Security and fraud prevention.
TSIA; service providers.
Audio, electronic, visual, or similar information.
Security and fraud prevention; inclusion in the TSIA directory.
Professional or employment-related information
Employer, employment history, resumes and CVs, background checks, and other employment-related information.
Records maintained by an educational agency or institution that pertain to a student, such as grades and transcripts.
Sensitive personal information
Social Security, driver's license, state ID, or passport number; biometric information; personal information concerning health.
The Personal Information described in the table above is collected directly from you, or from the sources set forth in the Notice under "Sources of Personal Data." In addition to the parties described above, we may disclose your Personal Information to other third parties for legal, security, or safety purposes; to regulatory authorities, courts, and government agencies if required by applicable law; or with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries, or other assets.
We never sell your Personal Information, nor do we share it with third parties for the purposes of behavioral advertising. However, we may use de–identified, anonymized, or aggregated versions of your Personal Information for any purpose.
Right to Know
As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:
Right to Data Portability
You have the right to request a copy of Personal Information collected and maintained about you in the past 12 months. The CCPA allows you to request this information from us up to twice during a 12–month period. We will provide our response in a readily usable (in most cases, electronic) format.
Right to Delete
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception applies. For example, we may deny your deletion request if retention of the Personal Information is:
Right to Correct
You have the right to request the correction of any Personal Information we maintain about you.
Right to Limit the Use or Disclosure of Sensitive Personal Information
You have the right to limit the use or disclosure of your Sensitive Personal Information ("SPI") if we are using it beyond what is reasonable and proportionate within the context of your relationship with us as an employee or job applicant. You can make a request for us to limit the use or disclosure of your SPI by emailing us at firstname.lastname@example.org.
Right to Nondiscrimination
You will not receive discriminatory treatment by TSIA for exercising your CCPA privacy rights.
To exercise the rights described above, please submit a request to email@example.com.
After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, mailing address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.
Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. If you are making a request as the authorized agent of a consumer, we will ask you also submit reliable and verifiable proof that you have been authorized in writing by the consumer to act on such consumer's behalf.
We will make every effort to respond to your request within 60 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We may contact you within 60 days from the date you contacted us to inform you if we need more time to respond.
If you have any questions, comments, or complaints about how we use your information, or would like to exercise any rights that you may have under the CCPA, please reach out to at firstname.lastname@example.org.
The Technology & Services Industry Association (TSIA) is dedicated to helping technology and services organizations large and small grow and advance in the technology industry. Find out how you can achieve success, too. Call us at 800-876-6511 or we can call you.