DAHLIN PRIVACY NOTICE REGARDING EMPLOYMENT-RELATED PERSONAL INFORMATION

 

This privacy notice regarding security of employment-related Personal Information (“Personal Information” or “PI”) applies to residents of California who are employees, dependents, applicants, independent contractors, and Board Members (“Covered Individuals” or “CI”) of the DAHLIN Group, Inc. (“DAHLIN” or the “Company”).

 

Rights of Covered Individuals

 

Covered Individuals have the following rights:

• The right to receive information about DAHLIN’s Personal Information collection and disclosures practices. This disclosure is provided below.
• The right to tell us not to sell your Personal Information. DAHLIN does not sell your Personal Information.
• The right to tell us not to share your Personal Information for behavioral or cross-context marketing purposes. DAHLIN does not share your Personal Information for either of these purposes.
• The right to tell us not to use your Sensitive Personal Information (as defined in Section H below) for purposes other than the lawful reasons for which it was originally collected. DAHLIN only uses Sensitive Personal Information for lawful reasons.
• The right to request that we correct Personal Information that is incorrect. Please see below for how to exercise this right.
• The right to request a copy of Personal Information we collected about you, subject to certain exceptions. Please see below for how to exercise this right.
• The right to request that we delete Personal Information about you, subject to certain exceptions. Please see below for how to exercise this right.

Category	Examples	Collected from Covered Individuals
A. Identifiers.	A real name, any alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal Information.	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, bank account number, medical information. Some Personal Information included in this category may overlap with other categories.	YES
C. Information tending to identify individuals by characteristics protected from discrimination under California or federal law.	Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, sex, veteran, or military status.	YES
D. Internet or other similar network activity.	When used on DAHLIN information technology systems: Browsing history, search history, your interaction with Company systems, websites, applications, etc.	YES
E. Geolocation data.	Physical location or movements	YES
F. Sensory data.	Audio, electronic, visual, or similar information.	YES
G. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
H. Sensitive Personal Information	Social Security number, driver’s license, state identification card, or passport number, information about racial or ethnic origin.	YES

  

Personal Information that DAHLIN Collects

 

DAHLIN collects and uses Personal Information for human resources, employment, benefits administration, health and safety, and business- related purposes and otherwise when it is required by applicable law. Below are the categories of Personal Information we collect about Covered Individuals:

Personal information does not include, e.g.:

• Publicly available information from government records.
• De-identified or aggregated employee information.

 
Information Collection Practices: How DAHLIN Collects and Uses Personal Information

DAHLIN collects the above categories of Personal Information directly from Covered Individuals, and also from third parties such as staffing partners and employment application references.

We use Personal Information, including Sensitive PI, to:

• Comply with applicable laws and regulations.
• Recruit and evaluate job applicants and candidates for employment based on skills and experience.
• Conduct background checks.
• Manage the employment relationship, including for:
  • Onboarding processes.
  • Timekeeping, payroll, and expense report administration.
  • Employee benefits administration.
  • Employee training and development.
  • The creation, maintenance, and security of online employee accounts.
  • Reaching emergency contacts when needed, such as when employees are not reachable or are injured or ill.
  • Workers' compensation claims management.
  • Managing employee job performance.
  • Other human resources purposes.
  • Manage and monitor employee access to Company facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Ensure compliance with Company policies and procedures.
  • Engage in corporate transactions requiring review of employee records, such as in evaluations of potential mergers and acquisitions.
  • Maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.
  • Perform workforce analytics, data analytics, and benchmarking.
  • Administer and maintain the Company's operations, including for safety purposes.
  • Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
  • To ensure compliance with applicable laws, including anti-discrimination laws and disability accommodation laws.

 

Information Disclosure Practices

DAHLIN may disclose Personal Information for business purposes to service providers or contractors who assist us in administering our workforce, such as: benefits providers; payroll and expense administrators; worker’s compensation administrators; professional advisors such as attorneys, auditors, and accountants.

 

• We do NOT sell Personal Information.
• We do NOT share Personal Information with third parties for behavioral or cross-context marketing purposes.

 

Sensitive Personal Information

We do NOT use Sensitive Personal Information for purposes other than the lawful purpose for which it was originally collected. We do not collect more information than we need to fulfill our stated purposes and will not retain it for longer than is necessary.

Storage of Personal Information

The security of Personal Information is important to the Company. PI is only accessed by those with a legitimate business need to do so.

Remember that no method of transmission over the Internet, electronic storage, or physical storage is 100% secure. While DAHLIN strives to use reasonable and appropriate means to protect PI, the Company is unable to guarantee its absolute security. You have the right to seek damages, in accordance with the law, for breach of certain sensitive PI.

 

How to request correction of Personal Information

If you believe that information that DAHLIN holds about you is incorrect or needs to be updated, please contact the People and Culture team at HR@dahlingroup.com or call 925-251-7200. You can make this request at any time. We will acknowledge receipt of your request within 10 days and, if appropriate, we will correct your information promptly (generally within 45 days) after the request.

 

How to request a copy of your Personal Information

If you would like to receive a copy of the Personal Information collected about you, please contact the People and Culture team at HR@dahlingroup.com or call 925-251-7200. We will acknowledge receipt of your request within 10 days and provide a copy of your information in an easily readable format within 45 days. If we need an additional 45 days to compile your information, we will let you know.

 

How to request deletion of your Personal Information

If you would like the Company to delete PI that we are permitted by law to delete, please contact the People and Culture team at HR@dahlingroup.com or call 925-251-7200. We generally cannot delete information needed to operate our business, manage our employees, comply with legal obligations and rights, or to provide security for the Company, including our employees and our business and operational systems. You may make this request up to twice in any calendar year. We will acknowledge receipt of your request within 10 days and respond to your request, to the extent appropriate, within 45 days. If we need an additional 45 days to respond we will let you know.

 

Non-Discrimination

DAHLIN does not discriminate or retaliate against anyone who exercises of any of these rights.

Questions

If you have any questions about this Notice or need to access this Notice in an alternative format for any reason, please contact the People and Culture team at HR@dahlingroup.com or call 925-251-7200.

 

Changes to This Notice

The Company reserves the right to amend this Notice, in its sole discretion, at any time. When we make changes to this Notice, we will post the updated notice on our Website, Intranet and update the Notice’s effective date.

 

Effective Date: January 1, 2023