ASSOCIATE  AND  JOB  APPLICANT  PRIVACY  NOTICE

This Privacy Notice describes, among other things, how The Millennium Group (“TMG”) collects, processes, and uses your personal information (i.e., personal contact details such as name, job title, home addresses, telephone numbers, and personal email addresses, birthdate, gender, recruitment information, employment records, identification information, financial information) (“Personal Information”) about current, past, and prospective employees, independent contractors, interns, volunteers, temporary employees of TMG, or visitors of the TMG human resources website located at https://www.tmghumanresources.com (the “TMG HR Site”). The Personal Information processed by TMG (which may be held on paper, in electronic format, or in any other format) may be subject to certain legal safeguards specified in applicable laws.

U.S. STATE LAW REQUIREMENTS

Some U.S. state privacy laws, such as the California Consumer Privacy Act (“CCPA”), require specific disclosures to state residents. This Privacy Notice is designed to help you understand how TMG handles your information. Throughout this Privacy Notice we describe: (1) the categories of information TMG collects and the sources of that information; (2) how TMG uses information; (3) when TMG may disclose information; and (4) how TMG retains information.

INFORMATION THAT WE COLLECT

In the course of your employment with TMG, we may collect and process the following Personal Information:
  • Personal contact details such as name, job title, home addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • Marital status and information about your dependents
  • Next of kin and emergency contact information
  • National Insurance number
  • Bank account details, payroll records, and tax status information
  • Salary, annual leave, pension, and benefits information
  • Employment start date
  • Location of employment or workplace
  • Identification information (including a copy of driving license, passport, and utility bills)
  • Recruitment information (including copies of right to work documentation, references, and other information included in a CV or cover letter or as part of the application process)
  • Employment records (including job titles, work history, working hours, training records and professional memberships)
  • Compensation history
  • Performance information
  • Disciplinary and grievance information
  • CCTV or dashcam footage and other information obtained through electronic means such as swipe card records
  • Information about your use of our information and communications systems (including email and phone numbers for receiving text messages)
  • Inferences from any of the below personal information categories
  • Any other information that you voluntarily provide to us

SOURCES OF PERSONAL INFORMATION

The above information is collected in the following methods listed below:
  • Job applications (hard copy or electronic copy)
  • Resume(s)/curriculum vitae(s)
  • Information provided during job forums and recruitment events
  • Information forwarded by recruitment agencies
  • Information provided directly from employee
  • Pre-employment screening services
  • Publicly available sources such as your social media profile (e.g., Linked In, Twitter, and Facebook)
  • Performance reviews
  • Third parties as necessary for providing you with benefits and ancillary services
  • Training and certifications
Note, the above information is received by TMG in various forms including hard-copy and electronic form, delivered in-person or via email, text, fax, website, social media, etc.

INFORMATION WE COLLECT AUTOMATICALLY

When you visit the TMG HR Site, we may use cookies, pixels, web beacons, tags, or scripts to automatically collect information, such as the following:
  • Browser and Device Information: Certain information may be automatically collected by most browsers or devices, such as information about user devices (such as IP addresses and MAC addresses), operating systems, and browsers.
  • Information Stored in Cookies. The TMG HR Site may also use available web-based technologies to collect personal information, such as cookies, pixels, or web beacons. Cookies are pieces of information stored directly on users’ computers or devices. Cookies allow us to collect information such as browser type, time spent on online services, pages visited, referring URL, and other traffic and usage data. We may also use cookies for purposes such as determining what features interest our users, revising our site features or operations, and as further described below.
  • Pixel Tags and Log Files: The TMG HR Site may also use other tracking systems such as log files and pixel tags. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.
  • Information Collected in Connection with Analytics Technology: We may use various technologies to learn more about how visitors use the TMG HR Site, to help us analyze how visitors use the TMG HR Site. The information generated by the cookies about your use of the TMG HR Site includes your IP address and device IDs. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. We may also use other technologies to monitor your activities on our TMG HR Site.
On the TMG HR Site, we may use one or more of the following cookies:
  • Strictly Necessary Cookies: These are used to provide the TMG HR Site and to prevent fraudulent activity, improve security, and for the administration of the TMG HR Site.
  • Functional and Preference Cookies: These are used to remember choices you make regarding the TMG HR Site and help remember you when you visit the TMG HR Site to manage your access and privileges.
  • Performance Cookies: These are used to collect information about how you use the TMG HR Site and improve the sites performance by showing us pages you visit, any difficulties experienced, and whether or not the content provided is effective.
 
Managing and Blocking Cookies
 
Through browser settings, you can manage or block the use of cookies. In addition, you can use opt-out tools for ad networks and firms who participate in the Network Advertising Initiative as http://optout.networkadvertising.org/ or the Digital Advertising Alliance as http://optout.aboutads.info/.
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To effectively manage cookies via browser settings or through these ad industry opt-out tools, you must opt-out and set cookie preferences on all browsers and all devices that you use. If you clear the browser cache or cookies, be sure to reset your preferences.
 
Please note that blocking or disabling cookies may prevent or impair functionality and use of the Websites.
Please see your browsers’ help files for additional information about viewing and changing your browser settings to manage or block cookies.

CATEGORIES OF PERSONAL INFORMATION COLLECTED AND PURPOSE OF PROCESSING

OBJECTIVES OF THE PROCESSING ​
TYPE OF PERSONAL INFORMATION
BASIS FOR PROCESSING
Recruitment/Employee Management
Managing the workforce: recruiting, managing work, evaluating the work performance of employees, developing, and managing the company’s organizational structure, managing staff and team management, managing and business trips, talent management and work growth counseling, training, managing, and approving work leave, succession planning, provision of references on request.
  • identification data
  • data related to the employee’s position
  • salary data and related financial data
  • health data related to employment
  • information about committing or allegedly committing a criminal offense or an offense
Processing:
  • ​a contract of employment or other contract to which the employee is a party
  • for the proper assessment of a potential candidate
  • to fulfill the employment or other contract to which the employee is a party
Benefits
Salary Agenda, Employee Benefits and Payments: salary, rewards, and all other incentives and benefits, compliance with statutory social security and tax regulations.
  • identification data
  • data related to the employee’s position
  • salary data and related financial data
  • information on insurance and indemnity
  • information on the Social Security system
  • beneficiary and/or dependent information​
Processing:
  • to comply with the legal obligations applicable to
  • to fulfill the employment or other contract to which the employee is a party
Emergency
Communication with employees and their contact persons in case of urgency.
  • identification data
  • data related to the employee’s position​
Processing is necessary to protect the vital interests (health) of the employee in the event of an emergency
Legal Obligations
The fulfillment of our legal obligations, including obligations arising from employment and immigration laws, tax laws, and regulations relating to health and safety at work.
  • identification data
  • employee demographic information
  • data related to the employee’s position
  • salary data and related financial data
  • information on insurance and indemnity
  • information on the Social Security system health data
​Processing is necessary to comply with the legal obligations applicable to TMG
Protective Measures
Detection or prevention of any inappropriate behavior or violation of the TMG rules, including the protection of our intellectual property, confidential information, and other tangible and intangible property.
  • identification data
  • data related to the employee’s position
  • information on asset use and company systems​
Processing is necessary for the legitimate interests of TMG, to protect the assets of the company
Legal Proceedings
For the purposes of any potential and/or ongoing litigation or inquiries concerning us or one of our Group companies, representatives of the company.
  • ​identification data
  • data related to the employee’s position
  • information on asset use and company systems
Processing is necessary for TMG legitimate interests to claim TMG rights against third parties or to defend against third-party claims against TMG in a possible litigation or to defend and meet the requirements of an administrative inquiry
​IT Security
  • backing up
  • providing employees with IT support
  • detecting and protecting against security incidents and malicious, deceptive, fraudulent, or illegal activity
Value

SHARING OF PERSONAL INFORMATION

We may share your Personal Information as necessary for the purposes described in this Privacy Notice. For example, we share your Personal Information with the following parties:
  • Service Providers:  We use service providers to operate, host, and facilitate our operations and business (including human resources operations). These include hosting, technology, and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and external benefit providers, such as payroll, pension administration, benefits provision, occupational health, and IT services. TMG takes commercially reasonable measures to confirm that Personal Information shared with services providers is provided with adequate security measures and protected from unauthorized access.
  • Business Transfers:  Your Personal Information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).
  • Professional Advisors:  We may share your Personal Information with our professional advisors.
  • Other:  We may also share your Personal Information with third parties for purposes of fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property, or safety of you, us, or another party; enforcing any agreements with you; responding to claims; and resolving disputes.
TMG does not sell or otherwise disclose employee or prospective employee Personal Information for monetary or other consideration to any third parties.

RETENTION OF PERSONAL INFORMATION

TMG will not maintain your Personal Information longer than is necessary for the purpose for which it was collected. TMG will process Personal Information of the employee for the duration of the employment relationship between TMG and the employee and furthermore for the period of seven (7) years from the date of termination of the employment relationship, unless required to maintain the Personal Information for a longer period under any legal obligation. The employee’s Personal Information and documents may further be processed, if necessary, for the determination, exercise, or defense of TMG legal claims or for a period that is required by applicable law.

YOUR RIGHTS

Some state laws, like the CCPA, provide you with certain rights as it pertains to your Personal Information. Under California law, California employees of TMG have the following rights:
  • The right to receive disclosure about our Information Collection Practices.
  • The right to receive disclosure about our Information Disclosure Practices.
  • The right to tell us not to sell your personal information. TMG does not sell your personal information.
  • The right to tell us not to share your personal information for behavioral or cross-context marketing purposes. TMG does not share your personal information for this purpose.
  • The right to tell us not to process your Sensitive Personal Information for purposes other than the purposes for which it was originally collected. TMG only processes Sensitive Personal Information for the purpose for which it was originally collected.
  • The right to request that we correct information that is incorrect.
  • The right to request a copy of Personal Information we collected about you during the past 12 months, subject to certain exceptions.
  • The right to request that we delete Personal Information, subject to certain exceptions.
You may exercise your rights under the CCPA through one of the following means:

YOUR OBLIGATIONS ABOUT YOUR INFORMATION

It is important that the Personal Information we hold about you is accurate and up to date. If you become aware that Personal Information we hold is inaccurate or if your Personal Information changes, we ask that you let us know about this promptly, so that appropriate action can be taken. ​

SECURITY

TMG uses commercially reasonable security measures to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your Personal Information to those who have a genuine business need to know it. Those processing your Personal Information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

REVIEW

The company may revise the privacy notice from time to time and/or will update the privacy notice on an annual basis.

CONTACT INFORMATION

TMG has appointed/designated our Human Resources Director that is responsible for this Privacy Notice:
​
Name: Danielle Fitzgerald
Title:   Human Resources Director
Email: [email protected] 
Address: 106 Apple Street, Suite 101D, Tinton Falls, NJ 07724