Employee Privacy Policy
Contents
- Scope of this Policy
- Collection of Personal Information and Sensitive Personal Information
- Sources of Personal Information
- To Whom We Disclose Personal Information
- Reasons Why We Collect, Use, Retain, and Disclose Personal Information
- Retention of Personal Information
- Third Party Vendors
- Business Transfers
- Compliance with Law and Safety
- Passwords
- Employees and Their Family Members, Dependents, and Beneficiaries Under the Age of 16
- How We Protect the Information that We Collect
- Rights Under the CCPA and CPRA
- Consent to Terms and Conditions
- Changes to Our Privacy Policy
- Individuals With Disabilities
- Questions About the Policy
Scope of this Policy
TDS Logistics, LLC (the “Company”, “TDS”, or “we”) has developed this Privacy Policy out of respect for the privacy of our employees and their family members, dependents, and beneficiaries. This Policy describes the personal information we collect, both online and offline, about current employees and their family members, dependents, and beneficiaries.
This Privacy Policy applies only to information collected, used, or disclosed by the Company in the employment context and does not apply to other contexts, such as when you visit our public-facing website or engage with the Company as a client or customer. Interactions outside the employment context are subject to the privacy policy on our website.
Collection of Personal Information and Sensitive Personal Information
In the last 12 months, we have collected the following categories of personal information from or about employees and their family members, dependents, and beneficiaries. For each category of information, we identify below the categories of third parties, service providers, and contractors to whom we have disclosed the information in the last 12 months. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you a meaningful understanding of the types of information that may be collected within each category.
| Category | Personal Identifiers |
| Examples | Name, alias, social security number, date of birth, driver’s license or state identification card number, passport number, employee ID number, professional license number. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Name and employee ID number: Permanent. Otherwise, duration of employment plus 6 years. |
| Category | Contact Information |
| Examples | Home, postal or mailing address, email address, home phone number, cell phone number. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Permanent |
| Category | Account Information |
| Examples | Username and password for Company accounts and systems, and any required security or access code, password, or credentials allowing access to your Company accounts. |
| Disclosed To in Last 12 Months | IT, cybersecurity, and privacy vendors and consultants |
| Retention Period | Username: permanent; Password or security code: while in use + last several passwords used or 2 years, whichever is longer, and this may vary by system application |
| Category | Protected Classifications |
| Examples | Race, ethnicity, national origin, citizenship or immigration status, sex, gender, sexual orientation, gender identity, religious or philosophical beliefs, age, disability, medical or mental condition, military status, familial status, language, or union membership. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Physical Characteristics or Description |
| Examples | Information on your Driver’s License (such as eye color, hair color, height, weight), as well as information collected to the extent relevant for workplace investigations or for enforcement of Company policies on appearance and grooming (such as tattoos, piercings). |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Financial Information |
| Examples | Bank account number for direct deposit, credit card number, debit card number, or other financial account information. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Internet, Network, and Computer Activity |
| Examples | Internet or other electronic network activity information related to usage of Company networks, servers, intranet, shared drives, or Company-issued computers and electronic devices, including system and file access logs, security clearance level, browsing history, search history, and usage history. |
| Disclosed To in Last 12 Months | |
| Retention Period | 4 years, but it varies by system and there are often legal or business purposes for retaining this for a longer period. |
| Category | Geolocation Data |
| Examples | IP address and/or GPS location (latitude & longitude) recorded on Company-issued computers, and electronic devices, as well as timekeeping applications on cell phones that employees use to clock in and out and that log the geographic location at which each time entry was made. |
| Disclosed To in Last 12 Months |
|
| Retention Period | At least 4 years, but it varies by system and there are often legal or business purposes for retaining this for a longer period. |
| Category | Mobile Device Data |
| Examples | IP address and/or GPS location (latitude & longitude) recorded on Company-issued computers, electronic devices, and vehicles, as well as timekeeping applications on cell phones that employees use to clock in and out and that log the geographic location at which each time entry was made. |
| Disclosed To in Last 12 Months | IT, cybersecurity, and privacy vendors and consultants |
| Retention Period | At least 4 years, but it varies by system and there are often legal or business purposes for retaining this for a longer period. |
| Category | Mobile App Access and Usage Information |
| Examples | Username and password, account history, usage history, file access logs, and security clearance level. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Username kept indefinitely; passwords while in use + last several passwords used or for 2 years, whichever is longer; rest of this category for at least 4 years. |
| Category | Visual, Audio or Video Recordings |
| Examples | Your image when recorded or captured in surveillance camera footage or pictures of employees taken in the workplace or at a Company function or event; footage from inward facing cameras in Company trucks. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Surveillance footage: 90 days Otherwise, duration of employment plus at least 6 years |
| Category | Pre-Hire Information |
| Examples | Information provided in your job application or resume, information gathered as part of background screening and reference checks, pre-hire drug test results, job interview notes by persons conducting job interviews for the Company, information contained in candidate evaluation records and assessments, information in work product samples you provided, voluntary disclosures by you, and Wage Opportunity Tax Credit (WOTC) information. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Employment History |
| Examples | Information regarding prior job experience, positions held, names of prior supervisors, and when permitted by applicable law your salary history or expectations. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Education Information |
| Examples | Information from resumes regarding educational history; information obtained from transcripts or records of degrees and vocational certifications obtained. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Professional or Employment-Related Information |
| Examples | Information contained in your personnel file and in other employment documents and records, including information contained in the following types of records: new hire or onboarding records, I-9 forms, tax forms, time and attendance records, non-medical leave of absence records, workplace injury records, safety records, performance evaluations and records, disciplinary records, investigatory records, training records, licensing and certification records, compensation and health benefits records, COBRA notifications, business expense records, and payroll records. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years, unless related to hazardous exposure records required by OSHA to be retained for at least 30 years. We retain permanently a record of your name, last position held, and dates of employment |
| Category | Facility & Systems Access Records |
| Examples | Information identifying which employees accessed secure Company facilities, systems, networks, computers, and equipment and at what times using their keys, login credentials, or other security access method. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Depends on legal and business needs. |
| Category | Medical and Health Information |
| Examples | Medical information contained in such documents as doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, ergonomic assessment and accommodation records, and correspondence with you and your medical or mental health provider(s) regarding any request for accommodation or medical leave of absence, as well as information in post-hire drug test results, and information related to symptoms, exposure, contact tracing, diagnosis, testing, or vaccination for infectious diseases (e.g., COVID-19), pandemics, or other public health emergency. This includes medical information and health benefits information for dependents and beneficiaries. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years, unless related to hazardous exposure records required by OSHA to be retained for at least 30 years |
| Category | Travel Information |
| Examples | Information regarding business travel, vacation, and personal travel plans |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Family Information |
| Examples | Contact information for family members listed as emergency contacts, contact information for dependents and other dependent information, medical and health information for family members. |
| Disclosed To in Last 12 Months |
|
| Retention Period | Duration of employment plus 6 years |
| Category | Contents of Personal Communications where the Company is not the intended recipient |
| Examples | If you use Company email, phones, computers, or other Company systems for personal communications where the Company is not the intended recipient of the communication, the Company retains these communications in the ordinary course of managing its communication and computer systems and pursuant to the Company’s data retention practices. Employees have no expectation of privacy with respect to any communications or data they send, receive, access or store on any company computer or system, including any personal communications. The Company may monitor, access, review and use all such communications and data for lawful business purposes detailed below, including to manage and evaluate employee performance and make employment decisions. |
| Disclosed To in Last 12 Months | Not Disclosed |
| Retention Period | Email accounts are retained for at least 4 years after they are no longer active, unless related to a category of data identified above that requires a longer retention period. |
Of the above categories of Personal Information, the following are categories of Sensitive Personal Information we may collect from or about employees:
- Personal Identifiers (social security number, driver’s license or state identification card number, passport number)
- Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account)
- Protected Classifications (racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, union membership, or sexual orientation)
- Medical and Health Information
- Geolocation Data (IP address and/or GPS location, latitude & longitude)
- Contents of Personal Communications (contents of mail, email, and text messages where the Company is not the intended recipient)
Personal information does not include:
- Publicly available information from government records.
- Information that a business has a reasonable basis to believe is lawfully made available to the general public by the employee or from widely distributed media.
- Information made available by a person to whom the employee has disclosed the information if the employee has not restricted the information to a specific audience.
- De-identified or aggregated information.
Sources of Personal Information
We may collect your personal information from the following sources:
- You, the employee, when you voluntarily submit information for employment purposes
- Company-issued computers, electronic devices, and vehicles
- Company systems, networks, software applications, and databases you log into or use in the course of performing your job, including from vendors the Company engages to manage or host such systems, networks, applications or databases
- Surveillance cameras at our physical locations
- Drug testing and physical testing providers and vendors
- Credit and Consumer reporting agencies
- HR support vendors, including administrators of benefits, workers’ compensation, unemployment claims, payroll, timekeeping, expense management
- Social media platforms
- Professional employer organizations
- Recruiters
- Staffing agencies
- Personal references and former employers
- Our other employees, contractors, vendors, suppliers, guests, visitors, and customers based on your interactions with them
- Our affiliates, including parent, subsidiary, or sister companies
To Whom We Disclose Personal Information
We may disclose your personal information to the following categories of service providers, contractors, or third parties:
- Financial institutions
- Government agencies
- Benefits administrators and vendors, including third party administrators, 401K administrators, workers’ compensation and unemployment administrators, and wellness vendors
- Insurance carriers, administrators, and brokers
- Employee tracking and talent management systems
- Professional employer organizations, recruiting firms, and/or staffing agencies
- Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS)
- Consulting and investigation firms, including human resources consultants, safety consultants, and workplace investigators
- Our corporate customers (meaning an entity, as opposed to a natural person)
- IT, cybersecurity, and privacy vendors and consultants
- Accountants and CPAs
- Our affiliates, including parent, subsidiary, or sister companies
Reasons Why We Collect, Use, Retain, and Disclose Personal Information
We may collect, use, retain, and disclose your personal information for any of the following business purposes:
- To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to become an employee, we will use that Personal Information in connection with your employment.
- To comply with local, state, and federal law and regulations requiring employers to maintain certain records (such as immigration compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records).
- To manage and process payroll and/or Company travel and expenses.
- To validate an employee’s identity for payroll and timekeeping purposes.
- To maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
- To manage workers’ compensation claims.
- To administer, manage, and maintain group health insurance benefits, 401K and/or retirement plans, and other Company benefits and perks.
- To manage employee performance of their job duties and/or employee conduct, including by engaging in lawful monitoring of employee activities and communications when they are on duty, on Company premises, or utilizing Company internet and WiFi connections, computers, networks, devices, software applications or systems.
- To conduct workplace investigations (such as investigations of workplace accidents or injuries, harassment, or other misconduct).
- To evaluate job applicants and candidates for employment or promotions.
- To obtain and verify background checks on job applicants and employees and to verify employment references.
- To evaluate, make, and communicate decisions regarding an employee’s employment, including decisions to hire, terminate, promote, demote, transfer, suspend or discipline.
- To communicate with employees regarding employment-related matters such as upcoming benefits enrollment deadlines, action items, availability of W2s, and other alerts and notifications.
- To grant employees access to secure Company facilities and maintain information on who accessed the facility.
- To track employee movement and activity throughout Company facilities and keep the facilities secure.
- To engage in marketing efforts on behalf of the Company.
- To track and record sales and other transactions with our customers.
- To implement, monitor, and manage electronic security measures on Company internet and WiFi connections, computers, networks, devices, software applications or systems, as well as on employee devices that are used to access Company internet and WiFi connections, computers, networks, devices, software applications or systems.
- To engage in corporate transactions requiring review or disclosure of employee records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
- To communicate with an employee’s family or other contacts in case of emergency or other necessary circumstance.
- To manage employee recognition programs.
- To promote and foster diversity, equity, and inclusion in the workplace.
- To remain competitive in offering a variety of special discounts and benefits to employees.
- To comply with our contractual obligations.
- To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company.
- To improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
- To detect security incidents involving potentially unauthorized access to and/or disclosure of Personal Information or other confidential information, including proprietary or trade secret information and third-party information that the Company receives under conditions of confidentiality or subject to privacy rights.
- To protect against malicious or illegal activity and prosecute those responsible.
- To prevent identity theft.
- To verify and respond to consumer requests under applicable consumer privacy laws.
We do NOT and will not sell your personal information in exchange for monetary or other valuable consideration. We do not share your personal information for cross-context behavioral advertising.
We do NOT and will not use or disclose your sensitive personal information for any purposes that give rise to a right to limit the use or disclosure of your sensitive personal information under the California Consumer Privacy Act (CCPA), if it applies and you are a California resident.
Third-Party Vendors
We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail and payroll services. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose.
Retention of Personal Information
We will retain each category of personal information in accordance with our established data retention schedule as indicated above. Some of the retention periods in the retention schedule above are measured from a particular point in time that has not occurred yet, such as the end of employment or end of a relationship (whether business, contractual, or transactional) plus a certain number of years. Where no particular event is defined in the retention schedule as the point from which the retention period is measured, we will measure the retention period from either (1) the date the record or data was collected, created, or last modified, (2) the date of the particular transaction to which the record or data pertains, or (3) another triggering event that is determined to be reasonable and appropriate based on the nature of the data and the legal/business needs for its continued use.
In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statute of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.
We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.
Business Transfers
In the event we sell or transfer a particular portion of our business assets, employee information may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, employee information may be transferred as part of the acquisition.
Compliance with Law and Safety
We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.
Passwords
The personal data record created through your registration for your various Company accounts, including to access Company email, computers, networks, databases, and timekeeping and payroll applications, can only be accessed with the unique password associated with those records. To protect the integrity of the information contained in those records, you should not disclose or otherwise reveal your passwords to third parties.
Employees and Their Family Members, Dependents, and Beneficiaries Under the Age of 16
We do not knowingly sell or share the personal information of employees or any of their family members, dependents or beneficiaries under 16 years of age.
How We Protect the Information that We Collect
The protection of the information that we collect about employees is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:
- We keep automatically collected data and voluntarily collected data separate at all times.
- We use internal encryption on all data stores that house voluntarily captured data.
- We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
- We restrict access to private information to those who need such access in the course of their duties for us.
Rights Under the CCPA and CPRA
This section of the Privacy Policy applies only to California residents. If you are a California resident, you have the following rights pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):
- Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, shared or sold about you, (2) the categories of sources from which the personal information was collected, (3) the business or commercial purpose for collecting, selling, or sharing this information, and (4) the categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose;
- Right to Access. The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected from or about you;
- Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we have collected from you, subject to certain exceptions;
- Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you;
- The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
- The right to not be discriminated or retaliated against for exercising any of the above rights.
You Can Submit Any of the Above Types of Requests by Any of the Options Below:
- Send your request by email to privacy@tds-logistics.com.
- Call our privacy toll-free line at (888) 391-8126.
How We Will Verify That it is Really You Submitting the Request:
If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular information in our possession, which depends on the nature of your relationship and interaction with us.
Responding to your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests
Upon receiving a verifiable request from a California resident, we will confirm receipt of the request no later than 10 business days after receiving it. We endeavor to respond to a verifiable request within forty-five (45) calendar days of its receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
For a request to correct inaccurate personal information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessarily information at the time that you make the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we cannot comply with a request, if applicable.
If You Have an Authorized Agent:
If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either: (a) execute a valid, verifiable, and notarized power of attorney; or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf. We will also contact you and ask you for information to verify your own identity directly and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.
Consent to Terms and Conditions
By entering into an employment relationship with TDS Logistics LLC, you consent to all terms and conditions expressed in this Privacy Policy.
Changes to Our Privacy Policy
As our services evolve and we perceive the need or desirability of using personal information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check www.tds-logistics.com/privacy/employee frequently to see the current Privacy Policy in effect and any changes that may have been made to them. If we make material changes to this Policy, we will post the revised Policy and the revised effective date on www.tds-logistics.com/privacy/employee. Please check back here periodically or contact us at the address listed at the end of this Policy.
Individuals With Disabilities
This Policy is in a form that is or will be made accessible to employees with disabilities.
Questions About the Policy
If you have any questions about this Privacy Policy, please contact us at privacy@tds-logistics.com or call (888) 391-8126.
**This policy was last updated February 11th, 2025.
