California Employee Privacy Notice

Effective Date: January 1, 2020

What is the purpose of this document?

This California Employee Privacy Notice (the “Notice”) for TKC Holdings, Inc. and its subsidiaries including Advanced Technologies Group, LLC, Courtesy Group, LLC, Courtesy Products, LLC, Inmate Calling Solutions, LLC, Keefe Commissary Network, LLC, Keefe Group, LLC, Olivette Products, LLC, Trinity Services Group, Inc. and TSG Puerto Rico, LLC (collectively referred to herein as “TKC”), describes TKC’s collection of Personal Information from job applicants, employees, and contractors, and the business purposes for which this data will be used. This Notice supplements any other privacy notices and is not intended to override them. This includes, but is not limited any provisions in the Employee Handbook.

For the purposes of this Notice, “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household.

Categories of Personal Information Collected

TKC collects Personal Information about you during the application process and throughout the scope of your employment with TKC. The categories of Personal Information collected may include the following:

  • Identification data, such as your name, employee/staff ID, date of birth, nationality, Social Security number or equivalent national identification number.
  • Contact details, such as your work and home addresses, telephone numbers, email addresses, driver’s license information, and emergency contact details.
  • Family Information, such as the name, relationship, date of birth, contact details, and social security numbers of your family members, and any other information that may be needed for the administration of benefits.
  • Information about your job, such as job title, category and status, work location, department, employment contract, assigned tasks and projects, weekly hours, supervisor’s name, start and end date, eligibility for rehire, and reason for leaving.
  • Job qualifications, such as your education, training, certifications, motor vehicle records, and prior work experience.
  • Monitoring information, such as IT systems usage information related to your use of TKC equipment, systems, and other resources.
  • Communication details, such as email content, business letter content, business documents, video and audio conferencing, instant messaging, and chat content.
  • Performance and disciplinary information, such as performance reviews, evaluations and ratings, information about disciplinary allegations, the disciplinary process and any disciplinary warnings, details of grievances, and any outcome, and information collected through our reporting hotline(s).
  • Information about your compensation and benefits, such as your basic salary, bonus and commission entitlements, insurance benefits (including information about you and your dependents that we provide to the insurer), hours and overtime, tax code, holiday entitlement, sick time, accrued salary information, and information relating to your retirement plan.
  • Employment related documents and agreements, such as employment agreements, confidentiality agreements, proprietary rights agreements, onboarding documents, acknowledgement forms, and payroll documents.
  • Payment information, such as your bank details (for payroll and travel reimbursement purposes only) and business travel and entertainment data.
  • Health information, as required by law or as necessary to manage the employment relationship, including drug and health screens, COVID-19 health screening, benefits administration, occupational health, disability accommodation, workers’ compensation, and medical leave.
  • Equal opportunity monitoring data, to the extent voluntarily provided, such as race, ethnicity, disability, and military veteran information.
  • Union membership status, as required by law to ensure benefits, terms of employment, and employment policies comply with the Union’s requirements.
  • Termination and post-employment information, such as termination agreements, benefits notices, and unemployment compensations forms.

Business Purpose

TKC uses Personal Information, for all purposes related to the application for employment, and the creation, administration, and termination of your employment relationship with the TKC and for all purposes related to clients. These purposes include, but are not limited to, the following:

  • Making a decision about your recruitment or appointment.
  • To assess your skills, qualifications, and suitability for the work or role for which you are applying.
  • To carry out background and reference checks, where applicable.
  • To communicate with you about the recruitment process.
  • Determining the terms on which you work for us.
  • Confirming you are legally entitled to work in the United States.
  • To administer compensation, including, but not limited to, payment of wages and bonuses and income tax withholding and reimbursement of business expenses.
  • Providing employment benefits to you if applicable, for example, medical insurance, life insurance, and retirement savings plans.
  • Business management and planning, including accounting and auditing.
  • Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about salary reviews and compensation.
  • Assessing qualifications for a particular job or task, including decisions about promotions.
  • Gathering evidence for possible grievance or disciplinary hearings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
  • Ascertaining your fitness to work.
  • To administer leaves of absence as required by law or company policy
  • Complying with health and safety obligations.
  • To prevent fraud.
  • To monitor your use of our information and communication systems to ensure compliance with our policies.
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
  • To conduct data analytics studies to review and better understand employee retention and attrition rates.
  • Equal opportunities monitoring.
  • To exercise the TKC’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
  • To meet legal and regulatory requirements including civil discovery in litigation involving the TKC or affiliated companies.
  • To facilitate administrative functions, including, but not limited to, the management and operation of information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning, and the maintenance of licenses, permits and authorizations applicable to the TKC’s business operations.

Questions

If you have any questions or concerns about this Notice, please contact LegalAffairs@tkcholdings.com.