APPLICANT AND WORKER PRIVACY NOTICE

Date of last revision: January 1, 2023

Welcome to PeopleConnect!

Whether you’re a current PeopleConnect team member or you’re applying to be part of our team, it’s important to us that you’re aware of the personal information we collect, how we use that information, and how you’re empowered to opt-out, correct, delete, or change that information.


The terms “PeopleConnect,” “we,” “us,” and “our” in this Privacy Notice apply to all companies in the PeopleConnect family of companies, which includes The Control Group Media Company, LLC, TruthFinder LLC, Instant Checkmate, LLC, Intelius, LLC, PeopleConnect, Inc. (d/b/a Classmates.com), Intelicare Direct, LLC, as well as any other parents, affiliates or subsidiaries that may now exist or we may form in the future. This Privacy Notice applies to all our applicants and prospective employees (collectively, “Applicants”) and current and former employees, officers, directors, contractors, agents contingent and other personnel (collectively, “Workers”), whose personal information is collected and processed by us in the ordinary course of our business, as well as Applicant’s and Workers’ emergency contacts and beneficiaries.


We are committed to complying with all applicable data privacy laws regarding the personal information of Applicants and Workers. Applicants, Workers, emergency contacts and beneficiaries with disabilities may access this notice in an alternative format by contacting [email protected]. We do not sell your personal information.

1. WHAT INFORMATION PEOPLECONNECT COLLECTS

The personal information we may collect about you includes:

  • General HR information. This might include your name, alias, postal address, phone number, unique personal identifier, online identifier, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, employment history, education information and records, professional qualifications, salary information, financial information related to credit checks, bank account number, routing number, and other details required for payroll, information that may be recorded on a resume/CV or application form, language abilities, records of personal property, business or professional licenses and insurance information and motor vehicle records, contact information of third parties in case of an emergency, and beneficiaries under any insurance policy.
  • Demographic information. Where permitted by law, we may also collect sensitive personal information, such as details of health and disability, including medical or mental health details, health insurance information, medical leave, and maternity leave; information about national origin or immigration status; and optional information like ethnicity, gender, or veteran status. We may ask for this information, for example, to help us achieve our diversity goals, or to provide you with job-related benefits.

We may also collect other information from you, such as:

  • Performance Information. We may receive or collect other information to help evaluate your application or your performance, such as information you choose to disclose during the interview process (as an Applicant) or during performance reviews (as a Worker). We may also collect job assignments, work schedules, hours worked, accomplishments and awards, termination information, training and development information, discipline and counseling information, opinions, evaluations, and other information provided to us from other Workers and/or customers as part of this review process.
  • Communications with Us. If you contact us, for example to inquire about benefits or ask about a job opportunity, we’ll receive your information, including whatever information you use to contact us.
  • Posting on Intra-Company Sites. We may offer intra-company accessible sites, pages, messaging channels, blogs, or forums for Workers to communicate and collaborate with each other, such as Microsoft Teams, Discord, or Slack (“Intra-Company Sites”). We and other individuals who use the Intra-Company Sites may collect the information you submit or make available through these Intra-Company Sites. If you choose to make content available on any public area of the Intra-Company Sites, such content will be visible to other Workers, and is not subject to the privacy protections set forth here in this notice.
  • Sensory Data. We may collect audio and visual information such as through photographs used for identification purposes, and we might also use those photos to promote our business. We may also collect audio and video recordings of training sessions or other meetings, or use CCTV to observe our physical offices for security purposes.
  • Surveys and promotions. From time to time we may ask Workers and/or Applicants to participate in optional surveys or promotions to help inform our decision-making, build team morale, and to ensure that your views are represented and considered. If you decide to participate, you may be asked to provide certain information, which may include personal information.
  • Inferences drawn from other personal information. We may collect inferences drawn from other personal information, such as your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Legal information. We also collect contractual information, such as information necessary to comply with our legal and contractual obligations, exercise our legal and contractual rights, and initiate, respond to, or defend against legal claims.

Apart from information you provide directly, PeopleConnect also collects information automatically from you while you work for us. For example, like most companies, we receive data like your internet protocol (IP) address, your location based on your IP address or activities, identifiers associated with your computer or device, cell phone-related information, activity logs, and other information about activities you engage in while you use our equipment, accounts, systems, and networks.

  • To ensure that our hardware and software is working optimally, we reserve the right to monitor and review the use of PeopleConnect equipment, accounts, information technology systems and networks to both ensure they’re used appropriately and to determine what IT upgrades may be necessary. Should it become necessary, and in accordance with applicable law, we may also access and review electronic files, messages, and emails sent or stored on our information technology systems and hardware, including without notice to you where legally permitted. And while confidentiality and privileged information is core to our work together, this information may be made accessible, when necessary, to other Workers. Workers do not have a reasonable expectation of privacy in any computer, technology system, email, handheld device, telephone, voicemail, or document that is used to conduct our business. Similarly, Workers should also know that they may not have access to every file, network, or program if access is not required for their work – this is because we need to maintain confidentiality and protect our other Workers.

2. WHY PEOPLECONNECT COLLECTS THIS DATA

Our hope and goal is to collect only information and data that we need to conduct our work, fulfill our obligations to you, comply with our legal obligations, and otherwise help you be successful at PeopleConnect.


For Applicants, we collect your data to determine if you’re a good fit for our team, and to help you get on board if we make you an offer. For Workers, we ask for items like bank information so you can be paid. In the event you get hurt or we need to reach out to your emergency contact, we need to know who to call. When you’re at our office, we want to keep you safe and provide efficient resources, including IT and Human Resources support. If you reach out to us with questions about benefits, we want to give you the best service—so we may ask for personal information to get you the right responses. We also need your information to support our HR operations generally (administration, communication, running diversity and inclusion initiatives, worker safety, absence management, helpdesk and IT support services), and to comply with the law (for example, for fraud prevention, network and information security, to disclose to affiliated organizations for administrative tasks, Worker monitoring for safety or management, whistleblowing requirements, for the establishment, exercise, or defense of legal claims, to perform internal and/or external or governmental compliance investigations or audits, and for research purposes). Finally, various governments also require that we collect information like your Social Security number to ensure we follow all laws and fulfill our obligations and get you your money legally.


Note that it’s possible that your information will be shared, processed, and kept in a country different from where you live. To help keep your personal data safe, we keep informed of local laws and take best efforts to follow them.

3. HOW WE DISCLOSE YOUR INFORMATION

Vendors and other companies we work with, like those we use for HR and IT needs, may require that we provide them with your information. There may also be situations where we have to share personal information with our company affiliates and subsidiaries to support our business. Similarly, if we’re served with a court order, a subpoena, or receive a proper request from law enforcement, we would have to comply with that. We might also share your information if we reasonably believe it is necessary to protect the rights or safety of you or the team.


Note that if something were to happen to PeopleConnect as a company, such as us being involved in an actual or proposed merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, that might entail your personal information being seen by or transferred to an outside party (such as an investor).

4. YOUR CHOICES AND RIGHTS

So, what are your rights and obligations? For example, if you’re thinking about joining PeopleConnect, but you don’t want to know about future job opportunities, and only want us to use your information for the purpose of considering your suitability for the specific position for which you applied, you can let us know that by emailing Human Resources at the email listen below. In some instances, you can opt out of certain uses and disclosures of your personal information.


Depending on where you live, you also can request confirmation of whether we are processing your personal information, get a copy of that data, receive an electronic copy of the data you gave us, correct inaccurate information we have, object to or restrict the use of your data, or ask for your personal information to be deleted. In as much as we can do all of that while complying with our legal and other obligations, we will do so. Note that we’ll also take steps to verify your identity before fulfilling your request. You can also file a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

5. WHAT SHOULD I KNOW ABOUT INFORMATION SECURITY?

We’ve all seen news of data leaks from other companies—and those are unfortunate when they happen. Please know that we take seriously the trust you place in us to protect your information. We work hard to ensure that your information is kept secure and in accordance with this Privacy Notice. That said, despite best efforts and considering all potential situations, there exists the possibility of unauthorized disclosure. If that does happen, we’ll work with you and help you to be consistent with our legal obligations. However, to the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure of your information.


Various resources and sites at PeopleConnect may contain links to third-party websites/applications and other websites/applications may reference or link to PeopleConnect. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application you interact with. We do not endorse, screen, or approve these third-party services, and are not responsible for their privacy practices or content. Visiting these other websites or applications is at your own risk.

6. CHANGES TO THIS PRIVACY NOTICE AND PRACTICES

To ensure that this Privacy Notice continues to protect both you and PeopleConnect, we may revise it from time to time in our sole discretion. In the event we make a material change, we’ll get your consent where required by law.


If you have any questions about our practices or this Privacy Notice, please feel free to reach out to us by emailing [email protected] or by contacting our Human Resources Department.