TrustedTech Workforce Privacy Notice — United States

Trusted Tech Team, LLC

Effective Date: September 14, 2026

Applies to: Job applicants, employees, former employees, officers, directors, independent contractors and staffing agency personnel who provide services to Trusted Tech Team, LLC in the United States, and their emergency contacts, dependents, and benefit plan beneficiaries (collectively, “you” or “Workforce Members”).

This document is also our Notice at Collection for purposes of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). It is provided to you at or before the point at which we collect your personal information.

1. Purpose of This Notice

Trusted Tech Team, LLC (“TrustedTech,” “we,” “us,” or “our”) is a Delaware limited liability company with its principal place of business at 5171 California Avenue, Suite 250, Irvine, CA 92617. This Notice explains what personal information we collect about Workforce Members, why we collect it, who we share it with, how long we keep it, and the rights you have.

This Notice does not form part of any employment contract or offer of employment, and it does not create contractual rights or obligations. We may update it from time to time and will notify you of material changes.

If you are a customer, Site visitor, vendor representative, or other individual interacting with us outside the workforce context, the TrustedTech Privacy Notice — United States applies to you instead. If you are engaged by Trusted Tech Team Limited (UK or Ireland) or TrustedTech FZCO (UAE), a different notice applies to you.

2. Categories of Personal Information We Collect

We collect the following categories of personal information about Workforce Members. Not every category applies to every individual — for example, we collect far less about applicants who are not hired than about employees.

a. Personal and contact identifiers. Name, former names, preferred name, home and mailing address, personal and work email addresses, personal and work telephone numbers, date of birth, signature, photograph, employee identification number, and emergency contact details.

b. Government identifiers. Social Security number, taxpayer identification number, driver’s license or state identification card number, passport number, visa and immigration status, work authorization documentation, and citizenship or nationality where required for employment eligibility verification or export control compliance.

c. Recruitment and background information. Resume or CV, cover letter, application form responses, employment and education history, professional qualifications, certifications and licenses, references and reference checks, interview notes and assessment results, salary expectations, and the results of background checks, criminal history checks, credit checks, and drug or substance screening, in each case only to the extent permitted by applicable federal, state, and local law.

d. Employment records. Job title, department, work location, manager, start and end dates, employment status, work schedule and hours, timekeeping records, attendance and leave records, performance reviews and ratings, disciplinary records, promotions and transfers, training records, and records relating to grievances or investigations in which you are involved.

e. Compensation and benefits information. Salary or hourly rate, bonus and commission information, equity or incentive plan participation, payroll deductions and garnishments, bank account and direct deposit details, tax withholding elections and filings, expense reimbursement records, benefit plan enrollment and elections, and dependent and beneficiary information.

f. Health and leave information. Sick leave and medical leave records, medical certifications supporting leave or accommodation requests, workplace injury and workers’ compensation records, disability and reasonable accommodation records, and occupational health information. We collect this information only as necessary to administer leave, benefits, and accommodations and to comply with law, and we maintain it separately from your general personnel file where required.

g. Diversity information. Race, ethnicity, sex, gender, veteran status, and disability status, where you voluntarily provide it for equal employment opportunity and affirmative action reporting purposes. Provision of this information is entirely voluntary, and declining to provide it has no effect on your application, employment, or terms of engagement.

h. Company systems, device, and network information. Login credentials, authentication and multi-factor records, IP and MAC addresses, device identifiers, system and application access logs, email and messaging metadata and, where lawful and necessary, content, internet and network usage records, and records generated by our security, endpoint protection, and data loss prevention tools.

i. Physical access and premises information. Building access badge records, visitor logs, and security camera footage at our premises.

j. Recorded communications. Recordings of business calls, customer support sessions, and internal meetings, where recording is used for quality assurance, training, or record-keeping purposes and where notice and any legally required consent have been given. This also includes video and audio recordings of job interviews, together with the written transcripts and AI-generated summaries produced from them. Interviews are recorded by default; you are told this in the scheduling communication and again at the start of the interview, and you may decline recording before or at the start of the session without any effect on your candidacy. If you decline, the interview proceeds without recording.

k. Inferences. Inferences drawn from the above, such as performance trends and skills assessments.

l. Recruitment sourcing and scheduling data. Where we identify you as a potential candidate through a professional networking or sourcing platform, we collect the information available on your profile, including your name, location, current and previous roles, employer, education, skills, and any contact details you have made available; together with recruiter notes, ratings, project or pipeline membership, and our correspondence with you through the platform. We also collect the scheduling information you provide when booking an interview, including your name, email address, and availability. We collect this information whether or not you have applied to us.

We do not collect biometric information — including fingerprints, facial geometry, voiceprints, or retina or iris scans — from Workforce Members for timekeeping, physical access, or any other purpose. If this changes, we will update this Notice and provide any separate notice and consent required by applicable law before collecting such information. In this regard, we note that some applications may invite users to use facial recognition or fingerprints as an optional mechanism to access certain applications; however, such invitations are optional—based on user preference, and any biometric data collection is effected by the application provider and not by us; accordingly, please look to the privacy policies of such application providers for further information regarding their management of such biometric information.

Interview and meeting recordings are not biometric information. We record the audio and video of interviews and certain meetings, and we generate transcripts and summaries from them, but we do not create or use a voiceprint, a facial template, or any other biometric identifier from those recordings, and we do not use them for identification or verification.

3. Sensitive Personal Information

Some of the information above is “sensitive personal information” under the CCPA, including your Social Security, driver’s license, state identification card, and passport numbers; financial account information in combination with access credentials; account log-in credentials; racial or ethnic origin; health information; and the contents of your communications where we are not the intended recipient.

We collect and use sensitive personal information only for the purposes permitted by Cal. Civ. Code § 1798.121(d) and 11 C.C.R. § 7027(m) — including to perform the services reasonably expected by you, to ensure security and integrity, for short-term transient use, to perform services on our behalf such as payroll and benefits administration, and to verify or maintain the quality of our services. We do not use or disclose sensitive personal information to infer characteristics about you. Because of this, we are not required to offer, and do not offer, a “Limit the Use of My Sensitive Personal Information” option.

4. Sources of Personal Information

We collect personal information from:

  • You, through your application, onboarding paperwork, benefit elections, expense submissions, communications, and use of our systems;
  • References, former employers, and educational institutions you identify;
  • Background check and screening providers, consumer reporting agencies, and drug testing facilities, subject to the disclosures and authorizations described in Section 6;
  • Recruiters, staffing agencies, and job boards;
  • Professional networking and candidate sourcing platforms, including LinkedIn Recruiter, where we search for and review the profiles of potential candidates and correspond with them, whether or not they have applied;
  • Interview scheduling, video conferencing, and recording tools, which generate scheduling records, recordings, transcripts, and AI-generated summaries of interviews;
  • Benefits providers, insurers, and retirement plan administrators;
  • Government agencies, including tax authorities, immigration authorities, and workers’ compensation boards;
  • Our own systems and monitoring tools, including IT, security, badge access, and timekeeping systems;
  • Managers, colleagues, customers, and third parties, in the course of performance management, investigations, or customer feedback; and
  • Publicly available sources, including professional networking sites and public records, where relevant to recruitment or verification.

5. How and Why We Use Your Personal Information

We use Workforce Member personal information for the following business purposes:

  • Recruiting, evaluating, and selecting candidates, including scheduling, interviewing, assessing, and verifying qualifications;
  • Identifying and contacting potential candidates through professional networking and sourcing platforms, including candidates who have not applied to us;
  • Recording, transcribing, and summarizing interviews so that interviewers can engage with you rather than take notes, and so that we hold an accurate record of what was discussed;
  • Verifying employment eligibility and work authorization, and complying with immigration law;
  • Conducting background, reference, criminal history, credit, and drug screening to the extent permitted by law;
  • Onboarding, provisioning access, and administering the employment or contractor relationship;
  • Administering compensation, payroll, expense reimbursement, tax withholding, and reporting;
  • Administering benefit plans, insurance, leave, and retirement programs, including for dependents and beneficiaries;
  • Managing performance, promotions, transfers, training, development, and succession planning;
  • Managing absence, leave, workplace accommodations, and occupational health and safety;
  • Conducting workplace investigations and administering disciplinary and grievance processes;
  • Maintaining the security and integrity of our systems, facilities, data, and personnel, including monitoring described in Section 7;
  • Protecting our confidential information, trade secrets, and customer data, and preventing fraud, theft, and misuse;
  • Complying with legal, regulatory, tax, export control, sanctions screening, and recordkeeping obligations, including equal employment opportunity and affirmative action reporting;
  • Responding to litigation, regulatory investigations, audits, subpoenas, and legal process, and establishing, exercising, or defending legal claims;
  • Managing corporate transactions, including mergers, acquisitions, financings, and reorganizations; and
  • Communicating with you and with your emergency contacts in an emergency.

6. Background Checks

Where permitted by applicable federal, state, and local law, we conduct background checks on candidates and, in limited circumstances, on current employees and contractors. Where a background check involves a “consumer report” or “investigative consumer report,” we will:

  • provide you with a clear and conspicuous written disclosure, in a standalone document, that a consumer report may be obtained;
  • obtain your written authorization before requesting the report;
  • provide you with the summary of rights required by the federal Fair Credit Reporting Act and, for California residents, the notices required by the California Investigative Consumer Reporting Agencies Act (Cal. Civ. Code § 1786 et seq.) and the Consumer Credit Reporting Agencies Act (Cal. Civ. Code § 1785 et seq.), including the opportunity to request a copy of any report obtained; and
  • before taking any adverse action based in whole or in part on the report, provide you with a pre-adverse action notice, a copy of the report, and a reasonable opportunity to respond, followed by an adverse action notice, in accordance with the Fair Credit Reporting Act and applicable state and local fair chance and ban-the-box laws, including the California Fair Chance Act.

We consider criminal history only where and to the extent permitted by law and only after any conditional offer required by applicable law has been made. We do not consider credit history except for positions for which consideration of credit history is expressly permitted by applicable law.

7. Workplace Monitoring

We provide company systems, devices, accounts, and networks for business purposes. To protect our systems, data, personnel, and customers, and to comply with legal and contractual obligations, we log and monitor use of those systems, including access logs, network and internet usage, email and messaging metadata, endpoint security events, and data loss prevention alerts. We may access the contents of communications and files stored on company systems where necessary for a legitimate business purpose, such as an investigation, a legal hold, a security incident, or business continuity, and where permitted by applicable law.

We also maintain badge access records and security camera footage at our premises for physical security purposes. Cameras are not placed in restrooms, changing areas, or other locations where individuals have a reasonable expectation of privacy.

You should not expect privacy in your use of company systems, devices, accounts, or premises, except to the extent a right to privacy is guaranteed by applicable law. We do not use automated tools to make employment decisions that produce legal or similarly significant effects without human review.

Use of artificial intelligence tools. We use a limited set of approved AI tools in connection with the workforce and recruitment activities described in this Notice. These are used to transcribe and summarize interviews and certain meetings, to assist our IT function with internal code and automation work, and to consider generalized, de-identified employee relations scenarios. We do not use AI to score, rank, shortlist, or filter candidates, to infer personality, sentiment, or protected characteristics, or to make or materially inform any employment decision without human review. Every AI-generated interview summary is reviewed and corrected by the interviewer before it is relied on. Our agreements with these providers do not permit them to use our inputs or outputs to train their models. We have completed a data protection impact assessment covering these uses.

8. Who We Share Your Personal Information With

We disclose Workforce Member personal information for the business purposes described above to the following categories of recipients:

  • Affiliates, including Trusted Tech Team Limited (UK), Trusted Tech Team Limited (Ireland), and TrustedTech FZCO, for group administration, IT support, and management purposes;
  • Payroll, HRIS, benefits, and retirement plan providers, insurers, brokers, and third-party administrators;
  • Background check providers, consumer reporting agencies, and screening vendors;
  • IT, cloud hosting, cybersecurity, communications, and software providers;
  • Recruitment sourcing, interview scheduling, and interview recording and transcription providers, including the professional networking platform through which we source candidates and the tools we use to schedule, record, transcribe, and summarize interviews;
  • Professional advisors, including legal counsel, accountants, auditors, and insurers;
  • Government agencies and regulators, including the Internal Revenue Service, state tax and labor agencies, the Department of Homeland Security, the Equal Employment Opportunity Commission, and workers’ compensation authorities;
  • Courts, law enforcement, and parties to legal proceedings, in response to subpoenas, court orders, or other legal process, or to establish, exercise, or defend legal claims;
  • Customers, where your name, business contact details, job title, and professional qualifications are provided in connection with the services you deliver to them; and
  • Acquirers or successors, in connection with a merger, acquisition, financing, reorganization, or sale of assets.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA. We do not use or disclose Workforce Member personal information for targeted advertising or for profiling in furtherance of decisions producing legal or similarly significant effects.

9. Data Retention

We retain Workforce Member personal information for the periods required by applicable law and, where no period is prescribed, for as long as necessary for the purposes described in this Notice. Where multiple periods apply to a single record, we apply the longest.

Category of Record Retention Period Legal Basis for the Period
Applications, resumes, interview notes, and hiring records for candidates not hired 4 years from the date the record was created or the date of the personnel action, whichever is later Cal. Gov. Code § 12946 (as amended by SB 807); 29 C.F.R. § 1602.14 (1 year, Title VII); 29 C.F.R. § 1627.3 (1 year, ADEA)
Personnel files of employees and former employees 4 years from creation of the record or the date of the personnel action, and at least 4 years after the date of termination Cal. Gov. Code § 12946; 29 C.F.R. § 1602.14
Payroll records, timekeeping records, and wage statements 3 years 29 C.F.R. § 516.5 (FLSA); Cal. Lab. Code § 1174(d); Cal. Lab. Code § 226(a)
Supplementary payroll records (wage computations, work time schedules) 2 years 29 C.F.R. § 516.6 (FLSA); 29 C.F.R. § 1620.32 (Equal Pay Act)
Employment tax records 4 years after the due date of the tax or the date the tax is paid, whichever is later 26 C.F.R. § 31.6001-1
Form I-9 and supporting work authorization documents 3 years after the date of hire, or 1 year after the date employment ends, whichever is later 8 C.F.R. § 274a.2(b)(2)(i)(A)
Benefit plan records, enrollment, elections, and beneficiary designations 6 years after the filing date of the related plan report ERISA § 107 (29 U.S.C. § 1027); ERISA § 209
FMLA leave records 3 years 29 C.F.R. § 825.500
OSHA Forms 300, 300A, and 301 (injury and illness logs) 5 years following the end of the calendar year the records cover 29 C.F.R. § 1904.33
Employee medical records and records of exposure to hazardous substances Duration of employment plus 30 years 29 C.F.R. § 1910.1020(d)
Workers’ compensation claim records 5 years from the date of injury or the date of last payment, whichever is later Cal. Code Regs. tit. 8, § 10101.1 and comparable state rules
Background check reports and related authorizations 5 years from the date the report was obtained Fair Credit Reporting Act limitation period, 15 U.S.C. § 1681p; state fair chance recordkeeping
Voluntary EEO and diversity self-identification data 1 year from creation, or the duration of employment plus 1 year, whichever is longer; retained separately from personnel files 29 C.F.R. § 1602.14; 41 C.F.R. § 60-1.12
IT system, email, network, and security logs 24 months Security and incident investigation needs; no statutory period applies
Interview recordings (audio and video) Deleted within 30 days of the hiring decision Data minimization; the reviewed transcript and summary are retained instead
Interview transcripts and AI-generated summaries Retained with the recruitment or personnel file and deleted on the same schedule as that file — 4 years for candidates not hired, and for employees as set out above Cal. Gov. Code § 12946; 29 C.F.R. § 1602.14
Candidate sourcing records (saved profiles, recruiter notes, ratings, pipeline membership, and platform correspondence) for candidates not hired 4 years from the date of the decision or last contact. Where the platform applies a shorter or longer default, we delete manually to meet this period Cal. Gov. Code § 12946; 29 C.F.R. § 1602.14
Interview scheduling records 4 years from the date of the decision, with the recruitment file Cal. Gov. Code § 12946
Building access records and security camera footage 90 days for camera footage; 24 months for badge access records Security needs; no statutory period applies
Records of privacy rights requests, including verification records 24 months from the date of the request 11 C.C.R. § 7101(a)
Records subject to a litigation hold, audit, or regulatory inquiry For the duration of the hold or obligation, notwithstanding any shorter period above Legal preservation obligations

At the end of the applicable period we securely delete or destroy the information, or de-identify or aggregate it.

10. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect Workforce Member personal information against unauthorized access, destruction, use, modification, or disclosure, appropriate to the nature and sensitivity of the information. Access to Workforce Member information is limited to personnel and service providers with a legitimate need to know. No security measure is perfect, and we cannot guarantee absolute security.

11. Your Privacy Rights

California Residents

If you are a California resident, you have the following rights under the CCPA with respect to the personal information we hold about you as a Workforce Member:

  • Right to Know / Access. To request the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties to whom we disclose it.
  • Right to Delete. To request deletion of personal information we collected from you, subject to the exceptions in Cal. Civ. Code § 1798.105(d) — which are extensive in the employment context, because most Workforce Member records are retained to comply with legal obligations, complete a transaction, or exercise or defend legal claims.
  • Right to Correct. To request correction of inaccurate personal information we maintain about you.
  • Right to Limit Use of Sensitive Personal Information. As described in Section 3, we do not use sensitive personal information beyond the purposes permitted by the CCPA, so this right does not apply to our processing.
  • Right to Opt Out of Sale or Sharing. We do not sell or share Workforce Member personal information, so there is nothing to opt out of.
  • Right to Non-Retaliation. We will not retaliate or discriminate against you — in hiring, compensation, terms of employment, or otherwise — for exercising any of these rights.
  • Right to Appeal. To appeal a decision declining to act on your request.

How to exercise your rights. Email compliance@trustedtechteam.com with the subject line “Workforce Privacy Request,” or contact People Operations. We will verify your identity through your employment records and any additional information reasonably necessary. Authorized agents may submit requests on your behalf with written, signed permission and subject to verification. We will respond within 45 days of receiving a verifiable request, and may extend that period by a further 45 days with notice to you and the reason for the delay. If the request is for copies of records, we will respond to such requests as follows: 21 days for payroll records and 30 days for personnel records (or such earlier time as may be required by applicable law).

Appeals. If we deny your request in whole or in part, email compliance@trustedtechteam.com with the subject line “CCPA Appeal” and a description of the basis for your appeal. We will respond in writing within the timeframe required by law. If your appeal is denied, we will provide information on how to contact the California Privacy Protection Agency or the California Attorney General to submit a complaint.

Residents of Other States

Most other U.S. state consumer privacy laws — including those of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and Utah — expressly exclude personal data processed in an employment or commercial context. As a result, those laws generally do not give you consumer privacy rights with respect to the information described in this Notice. Where a state law does apply to Workforce Member information, we will honor the rights it provides.

Regardless of your state of residence, you may contact us at compliance@trustedtechteam.com with any question or concern about how we handle your personal information, and you may request access to your personnel file to the extent provided by applicable state law.

12. International Access to Your Information

Your personal information is stored in the United States. Our affiliates in the United Kingdom and the United Arab Emirates, and certain of our service providers, may access it from outside the United States for group administration, IT, and support purposes. Where we do so, we require appropriate contractual and security protections. Our recruitment function is based in the United States and operates for the group as a whole, which means that personal information about candidates for roles outside the United States is also collected into and processed in systems held by Trusted Tech Team, LLC. Where that information relates to individuals in the United Kingdom, Ireland, or the European Union, the transfer to us is made under the safeguards described in the privacy notice applicable to that region and under an intra-company data transfer agreement between the relevant entities.

13. Contact

Questions, concerns, and requests relating to this Notice should be directed to:

Email: compliance@trustedtechteam.com

Mail: Trusted Tech Team, LLC, Attn: Privacy — People Operations, 5171 California Avenue, Suite 250, Irvine, CA 92617

Telephone: (855) 202-8140