US and LATAM Employee Privacy Notice

RB Global, Inc. and its group companies respect the privacy of all individuals and are committed to handling personal information responsibly and in accordance with applicable laws.

This Employee Privacy Notice explains what personal information is collected about you, how it is used during and after your employment, and your rights to this personal information.

1. Sources & Types of Employee Personal Information Processed
2. Use of Employee Personal Information
3. Disclosures of Employee Personal Information
4. Recipients of Employee Personal Information
5. Consumer Privacy Rights
6. Additional California Notices
7. Security & Retention
8. Changes to this Employee Privacy Notice
9. How to Contact Us

1. Sources & Types of Employee Personal Information Processed

Most often, the personal information collected for employment related purposes is collected from you directly, for example, during the onboarding process, although in some cases, it may be collected from third parties. In addition, some types of personal information will be generated during the course of establishing, managing and terminating the employment relationship and managing post–termination matters.

In most circumstances, permission will be obtained before collecting personal information about you from a third party.

The following types of personal information are collected, used, and stored:

Voluntarily provided demographic information that qualifies as sensitive personal information, such as ethnicity, gender, veteran status, and disability may also be collected to help us understand and report on the diversity of our workforce. This information is not used to make inferences about you.

2. Use of Employee Personal Information

Employee personal information is not sold or shared – as those terms are defined in the California Consumer Privacy Act, as amended (“CCPA”). Only the minimum information necessary is collected and limited in use to reasonable employment–related and business purposes, including:

• Workforce Planning and Recruitment: for example, for business forecasting, employee assignment planning and budgeting, conducting background and criminal history checks, performing drug testing, managing, promoting and terminating staff.
• General Human Resources Management and Administration: for example, for career development, performance management, compensation and benefits management, administering payroll, managing reward and recognition programs, collaborating on charitable donations and volunteer opportunities, reimbursing expenses, managing absences, training staff, and carrying out disciplinary or grievance procedures.
• Performance of Business Operations: for example, to carry out day to day business
  activities, to ensure business continuity, to enforce rights and protect business operations,
  and to pursue available remedies and limit damages the organization may sustain.
• Security Management: for example, to ensure the security of the organization’s
  premises, assets, information, and staff.
• Legal and Regulatory Compliance: for example, to respond to law enforcement
  requests; as required by applicable law, court order, or governmental regulations; to
  ensure compliance with health & safety requirements and other legal or fiscal obligations,
  or in connection with litigation or an internal investigation or audit and to ensure
  compliance with the organization’s Code of Conduct and Business Ethics and policies
  regarding anti– money laundering, bribery, and corruption.
• Provide immigration support: If applicable and as permitted by applicable law, to assist
  with immigration support, such as applying for visas or work permits.
• Business transactions: for example, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the organization’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held about you is among the assets transferred.
• As otherwise described to you at the time your personal information is collected.

Staff are not subject to automated decision–making.

3. Disclosures of Employee Personal Information

Personal information is disclosed for the following reasons:

• You request or consent to the disclosure.
• There is an emergency and physical safety is at risk.
• We are conducting an investigation and the disclosure is reasonable for the purposes of the investigation.
• The information is necessary to process an insurance claim.
• Auditors require your personal information as part of an audit.
• To obtain advice of professional advisors, such as tax, legal, accounting, and other business advisors.
• Applicable laws, a court order, a warrant, or a government or legal authority instructs the disclosure of certain information.
• Other purposes where applicable laws do not require your knowledge or consent.

4. Recipients of Employee Personal Information

In connection with the use and disclosure of your personal information as described in this Employee Privacy Notice, the information is made available to the following categories of recipients:

• Team Members at various group companies: To establish, manage, or terminate your
  employment.
• Service Providers: Service providers are used to operate, host, and facilitate the
  organization’s operations and business, including human resources operations, and to
  provide services to you on behalf of the organization, such as recruitment providers,
  financial investment service providers, insurance providers, healthcare providers and
  other benefits providers, payroll support services and motor vehicle, criminal background
  drug screening services.
• Professional advisors: Personal information may be accessible to professional advisors
  that are implementing or updating technical systems or providing legal or consulting
  services. These services are provided under and governed by contracts.
• Government authorities and law enforcement: In certain situations, the disclose of
  personal information may be required in response to lawful requests by public authorities,
  including to meet national security or law enforcement requirements.
• Business transfers: Your personal information may be transferred to a third party as part of a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of the business (in whole or in part) you work for.

Personal information is also made available to the above recipients and/or third parties for purposes of: fulfilling legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting, and investigating potentially illegal or prohibited activities; preventing, detecting, and investigating security incidents; protecting the rights, property, or safety of you, the organization, or another party; enforcing any agreements with you; responding to claims; and resolving disputes.

5. Consumer Privacy Rights

California law provides employees who are California residents with the following privacy rights, subject to certain exceptions and limitations:

• Right to Access & Know – You have the right to obtain confirmation whether your personal data is being processed, obtain a copy of your personal data and know:
  • The categories and/or specific pieces of information we’re processing
  • The purposes of information processing
  • The categories of third parties to whom the information may be disclosed
  • How long the information will be stored (or the criteria used to determine that period)
  • Your other rights regarding our use of your data
• Right to Information Portability – you may request your personal information in a structured, commonly used, and machine–readable format
• Right to Correction – you may request we correct inaccurate personal information and the right to have incomplete personal information completed.
• Right to Delete – you may request we delete any of your personal information, subject to certain exceptions.
• Right to Non–Discrimination – we will not discriminate against you in any manner
  prohibited by applicable privacy law for exercising these rights.

Under specific circumstance, these rights may be limited. For example, if fulfilling your request would reveal personal information about another individual, or if you ask for the deletion of personal information which must be kept to comply with applicable law which is needed to defend claims against the organization. If there is an exception to fulfilling your request, it will be communicated clearly and fully to you.

To exercise any of these rights, please contact the Data Privacy Office directly at: dataprotection@rbglobal.com. Please note, we may take steps to verify your identity by matching the information you provide with your request with the information we have on file about you.
Depending on the sensitivity of the information at issue, we may utilize more stringent verification methods, including but not limited to requiring you to sign a declaration under penalty of perjury.

Other applicable data privacy law may provide staff with similar or additional privacy rights, subject to certain exceptions and limitations. For questions, reach out using the email above.

6. Additional California Notices

Notice of Disclosure For a Business Purpose. For a list of the categories of personal information we have disclosed for a business purpose in the twelve months preceding the date this notice was last updated, please see Section 1 above. For a list of the categories of third parties with whom such personal information was disclosed, please see Section 3 above.

Notice of Sale or Sharing. We do not sell or share your personal information. We do not knowingly sell the personal information of any California resident who is 16 years or younger.

Notice of Processing Sensitive Personal Information. We do not use your sensitive personal information other than as permitted under the CCPA.

7. Security & Retention

The organization maintains appropriate technical and organizational measures, including, but not limited to, reasonably designed administrative, physical, and technical safeguards, designed to protect the personal information obtained as discussed in this Employee Privacy Notice from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and access. However, no system of safeguards can guarantee the security of your personal information.

As an employee, you have a role to play in ensuring personal information is secured against unauthorized access or disclosure by following organizational policy.

Unless a longer retention period is required by law, your personal information will be retained in accordance with the organization’s retention policies and for only as long as is needed to fulfill the purposes outlined in this Employee Privacy Notice. When the retention of your personal information is no longer required for these purposes or to comply with applicable law, it will either be deleted or anonymized.

8. Changes to this Employee Privacy Notice

The organization reserves the right to amend the Employee Privacy Notice at any time. Updated notices will be posted with new effective dates.

9. How to Contact Us

If you have any questions or concerns regarding this Employee Privacy Notice or the collection and use of your personal information, or for copies of any documents mentioned, please contact us directly at: dataprotection@rbglobal.com

The organization’s address is:

RB Global
Data Protection Office
Two Westbrook Corporate Center
Suite #1000
Westchester, Illinois, 60154

Toll Free: +1.800.663.8457