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Communications Test Design, Inc. Employee Privacy Notice

Last updated January 1, 2023

This Employee Privacy Notice (“Privacy Notice”) describes the collection, use, and sharing of your personal information through the course of your tenure with Community Test Design, Inc. (“CTDI,” “we,” “us,” or “our”) and its subsidiaries and affiliates.

1. APPLICABILITY OF PRIVACY NOTICE

This Privacy Notice applies to personal information collected from personnel of CTDI. The term “personnel” includes U.S. employees and those that work on a non-permanent basis, such a temporary and contract workers, independent contractors, consultants, and interns.

HIPAA Notice

The information that you provide to us for the purposes of obtaining health insurance will also be subject to each health care providers’ HIPPA Notice of Privacy Practices. Our HIPPA Notice which describes our use and disclosure of your protected health information is posted at each work location or you can access it by contacting your local Human Resources representative or ambassador.

1. COLLECTION AND USE OF PERSONAL INFORMATION

During the course of your tenure with CTDI, we collect personal information about you, as well as personal information related to your spouse, dependent(s), or family member(s) (collectively, “dependents”), where there is a legitimate reason to do so in connection with our relationship with you. To the extent we collect personal information on your dependents, you should inform your dependents that you are providing this information to us and why, and make sure that it is acceptable to them.

Through your tenure with CTDI, we will collect personal information to:

• Administer salary and benefits: We collect from you as well as from governmental entities and benefit providers your identifiers (name, telephone number, physical address, email address (if provided), date of birth, employment identification number, Social Security number, insurance policy number, driver’s license number, state identification number, and passport (if provided)), protected classifications (marital status, age, race, sex, gender, citizenship status, immigration status, disability status (if provided), and veteran status (if provided)), and financial information (bank account and routing number). We use this information to administer salary and benefits, such as medical, dental, and retirement benefits. We also collect from you identifiers (name, date of birth, and Social Security number) of dependents. We use the dependent information to process their eligibility as your dependents for the purpose of benefits.

• Administer reimbursements: We collect, from you, your identifiers (name and physical address), financial information (bank account and routing number), and corporate financial information (CTDI-issued credit card), and details of travel or expenses incurred in connection with your tenure. We use this information to issue reimbursements.

• Career Development. We collect, from you, your identifiers (name) and professional information (federal identification authorizing work in the United States, licenses, credentials, employment history, educational history, resume/CV, disciplinary evaluations, performance reviews, terms and conditions of employment). We use this information to identify, deliver, and track training needs and outcomes, to help with career development, succession, planning, and workforce management and to manage professional requirements, certifications and memberships and to manage relationships with vendors.

• Conduct IT security and management: We collect, automatically, when you use Company systems, electronic network activity information (username, password, IP address, browsing history, search history, websites visited, and interactions with websites). We collect geolocation information (city, state, and country level geolocation data of the IP from workstations, and mobile data) and your business email address. We use this information to ensure compliance with CTDI’s policies and procedures, to protect data assets of CTDI, for authentication purposes, and to provide IT support.

• Conduct performance reviews: We collect from you your identifiers (name) and professional information (licenses, credentials, employment history, educational history, and resume/CV). We use this to conduct performance reviews and evaluate personnel for internal opportunities.

• Conduct background checks. We collect both from you and from third-party background check vendors your identifiers (name, date of birth, and Social Security number). We use this information to conduct background checks for employment purposes.

• Create a personnel file: We collect, from you your identifiers (name, date of birth, telephone number, physical address, date of birth, physical characteristics or description, and primary language) and professional information (licenses, credentials, employment history, educational history, resume/CV, disciplinary evaluations, performance reviews, terms and conditions of employment, salary (including retirement accounts, pensions, or insurance coverage), skills, qualifications, experience, travel history, professional/occupational memberships, and time-off work). We use this personal information to maintain your personnel file, create personnel biographies, and for internal recruitment purposes (assessing your eligibility for other positions within CTDI).

• Handle general human resources functions: We collect from you your identifiers (name, Social Security Number, personnel ID, email address, telephone number, and physical address) and emergency contact information. We use this information to handle general human resources functions, such as personnel support, termination, and emergency contact procedures.

• Employee engagement. We analyze the information provided to make inferences with respect to your individual preferences, behaviors, predispositions, characteristics, intelligence abilities and aptitudes.

• Facilitate visa sponsorship: We collect from you your identifiers (name, physical address, work address, and passport (if provided)) and your visa information (job title, salary offered, type of visa, eligibility basis and expiration date) and your dependents’ identifiers and visa information. We use this visa information to facilitate your employee visa sponsorship and for the purpose of maintaining your employment.

• Facilitate company sponsored event: We collect, from you, identifiers (name and date of birth) and COVID-19 test results of your dependents for the purpose of facilitating company-sponsored events. We use this information in order to mitigate the spread of COVID-19 at company-sponsored events.

• Issue tax forms: We collect from our third-party onboarding vendor your identifiers (name, physical address, and Social Security number) and tax information (withholding details). We use this information to issue tax forms and comply with tax reporting requirements.

• Monitor compliance with equal opportunities and anti-discrimination laws: We collect from you protected classifications (race, national origin, citizenship, sex, military or veteran status, and any disabilities you may have). We use this information to comply with our obligations under equal opportunity and anti-discrimination laws.

• Monitor work-related licenses and credentials: We collect from you as well as from educational institutions, personal and professional references your identifiers (name) and your professional information (licenses, credentials, employment history, educational history, and resume/CV). We use this information to manage work-related licenses and credentials.

• Provide on-site access: We collect from you your visual information (photographs). We use this for employee access badges to verify your identity and to grant physical access to CTDI facilities.

• Promote safety and security. We collect from you and automatically from closed circuit cameras your visual information (photographs, images, and video). We use the photographs and images verify compliance with policies, and to create security badges to promote the safety and security of employees, contractors, visitors, customers, and consumers.

• HOW WE SHARE YOUR PERSONAL INFORMATION

General Sharing

We share your personal information as follows:

Within CTDI. We share personnel personal information within CTDI and among its subsidiaries and affiliates to receive IT services/security, Human Resources, tax and accounting, and general business and employment purposes. Access to personal information is limited to those on a need-to-know basis.

With Service Providers. We will share your personal information with our service providers to assist us in managing and administrating your tenure. These service providers include IT support, human resource management software providers, health insurance, payroll, expense processing, benefits plan providers, and professional advisors (i.e., accountants, legal).

With Third Parties. We will share your personal information with third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, for risk management purposes, and to comply with our legal obligations.

During a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we will share personnel personal information.

Legal Purposes. We will share personal information where we are legally required to do so, such as response to court orders, law enforcement, or legal process including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our agreements or other contracts; to defend against legal claims or demands; or to comply with the requirements of any applicable law.

Sharing in the Preceding Twelve (12) Months

For Business Purposes. In the preceding twelve (12) months, CTDI has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

• We have disclosed your personal identifiers, protected classifications, professional or employment related information, internet or other electronic network information, and your customer records information to service providers that help us perform employment-related functions. These service providers include IT support, background check companies, payroll processors, expense processors, health insurance providers, and benefits providers.

• We have disclosed your personal identifiers and internet or other electronic network information to IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair errors that impair functionality.

• We have disclosed your personal identifiers and internet or other electronic network activity information to IT support to help us maintain the quality and safety of CTDI devices or to improve, upgrade, or enhance CTDI devices.

For Sale. CTDI does not sell personnel personal information.    

1. RIGHTS OF CALIFORNIA EMPLOYEES

The California Privacy Rights Act (CPRA) grants certain rights to California residents. If our processing of your personal information is subject to the CPRA, you are entitled to the following rights:

• Right to know/access: You have the right to request what personal information we have collected, used, disclosed, and sold about you. Below, there are details on how to exercise this right. You may only make a request for access twice within a 12-month period.

• Right to deletion: You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.

• Right to opt-out: You have the right to opt-out of the sale or sharing of your personal information to third parties. CTDI does not sell your personal information. CTDI does not have actual knowledge that it sells personal information of minors under the age of 16 years.

• Right to non-discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CPRA.

• Right to correct: You have the right to correct inaccurate personal information that we collect or maintain. If we believe the information in question is correct we will ask you to provide documentation if necessary to rebut our own documentation that the personal information is accurate.

• Right to limit use of sensitive personal information: You have the right to limit the use of how we use your sensitive personal information. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin.

To exercise your right to access or delete your personal information, you may submit a request by mail to the attention of Jodi Colello at the address below, by email to jcolello@ctdi.com, or by sending a message via https://www.ctdi.com/contact-us/ (drop down to “Employee Relations” as the “Reason for Contact”).  For all requests, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it.  If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. Only you, or an agent that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

1. SECURITY

We implement and maintain reasonable security measures to protect the personal information we collect and maintain. These security measures include encryption, access controls, employee training, and others developed in line with industry standards. However, no security measure or modality of data transmission over the internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.

1. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is subject to change at the sole discretion of CTDI. If we make any changes, we will announce those changes and we will indicate the date the changes go into effect. If we make any changes that materially affect your privacy rights, we will announce those changes by posting a notice at your place of work.

• CONTACT US

For questions about this Privacy Notice, please contact:

Communications Test Design, Inc.

Jodi Colello

1336 Enterprise Drive

West Chester, PA  19380

E-mail: jcolello@ctdi.com