Privacy Rights Portal

California Workforce Privacy Notice

Last Updated: March 2024 

Introduction

RoadSafe Traffic Systems, Inc. (RoadSafe, “we,” or “us”). understands the importance of protecting the privacy of our job applicants and workforce. 

This Workforce Privacy Notice (“Privacy Notice”) is directed to RoadSafe job applicants and Workforce Members who reside in California. It acknowledges the California Consumer Privacy Act and explains our information collection practices during your recruitment, during and after your employment, and when you apply for a job or submit a resume online. This Privacy Notice includes the rights and choices that you have in relation to how we collect, use, retain, and disclose your Personal Information. Please see the section below titled Your Privacy Rights and Choices; California Residents for additional information. This Privacy Notice applies to prospective, current, and former employees and interns, independent contractors, and other temporary workers of RoadSafe (“Workforce Members”). However, this Privacy Notice is not intended to and shall not be construed to create an employment relationship. Terms that are capitalized are defined within this Privacy Notice.

For purposes of this Privacy Notice, Personal Information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household.  Personal Information does not include anonymous, de-identified or aggregated data that is not associated with a particular individual. Personal information also does not include publicly available information, such as information obtained from government records or information that has otherwise been lawfully made available to the public. This Privacy Notice explains how RoadSafe collects and processes Personal Information, including internally, as between business units and departments, and when disclosing such information externally for a business purpose. We also explain the categories of Personal Information we maintain about you, the sources from which we receive Personal Information, and the categories of recipients to whom Personal Information may be disclosed. We describe certain privacy rights and choices you may have related to the Personal Information we hold, including how to request access to, correction, or deletion of your Personal Information. 

Categories of Personal Information We Collect

We may collect one or more categories of Personal Information and Sensitive Personal Information listed in the tables below. We typically collect Personal Information or Sensitive Personal Information, as applicable, directly from you. For example, when you visit the “Careers” page on our website or otherwise submit information in connection with a job application (e.g., online or at a job fair, etc.), we receive and store that information in our internal employment records. 

In limited circumstances, we may receive your Personal Information from third parties. Those third parties may include your current or former employers; recruiting agencies; job boards, social media platforms, such as LinkedIn or ZipRecruiter; government agencies; courts; or background/guardian check providers. Depending on your interactions with us, we may also obtain information about you from digital marketing or advertising networks, internet service providers, or data analytics providers. 

The table below lists categories of Personal Information we may collect, and whether we have collected those categories of information from Workforce Members within the last twelve (12) months:

Category	Examples	Collected
Identifiers	Full name, address, contact information, online identifiers, Internet Protocol address, email address, account name, signature (electronic or handwritten), or government-issued identifiers.	YES
Personal Information categories listed in California Customer Records statute (Cal. Civ. Code §1798.80(e))	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information.	YES
Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, , pregnancy or childbirth and related medical conditions), veteran or military status.	YES
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	NO
Biometric Information	Activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
Internet or other electronic network activity information	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
Geolocation Data	Time, physical location, or movement (when related to use of or access to a RoadSafe-owned device or application, the RoadSafe network, or a RoadSafe office location).	YES
Sensory Data	Audio, electronic, visual, or similar information, such as audio and video surveillance recorded in RoadSafe-owned vehicles.	YES
Professional or employment-related information.	Current or past job history or performance evaluations.	YES
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
Inferences drawn from other personal information	Information gathered through employee evaluations such as details regarding a person’s characteristics, predispositions, behavior, aptitudes, intelligence, and abilities.	YES

The table below lists categories of Sensitive Personal Information and whether we have collected those categories of information from Workforce Members within the last twelve (12) months:

Category	Example	Collected
Government Identifiers	Social Security number, driver’s license, state identification card, or passport number	YES
Complete Access Credentials	Account log-in credentials, financial account details for direct deposits, daily pay debit cards, or other payment card numbers in combination with any required security or access code, password, or credentials allowing access to an account.	YES
Precise Geolocation	GPS coordinates in fleet vehicles derived from a device and used or intended to be used to locate an individual within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.	YES
Racial or ethnic origin	Records related to a Workforce Member’s accommodation request	YES
Message Contents unless RoadSafe is the intended recipient	The contents of mail, email, or text messages sent from RoadSafe’s domain but directed by a Workforce Member to any person or business other than RoadSafe. This may occur, for example, if Workforce Members use their RoadSafe email address to send personal communications.	YES
Genetic Data	Biological samples concerning genetic material, such as DNA or chromosomes	NO

Why We Collect Your Personal Information

We collect and use Personal Information, including Sensitive Personal Information, for the business purpose of administering your employment or work with us including:

• To process payroll and other human resources requests;
• To administer employee benefits, including group health insurance, life insurance, and 401Ks;
• To maintain and update employment records; 
• To process Workers’ Compensation claims;
• To maintain our commercial insurance policies; 
• To obtain and verify background checks, motor vehicle records (MVRs), and guardian checks (i.e., sex offender registry checks);
• To comply with federal and state laws or other legal requirements, such as audits or other requests by government agencies such as the Departments of Labor or Transportation and the Occupational Safety and Health Administration;
• To perform drug trusts and otherwise verify qualifications for employment; and
• To protect and evaluate the safety of our drivers, vehicle fleets, and work sites.

We do not knowingly collect Personal Information from children under the age of 16 without parental or guardian consent. If a child under the age of 16 has provided us with Personal Information we ask that a parent or guardian contact us so that the information can be deleted.

Sources of Personal Information Collection

We obtain the Personal Information we collect from the following categories of sources:

1. Directly and indirectly from your activity on our website (https://www.roadsafetraffic.com). For example, from submissions through our Careers page or website usage details collected through cookies or other website technologies. Please note, however, that our online Careers Center is hosted externally by Ascentis, a UKG Company. We encourage you to review Ascentis’s Privacy Policy for details regarding its information collection practices.
2. From third parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare compliance reports for projects that receive government funding.

How We Use Personal Information

The following table describes how we use the Personal Information or Sensitive Personal Information, as applicable, that we collect from our Workforce Members:

Use/Purpose	Employees	Job Applicants	Independent Contractors
Comply with applicable laws and regulations.	YES	YES	YES
Recruit and evaluate job applicants, candidates, and independent contractors for employment or independent contractor engagements.	YES	YES	YES
Conduct background checks and guardian checks.	YES	YES	YES
Manage your employment record and relationship with us, including for: the onboarding processes; timekeeping, payroll, and expense report administration; benefits administration; training and development requirements; the creation, maintenance, and security of your online employee accounts; reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill; workers’ compensation claims management.  job performance, including goals and performance reviews, promotions, discipline, and termination; and other human resources and administrative purposes.	YES	NO	YES (as applicable)
Solicit and manage customer relationships and engagements including:  staffing customer projects  marketing our services, capabilities, and areas of expertise.  responding to diversity, equity, and inclusion data inquiries, such as in a request for proposal (RFP)	YES	NO	YES
Manage your contract relationship with us, including for: payment administration;  the creation, maintenance, and security of your online accounts; and reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill.	YES	NO	YES
Manage and monitor an individual’s access to and use of our facilities, fleet vehicles, equipment, and systems.	YES	NO	YES
Conduct internal audits and workplace investigations.	YES	NO	YES
Investigate and enforce compliance with and potential violations of our policies and procedures.	YES	NO	YES
Engage in corporate transactions requiring the review of employee, applicant, or independent contractor records, such as for evaluating potential mergers and acquisitions.	YES	YES	YES
Maintain commercial insurance policies and coverages, including for life and health, workers’ compensation, general liability, errors and omissions, cyber and other liability insurance.	YES	NO	YES
Perform workforce analytics, data analytics, and benchmarking.	YES	YES	YES
Administer and maintain our operations, including for safety purposes.	YES	YES	YES
Respond to government or other customer requests for information regarding the demographic composition of our workforce.	YES	YES	YES
Exercise or defend our legal rights and those of our employees, affiliates, customers, contractors, and agents.	YES	YES	YES

Disclosures of Personal Information

We may disclose Personal Information or Sensitive Personal Information, as applicable, to the following categories of recipients for a business purpose: 

1. Benefits Administrators and Insurance Providers
2. Customers
3. Government Agencies
4. Other Government Entities, including Taxing Authorities and Auditors 
5. Law Enforcement Agencies 
6. Service Providers
7. Parties to litigation involving RoadSafe

We will only disclose your Personal Information to third parties where required by law or to assist in furthering our business processes outlined in this Privacy Notice. Several of our employment-related business processes are supported by service providers who are contractually restricted to perform specific business functions as instructed by RoadSafe. These processes relate to: 

• Background checks and other employment eligibility assessments
• Drug tests 
• Employee benefits administration and annual census reporting
• File sharing, data storage, or data hosting
• Incident and injury reports 
• Online chat or messaging providers
• Payroll
• Workers’ compensation claims

We require our service providers to implement appropriate security measures to protect your Personal Information. We do not permit those providers or other third parties to process or use your Personal Information for any purpose other than those specified in our service agreements or otherwise instructed by us. Our service providers may be located outside of your state of residence or the United States.

Other Disclosures Permitted or Required by Law

We may also disclose your Personal Information for the following additional purposes, where permitted or required by applicable law:

• To other members of our company (including outside of your home state) for the purposes set out in this Privacy Notice or as necessary to administer the application, recruitment process, employment or contractual relationship.
• To comply with our legal obligations or other valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your Personal Information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Information necessary to accomplish the specific purpose of the request.
• To protect our legal rights and property, including the safety of our premises and work sites.
• During emergency situations or where necessary to protect the safety of persons or to notify emergency contacts.
• In the event of a merger, business transfer, or other change in ownership.
• If the Personal Information is publicly available.
• For additional purposes with your consent where such consent is required by law.

Data Security

Maintaining the security of Personal Information is very important to us. We maintain reasonable administrative, technical, and physical safeguards to protect the confidentiality, integrity, and accessibility of Personal Information. 

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or information systems, you are responsible for keeping that password confidential. Password sharing is strictly prohibited by RoadSafe. 

Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted to our website or information systems via the Internet. Any transmission of Personal Information is at your own risk. 

De-Identified Data and Data Retention

Under certain circumstances we may anonymize or de-identify your Personal Information so that it cannot be associated with you, such as when aggregated data is requested or required by a government entity with regulatory authority over our operations. We reserve the right to use such data for any legitimate business purpose or to comply with our legal obligations without further notice to you.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve legal disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information at issue, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we process the Personal Information, and whether we can achieve those purposes through other means.

If you are offered and accept employment with the us, the Personal Information we collect during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with this Privacy Notice. If you do not become an employee, or, once you are no longer an employee of the Company, we will retain your Personal Information in accordance with our retention policy, applicable laws, and regulations.

Your Privacy Rights and Choices; Notice to California Residents

It is important for the Personal Information we maintain about employees and applicants to be accurate and current. Please keep us informed of any changes to your Personal Information that may occur during the recruitment process or your employment. 

Under California law and the laws of certain other jurisdictions, depending on where you reside, you may have certain rights with respect to Personal Information.  These rights include:

Your Right to Request Access to Information. To request access to your Personal Information and, where technically feasible, request a copy of your Personal Information. You may also have the right to obtain details about how we process or disclose your Personal Information.

Your Right to Request Review and Correction of Information. To request that we correct any inaccurate or incomplete Personal Information we have about you.

Your Right to Request Deletion of Information: To request that we delete your Personal Information. Please note that we may not be able to delete certain information depending on legal exceptions or obligations. Please see the De-Identified Data and Data Retention section above for more information about why we may retain your information.

Your Right to Restrict the Use and Disclosure of Information. To restrict how we use your information, including your Sensitive Personal Information.  For example, you may decline to allow RoadSafe to use your Personal Information for certain marketing purposes.  Note, however, that RoadSafe collects, uses, and discloses Personal Information solely for the operational purposes described in this Privacy Notice.  RoadSafe does not collect, use, or disclose Sensitive Personal Information to infer characteristics about you.

Your Right to Opt-Out of Targeted Advertising:  To opt out of any Personal Information disclosures for the purposes of targeted advertising. Please note that RoadSafe does not use or disclose our Workforce Members’ Personal Information for targeted advertising purposes. However, certain Personal Information may be collected automatically by website technologies when you visit our website.  

If you wish to make one of these requests, please visit our Privacy Rights Portal, or contact us at Partner@roadsafetraffic.com.   

We do not sell or share our Workforce Members’ Personal Information, including Sensitive Personal Information, to or with third parties. 

We may ask you to help us confirm your identity and verify your rights related to the Personal Information we hold. Applicable law may allow or require us to decline your request as to some or all of your Personal Information. If we cannot honor your rights request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any material updates. Where required or permitted by applicable law or regulation, we may process your Personal Information without your knowledge or consent. 

Contact Us

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format, please contact Human Resources at hrformsubmissions@roadsafetraffic.com or at (888) 650-7623.

If you have any questions about our processing of your Personal Information or would like to make an access or other rights request, please contact us at Partner@roadsafetraffic.com or submit your request via our Privacy Rights Portal. You may also submit a request to exercise your rights through an authorized agent, in which case your agent must present signed written permission to act on your behalf. You may be required to independently verify your identity with us and confirm that you have provided authorization to the agent.