TriNet Platform Privacy Policy

Effective Date: July 5, 2018

I. Policy Overview

This privacy policy (this "Policy") applies to the TriNet technology platform (the "Platform") and describes how TriNet Group, Inc. and its subsidiaries ("TriNet," "we," "our," or "us") collect, use, and disclose personal information in connection with the Platform. It also describes how you can access and update your personal information on the Platform.

This Policy applies to all users of the Platform, including clients of TriNet (or their authorized users), worksite employees of a client serviced by TriNet or corporate colleagues of TriNet. By accessing the Platform, whether online or through a mobile app, you consent to the collection, use, and disclosure of your personal information as described in this Policy.

II. Personal Information Provided by You or Your Employer

In order to provide our services to you, TriNet may collect personal information directly from you or your employer. Please note that the provision of such personal information may be a contractual requirement of your employment. Failure to provide such personal information may limit your eligibility for certain positions or disqualify you from receiving TriNet’s services.

III. Categories of Personal Information Collected

The personal information collected about you may vary based on the requirements and/or limitations of the local laws where you work, as well as the requirements of your job or salary grade. The general categories of personal information we may collect, unless restricted by state or local law, are:

  1. Personal details and contact information, such as name; e-mail address; telephone number; mailing address; date and place of birth; age; gender; marital status; native language; photographs; driver’s license and automobile license numbers; emergency contact details; dependent details.

  2. Employment, work record, and performance information, such as employer name and address; employee ID number; job title and level; department; location; supervisor; dates of employment; performance and evaluation records; disciplinary records or reports, including investigations related to workplace conduct; training and attendance records.

  3. Right to work and immigration information, such as social security or social insurance number, taxpayer identification number (or other government identification number); citizenship, visa, and work permit information; identity card, passport, and/or birth certificate details.

  4. Compensation and benefits information, such as salary and compensation details, including bonus, benefits, and stock option information; tax rates and allowances; retirement fund details; expense details, including corporate credit card and payment history; benefits enrollment details; banking details, including bank account numbers.

  5. Talent, recruitment, and education, such as education and other academic and professional qualifications; details about your previous roles and employment, including employment references; language and other relevant skills; resume, curriculum vitae, and application details; veteran status.

  6. Transaction-related information, such as information you provide when you contact us with questions or requests for certain information. If you send us proposals or personal correspondence, such as emails or letters, we may collect and store such information in a file specific to you.

  7. Sensitive Personal Information. Some of the above categories of personal information may include sensitive personal information that is given extra protection by law. TriNet may collect sensitive personal information as necessary for payroll and benefits administration or other similar lawful purposes, as required by law, as necessary for the establishment or defense of legal claims, and where necessary to assess or provide equality of opportunity. TriNet may also collect and process sensitive personal information for other purposes with your consent. The sensitive personal information we collect may include:

    1. Health information, such as information necessary: to provide you with health insurance or other benefits; to provide you with parental, family, or disability leave, pay, or related benefits; for workers’ compensation claims; to assess your fitness to work; or to protect your health and safety.

    2. Background-check information, such as information related to offenses or criminal proceedings, outcomes, and sentences where required by law, relevant to job function, or necessary to protect the health and safety of other personnel; certain other background information including reference checks.

    3. Diversity and equal opportunity information, such as information necessary to identify and review equal opportunity or employment equity practices, or in connection with the publication of aggregate data on the diversity of TriNet’s or its customers’ workforces.

  8. Information Regarding Dependents. In some cases, TriNet may collect personal information (including sensitive personal information) about your dependent family members, beneficiaries, and emergency contacts for purposes such as the provision of health care or life insurance benefits to you or your dependents or in case you experience a medical emergency at work. If you provide personal information about others, TriNet will rely on you (unless otherwise required by law) to communicate to those individuals that you are providing us with their personal information and to obtain their consent, as necessary, for us to process their personal information (including explicit consent where necessary for the collection and disclosure of sensitive personal information) as described in this Policy.

  9. Automatically Collected Information. TriNet automatically collects certain technical information when you access the Platform, including your IP address, browser type, operating system, the type of device you are using, and the device identifier. TriNet, and its affiliates, suppliers, and service providers, also use technologies such as cookies, beacons, tags, and scripts in order to gather information regarding your use of the Platform. This includes information such as page views, which URL you just came from (whether on our site or not), and which URL you go to next (whether on our site or not). This allows us to analyze trends, administer the Platform, and gather demographic information about our user base as a whole. We use cookies on certain pages of the Platform. Some features of the Platform may only be available through the use of a cookie. Most cookies are "session cookies," meaning they are automatically deleted at the end of a session. We also use persistent cookies. A persistent cookie remains on your hard drive for an extended period of time and remembers your preferences. You are always free to decline cookies if your browser permits, although in that case you may not be able to use certain features of the Platform and you may be required to reenter your password more frequently during a session.

IV. Use of Information

TriNet uses the personal information we collect from you and, if applicable, your family members including your dependents, for a variety of purposes in providing our services and managing our business, including:

  1. Human resources and personnel management, such as recruiting; verifying background and qualifications (if and when relevant to your job function and in compliance with applicable law); offering and administering payroll, insurance, and other benefits including pensions; managing work-related expenses; evaluating performance, training, and career development; managing disciplinary and termination processes; responding to employee grievances; enforcing compliance with internal policies; complying with applicable legal requirements; and performing other administrative and managerial tasks.

  2. Customer service, such as administering your account with us; responding to your inquiries for assistance with your account or your benefits; sending you certain communications (including by email and SMS) such as service announcements and administrative messages and other communications relating to our services; and maintaining service quality (calls to our customer services may be monitored and/or recorded for authentication, security, quality, and training purposes). Please note that you will not be able to opt out of receiving these essential service communications.

  3. Compliance with legal and other requirements, such as duties under labor laws and regulations; record-keeping and reporting obligations; lawful government requests, inspections, and investigations; responding to legal process such as court orders or subpoenas; protecting the legal rights of TriNet, our personnel, our customers, or others; detecting and preventing crime and fraud; auditing compliance with TriNet standards, procedures, and contractual obligations; and in the good faith belief that such use is necessary to adhere to applicable laws or perform any of the purposes described in this Policy.

  4. Providing and improving our services, such as performing research and analysis on Platform usage and the use of our services; customizing the Platform’s content, layout, and features; and troubleshooting problems or resolving disputes.

  5. Responding to your inquiries, such as resolving a question or concern that you may have.

If you are a corporate colleague of TriNet, we may additionally use your information for the following purposes:

On occasion, TriNet may have a business need to use personal information for a purpose not originally considered at the time of first collection. In these cases, TriNet will take reasonable steps to notify you or your employer of this new use and obtain any additional consents that may be necessary.

V. Security of Your Information

TriNet is committed to protecting your personal information. We have implemented technical, physical, and administrative controls appropriate to the sensitivity of the personal information in order to protect such information.

In order to help maintain security, you should never share your login ID or password and should always sign out when you are finished using the Platform.

Although we take reasonable steps to protect your privacy, no information system can be 100% secure. As a result, we cannot guarantee the absolute security of your personal information.

Social Security and Social Insurance Number Protection Policy Statement

TriNet collects Social Security or Social Insurance numbers and other sensitive personal information from you in order to provide you our services. We limit our use of Social Security or Social Insurance numbers and other sensitive personal information to circumstances where it is necessary and is used and disclosed for the purposes described in this Policy.

VI. Sharing of Personal Information

As a general matter, access to personal information is restricted to TriNet personnel who need such personal information for the purposes listed in this Policy, or where otherwise required by law.

If you are a worksite employee, we may disclose your personal information to your employer. If you seek to exercise any rights you may have under applicable law regarding your personal information, we may work with your employer to provide that information.

We do not sell, rent, or lease your personal information. In the normal course of business, TriNet may contract with third parties to perform business, administrative, or management functions on our behalf (including for provision and administration of benefits, compensation, financial, IT, audit, legal, and consulting services) and may provide your personal information to these service providers as necessary to perform these functions or in connection with any purpose described in this Policy. We may also provide your personal information to third parties as necessary to perform our services. For example, we may provide personal information to background check companies in order to complete background checks, or to your insurance company in connection with providing benefits. When we provide information to third parties, we take reasonable steps to require these third parties to protect your information and use it only as needed.

We may disclose information to law enforcement, regulatory authorities, or other third parties as required or permitted by law, such as to comply with a court order, subpoena, or similar legal process, or to comply with government reporting obligations.

We may disclose information in accordance with the law when we believe in good faith that disclosure is necessary to protect our rights; to protect your safety or the safety of others; or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Platform.

We may transfer your personal information as part of a sale or transfer of all or a relevant portion of our business or assets. In such event, we will use commercially reasonable efforts to help ensure that your personal information will be subject to appropriate privacy protections, in accordance with applicable privacy law.

VII. Access, Correction, and Deletion

TriNet strives to maintain accurate, complete, and up-to-date personal information. We rely on you to help us maintain accurate personal information about you. Once you receive a login ID and password, you can review and modify your personal information on the Platform. When your personal information changes, please log in to the Platform to review, correct, amend, and/or delete your information. You can do so by updating your profile. You can also access and modify your personal information by contacting the appropriate customer support office. We will respond to your inquiries within a reasonable timeframe.

We may retain your personal information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. Please be aware that it is not always possible to completely remove or delete all of your personal information from our databases without some residual personal information remaining due to backups or other technical constraints.

VIII. Children’s Privacy

The Platform is intended for adults. We do not knowingly collect personal information directly from children under the age of 13. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us using the contact information in this Policy. We will retain personal information from adult registered users about their dependents as provided by such users on the Platform for purposes of administering benefits for their dependents, including dependents under the age of 13.

IX. Do Not Track

Some browsers may transmit "do-not-track" signals to websites with which the browser communicates. This Platform does not currently respond to "do-not-track" signals.

X. EU-U.S. Privacy Shield

TriNet Group, Inc. (and its subsidiary companies) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. TriNet is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the applicable Privacy Shield Principles. To learn more about the Privacy Shield Framework and the Privacy Shield Principles, visit the U.S. Department of Commerce’s Privacy Shield List.

TriNet is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. TriNet complies with the Privacy Shield Principles for all onward transfers of personal information from the EU, including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, TriNet is subject to the regulatory enforcement of the U.S. Federal Trade Commission. In certain situations, TriNet may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

XI. Changes to this Policy

We may update this Policy from time to time to reflect legal, technological, and other developments. We will post the updated Policy on the Platform. If we make any material changes, we will take reasonable steps to notify you (e.g., by email or by means of a notice on the Platform) prior to the change becoming effective. We will obtain any necessary consents as required by law. We encourage you to periodically review this page for the latest information on our privacy practices.

XII. Contact Information

If you have any questions or concerns about this Policy, please contact us at the mailing or email address below:

TriNet Group, Inc.
One Park Place
Dublin, CA 94568, USA
Attention: Privacy Officer

Or email [email protected].