Job Applicant Personal Information Handling Policy

Introduction

TRISTAR is committed to protecting job applicants’ personal information.

TRISTAR observes principles of good information handling and takes all reasonable care when handling job applicants’ “Personal Information,” which includes any information that identifies or is capable of identifying, individual TRISTAR job applicants.

TRISTAR processes job applicants’ Personal Information in accordance with applicable privacy and data protection laws. For the purposes of this policy, all TRISTAR subsidiaries are collectively referred to as “TRISTAR.” Any reference to “TRISTAR” or “Company” in this policy means TRISTAR and its affiliates.

For information about the privacy rights of California residents, please see the State Consumer Privacy Notice section below.

What Personal Information may we collect and disclose about you?

Personal Information may be collected from you in various ways, including in person, by our company technology and systems when you use them, or by third-party recruiting tools, including online-recruitment services. Additionally, Personal Information may be obtained from your application materials including resume or CV; offer letter; backup files; internal or external contact information maintained in the onboarding, Human Resources Information System, active directory, or other internal systems; information captured from video or audio systems or other forms of monitoring or surveillance; data collected as part of the Company’s HR analytics or talent management programs; and data collected by third party services providers, such as background check.

Any or all Personal Information may be held electronically and/or in hard copy form.

How will we use your Personal Information?

TRISTAR will use your Personal Information to assess whether you are a good fit for relevant positions at our Company; to contact you in response to your application or the reason for which you provided your Personal Information to us; and/or to screen applicable workers against professional body registrations and licensing organizations. Such screenings are necessary to ensure that workers are suitable for their position at TRISTAR and, in particular, to confirm that they are permitted without exception to provide services to TRISTAR and all of TRISTAR’s clients, including organizations that prohibit excluded or debarred individuals from working on their account.

State Consumer Privacy Notice

This State Consumer Privacy Notice applies to residents of California and supplements our Consumer Privacy Policy for Applicants. It explains what Personal Information (PI) we collect about you, where and from whom we obtain it, why we collect it, and your respective rights regarding it. If you are a California resident, this notice applies to any PI that we collect about you.

PI, We Collect and Disclose for Business Purposes

In the preceding twelve (12) months, we may have collected the following PI about California residents and have disclosed it for the business purposes described below:

PI does not include:

• De-identified or aggregated consumer information.
• Publicly available information from government records
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
• PI covered by other privacy laws, including The Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Categories of Sources of PI

We obtain the categories of PI listed above from:

• You or your authorized agent,
• Service providers,
• Affiliates,
• Publicly available information,
• Organizations with which you are employed or affiliated

Collection from these sources may occur online, in person, via paper or other electronic means, and may occur automatically where state law permits such profiling absent an explicit request to opt-out.

Why We Collect PI

We collect your PI for one or more of the following business purposes:

• To respond to an email or particular request from you
• To communicate with you
• To personalize services for you
• To process an application as requested by you.
• To comply with applicable laws, regulations, and legal processes
• To protect someone's health, safety, or welfare.
• To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action.
• To keep a record of our transactions and communications
• To detect and protect against security incidents
• To debug to identify and repair errors.
• As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law

Sharing Your PI

At times, we may share your PI with third parties to display.

In the preceding twelve (12) months, we have not sold any PI.

Third parties are not allowed to use or disclose your PI other than as specified in our contract and as permitted by law.

If we seek to use your PI for a materially different purpose than we previously disclosed in this notice, we will notify you and will not use your PI for this new purpose without your explicit consent.

Sensitive Personal Data

We only process Sensitive Personal Data to process transactions necessarily related to your employment or application for employment.

How Long Do We Retain Your PI

We will retain your PI for as long as we provide services to you or as required by law.

Your Rights

You have the right to request that we disclose certain information to you about our collection and use of your PI over the preceding twelve (12) months prior to your request. Once we receive and confirm your verifiable consumer request, we will disclose it to you.

• What PI we collect about you
• Where and from whom we collect PI about you
• Our business purpose for collecting PI about you.
• The types of third parties with whom we share your PI.
• The specific pieces of PI we collect about you, in a readily-usable format—note that we will not disclose your actual Social Security number, driver’s license number or other government-issued identification numbers, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.
• The types of PI that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed your PI.
• You have the right to be informed about the PI that we collect about you at the time that or before we collect it. This is that notice.
• You have the right to request that we delete any PI about you that we have.
• You have the right to request a correction of any inaccurate information in the PI we collect about you.
• If we use your sensitive PI for purposes other than to render services to you, you will have the right to request that we limit the processing of your sensitive PI.
• You will not be discriminated against or penalized for exercising your rights to your PI, and we will honor your rights by not:
  • Denying you services,
  • Imposing penalties, or
  • Providing you with a different level or quality of services.
• Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why and you may appeal this decision (see additional information in Appeals section below).

How to Exercise Your Rights

You may exercise your rights by:

Emailing us at HRforms@TRISTARGROUP.NET Include “CPRA Request” in the subject line.

• Only applies to Tristar Insurance Group (tristargroup.net): You may opt out of the sharing of your PI collected on your device by using our cookie management tool on our website and by submitting a request via the Do Not Share My Information link on the website.
• You may be required to submit proof of your identity for these requests to be processed.
• We will not be able to comply with your request if we are unable to confirm your identity.
• You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

Timing

• Our responses to any of your requests for the information described above will be limited to information that we have collected in the preceding twelve (12) months before our receipt of your verified request.
• We will acknowledge receipt of your request within 10 days of receipt of your submission. You will receive our response to your request within 45 days of your request unless we provide you with notice that it will take more than 45 days to respond (in that case, we won’t take more than 90 days to respond).

Appeals

• If the business denies any of your requests, you may appeal by:
• Emailing us at HRforms@TRISTARGROUP.NET Include “CPRA Request” in the subject line.
• We will respond to your appeal within 45 days of receipt unless we notify you that we will require an additional 15 days to respond.
• If you remain concerned about the result of that appeal, you may contact the attorney general in your state of residency.