# Applicant and Employee Privacy Policy

**Purpose**  
Trust & Will has created this policy to outline its collection, use, and protection of personal information as it relates to those who apply to be considered for employment with Trust & Will (“Applicants”) and individuals who are employed by Trust & Will (“Employees”).

**Defined Terms**  
- **“Applicant”** means an individual who has submitted information to Trust & Will via a resume, job application, and/or internal referral, or who has otherwise provided consent to be considered a candidate for a position.
- **“Employee”** means a full or part time Trust & Will employee, director, Board member, as well as independent contractors, and interns.
- **“Personal Information”** means any information that relates to an identified or identifiable natural person. Data that includes personal information is considered “Personal Data”.
- **“Sensitive Personal Information”** means Personal Information that reveals a government issued identification number, financial account numbers (including credit or debit card numbers), biometric and/or geolocation information, information pertaining to health and any information that reveals an individual’s sexual orientation.
- **“Processing”** means the collection, storage, and use of data for any specific purpose. Trust & Will works with Service Providers who process your personal information on behalf of Trust & Will, to complete its People Operations tasks like processing payroll, and providing health care and retirement benefits.
- **“Service Provider”** means an outside entity or person with whom Trust & Will might work to facilitate its People Operations, including software providers who support the application process, as well as payroll and employee benefits management.

**What Personal Data does Trust & Will collect about Applicants and/or Employees?**  
During your application process, Trust & Will collects personal information about you such as: your name, contact information including phone number, email, and mailing address if provided, employment history including business affiliations if provided, and references.  
During your employment, Trust & Will collects personal information and sensitive personal information about you including your name, address, date of birth, phone number, email address, financial account information (bank routing number and account number), social security number, as well as the following information about any dependents you wish to add to your health benefits: name, address, social security number, and date of birth.

**How is Data Collected?**  
You will be prompted to provide information during the application and onboarding processes. Some information is provided directly to Trust & Will for internal use, while other information may be shared directly with a Service Provider who handles specific aspects of Trust & Will’s People Operations. Some information is mandatory to provide because it enables Trust & Will to perform a mandatory People Operations function like issuing your paycheck, or verifying your eligibility for employment.

**How Trust & Will processes and uses Employee Personal Data**  
Trust & Will uses Employee Personal Data to fulfill its necessary functions as an employer or prospective employer. Those functions include but are not limited to: reviewing information to determine suitability for a particular job opening, facilitating payroll, tracking performance, and offering employee benefits such as health care, retirement, and use of service providers to facilitate your role and responsibilities as an employee. Trust & Will does not sell your personal information for any reason, but may share your name and email address to ensure you receive the correct benefits, and have the tools you need to perform the functions of your position.  
We also use your information to comply with applicable legal and regulatory requests and obligations, and to seek legal advice related to legal claims, allegations, and investigations.

**Legal Basis for processing data**  
Trust & Will requires employees to produce Personal Information and Sensitive Personal Information in order to fulfill its obligations as an employer, such as processing payroll, and in providing health and other employee benefits. Such information is used in accordance with applicable law, and is never sold by Trust & Will for any reason.

**Service Providers**  
Trust & Will uses Service Providers to support its People Operations and facilitate performance of its roles and obligations as an employer. Generally, where a Service Provider is used, you will be asked to provide consent at the time the data is collected. In situations where Trust & Will enters your information on your behalf, you consent to the use of your personal information for the specific function provided by the Service Provider. Trust & Will will only provide the information required to fulfill the function.

**Categories of collected data and what they mean:**  
- **Identification Data** may include name, date of birth, government identifiers including SSN.
- **Contact Data** may include home address, telephone number, email addresses, emergency contact information.
- **Hiring Data** may include applicant qualifications, past employment, interview notes, references, immigration status and documentation.
- **Employment Data** may include qualifications for a professional role, role changes, resignation and termination records, performance records, etc.
- **Benefits Data** may include information relating to employment benefits provided, health information, vacation requests, leave requests.
- **Performance and Management Data** includes evaluations or reviews, disciplinary actions, and training plans.
- **Financial Data** may include banking information, payroll information, salary, expenses.
- **Systems and Asset use Data** may include login information, security logs, internal communications.
- **Demographic data** may include date of birth, gender, race/ethnicity, veteran status.
- **Other information Data** may include hobbies and interests, social preferences, participation in corporate initiatives.

**How and Why your personal information is collected/processed:**  
Trust & Will collects and/or processes data for the following categories and purposes:  
- **Purpose: Hiring**: Supporting the determination of candidate fit.
- **Purpose: Compensation and Benefits**: Manage payroll, taxes, and benefits access.
- **Purpose: Training**: Develop resources for employee training.
- **Purpose: Performance Reviews**: Review job performance and developmental support.
- **Purpose: Legal Requirements**: Ensure legal compliance with labor laws.
- **Purpose: Contacts**: Facilitate communication amongst employees.
- **Purpose: Security and IT**: Maintain security of systems and network.
- **Purpose: Emergencies**: Establish emergency contacts.
- **Purpose: Investigations**: Monitor and detect illegal activity.
- **Purpose: DEI initiatives**: Support diversity initiatives.
- **Purpose: Day to day business**: Reasonable performance of operations.

**California privacy rights:**  
The following rights apply to employees who are residents of California.  
- **Access to Personal Data**: Employees may request disclosure of their collected personal information.
- **Retention/Deletion of Personal Data**: Employees may request deletion of personal data with some restrictions.
- **The right to opt out of the sale of your personal information**: Employees can request to refrain from selling personal information.
- **The right to nondiscrimination** for exercising CCPA/CPRA rights.

**Applicability of other Trust & Will privacy policies**  
If you create an account, your information will be held subject to our consumer privacy policy.

**Changes to this policy**  
We will update you regarding any material changes that impact your rights.  
Updated: September 18, 2023