Applicant and Candidate Privacy Policy

Policy Scope:

This policy describes what type of information we collect, how we use the information shared with us, and/or the information which may be acquired or produced by Connecticut Transportation Solutions (CTS), its affiliates, and its divisions, during the application or recruitment process.

Types of Information We Collect:

The following information is collected during our application and recruitment process:

Personal and Contact Information:

• Applicant’s name, address, email address, telephone number, and other contact information.
• Resume or CV, cover letter, previous and/or relevant work experience, or other experience, education, transcripts, or other information provided to us in support of an application and/or the application and recruitment process.

Interview and Assessment Information:

• Information from interviews and phone-screenings including any recordings (with your consent).
• Information related to any assessment utilized as part of the interview screening process.
• Results for skills tests, personality assessments, or other evaluation tools.

Employment Preferences and History:

• Details of the type of employment an applicant is looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, and/or other job preferences.

• Details of how applicants heard about our open position(s).
• Information relating to previous applications submitted to CTS and/or previous employment history with CTS.

Reference and Background Information:

• Reference information and/or information received from background checks including information provided by third parties.
• We do not collect, consider, or use information about erased, expunged, or sealed criminal records in our hiring decision.

Publicly Available Information:

• Information from publicly available sources, including online and social media platforms (such as LinkedIn profiles), that we believe is relevant to an application or potential future application.
• Professional accomplishments, publications, or other career-related information available online.

Automated Decision-Making and AI Tools: We may use artificial intelligence, automated screening tools, machine learning algorithms, or other automated decision-making technologies as part of our recruitment process. When used, these tools may evaluate:

• Resume screening and ranking
• Skills assessments
• Video interview analysis
• Candidate matching to job requirements

If we use automated tools that significantly impact hiring decisions, we will inform you and provide information about how to request human review of automated decisions.

How We Use Information We Collect:

All information collected by CTS is used for the sole purpose of carrying out our application and recruitment process. This includes:

Primary Uses:

• Assessing skills, qualifications, and interests against our career opportunities.
• Verifying information and carrying out reference checks and/or conducting background checks (where applicable) if a conditional offer of employment is made.

Automated Processing:

• Using AI or automated tools to screen, rank or evaluate applications.
• Analyzing candidate responses for skills assessment or cultural fit.
• Matching candidate fit to current and future job opportunities.
• Processing biometric data for identity verification or security purposes (when applicable).

Sensitive Data Processing:

• Handling accommodation requests that may involve health-related information.

Legal and Compliance Uses:

• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable.
• Making improvements to the CTS application and/or recruitment process.
• Complying with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Protecting the rights and property of CTS, our users, applicants, candidates, employees, or the public as required or permitted by law.

Employment Record Integration:

If an applicant is offered and accepts employment with CTS, the information collected during the application and recruitment process will become part of their employment record.

Electronic Monitoring and Recording Disclosure

In accordance with Connecticut law:

• We do not use electronic surveillance or monitoring devices during the hiring process without proper disclosure and your consent.
• Phone interviews and video calls may be recorded only with your explicit consent.
• Any electronic monitoring will be disclosed to you in advance.
• You have the right to decline recording while still participating in the interview process.

Information Sharing and Third Parties

We may share your information with:

• Third-party service providers who assist with our recruitment process (background check companies, assessment providers, AI screening tools).
• Legal authorities when required by law.
• Internal teams involved in the hiring decision.

We require all third-party providers to maintain appropriate privacy and security standards for your information.

Our Retention of Your Information:

Unsuccessful Applications:

If you apply for a job at CTS and your application is unsuccessful, or you withdraw from the process, or you decline an employment offer, CTS will retain your information for a reasonable period after your application submission unless you request earlier deletion.

Retention Purposes:

We retain this information for various lawful reasons including:

• In case we are faced with a legal challenge regarding a recruitment decision
• To , including in case we face a legal challenge regarding a recruitment decision, to consider you for other current or future jobs at CTS.
• To help and to help us better understand, analyze, and improve our recruitment processes..
• To comply with applicable employment laws and regulations.

Deletion Requests:

If you do not want us to retain your information for consideration for other roles, or want us to update or delete it, please contact hr@icesonline.org. Please note we will retain information required or permitted by law or as necessary to protect ourselves from legal claims or as necessary to protect ourselves from legal claims.

Your Rights Regarding Your Information

General Rights:

You have certain rights under data protection law, including:

• The right to request access to your information.
• The right to update or correct your information.
• The right to request deletion or anonymization of your information.
• The right to object to or restrict CTS using your information for certain purposes.
• The right to request information about automated decision-making processes.

Connecticut Resident Rights:

If you are a Connecticut resident, you have additional rights under the Connecticut Data Privacy Act (CTDPA):

• Right to confirm whether we process your personal data.
• Right to access your personal data that we process.
• Right to delete your personal data, subject to certain exceptions.

• Right to correct inaccuracies in your personal data.
• Right to receive your personal data in a portable format.
• Right to opt out of profiling for decisions that produce legal or similarly significant effects.
• Right to appeal our decision regarding your rights request.

Automated Decision-Making Rights:

• Right to know when automated decision-making significantly affects your application.
• Right to request human review of automated decisions.
• Right to understand the logic behind automated screening tools.
• Right to challenge automated decisions.

Biometric Data Rights:

• Right to be informed before biometric data collection.
• Right to consent to biometric data processing.
• Right to request deletion of biometric data.
• Right to know the purpose and duration of biometric data storage.

Exercising Your Rights:

To exercise any of these rights, please contact: Email: hr@icesonline.org.

We will respond to your request within 45 days in accordance with applicable law. There may be circumstances where we cannot comply with your request due to legal requirements or legitimate business interests, and we will explain our reasoning if this occurs.

Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no data transmission or storage system can be guaranteed to be 100% secure.

Contact Information

If you have questions about this privacy policy or our data practices, please contact: Email: hr@icesonline.org.

Revised: August 2025