Employee Privacy Notice

This Privacy Notice describes how Turnitin, LLC and its companies (collectively, “we”, “us”, or “Turnitin”) collect and process Personal Information (defined below) about you, how we use and protect this information, and your rights in relation to this information.

This Privacy Notice applies to all Personal Information that we collect or process about you in relation to your employment or application for employment. Personal Information is information, or a combination of pieces of information, that could reasonably allow you to be identified.

1. Personal Information We Use

As described below, we may collect your Personal Information from you directly, from other sources, and in the course of your employment relationship with us.

1.1 Information we collect directly from you

The categories of information that we may collect directly from you are:

• Identifiers, such as your full name, contact information, date of birth, social security number, online identifiers (such as user name and password) and driver’s license or state identification numbers; personal details (e.g., name, date of birth)
• Protected Classification Characteristics under California or federal law, including information for diversity monitoring and government reporting where permitted by law (e.g., race, ethnicity, gender, disability, veteran status, and sexual orientation); contact details (e.g., phone number, email address, postal address)
• Biometric Information, such as photographs, where requested or required for security or compliance purposes
• Internet or other similar network activity information, including all activity on Turnitin’s information systems (such as internet browsing history, search history, usernames, passwords, and other credentials used to access systems and resources, and stored documents and emails)
• Geolocation data, such as the time and physical location related to use of an internet website or application
• Professional or employment-related information, such as employment application information, work history, professional qualifications, performance and disciplinary
  records, salary, bonus, and other similar compensation data (including bank account details, payroll information, employee benefits, information about family or dependents, and tax information)
• Non-public education information, such as education records, degrees, and transcripts
• Inferences drawn from other personal information to create a profile or summary, including an individual’s work preferences, abilities, and characteristics
• Other personal information, including personal information that you voluntarily share with us (e.g. hobbies)

If you do not provide us with certain types of Personal Information, we will not be able to provide you with pay and certain benefits or resources. Applicable laws may require us to collect certain Personal Information from you. We will inform you at the time of collection about the Personal Information that we require you to provide.

1.2 Information we collect from other sources

We may collect the following information about you from other sources:

• Background check information from employment screening agencies or publicly available registers (as allowed by law)
• Publicly available professional profiles on websites or social media
• Certifications, awards, memberships or other information associated with professional or regulatory bodies
• Health information or claims information from external service providers such as insurance companies or other companies that help administer benefit programs
• Information about your performance or conduct from other employees, clients or service providers you work with who may provide feedback about you; and/or
• Reference

1.3 Sensitive Personal Information and special categories of personal data

We may, as permitted or required by law for specific purposes, also collect and process sensitive Personal Information (personal data that may have special protection under data protection laws about you) such as:

• information about race, ethnic origin, religion, disability, or sexual orientation for diversity monitoring purposes
• biometric identifiers for identification, security, or compliance purposes
• health or disability information to administer sick pay, to monitor and manage sickness absence, to provide occupational health support and administer insurance benefits; and
• criminal background check information for employment vetting purposes.

Where we obtain consent to collect and process sensitive Personal Information, you have the right to withdraw consent at any time, and may do so by contacting us, as noted below.

2. How We Use Personal Information and the Basis on Which We Use It

We may use your Personal Information to:

• Carry out and support human resources administration including recruitment, right to work validation, performance evaluation, promotions, training, payroll administration, pension and insurance or other benefit administration, succession planning, reporting and management;
• Conduct investigations and resolve employee complaints, disciplinary or grievance issues;
• Carry out performance appraisals, promotion assessments/talent reviews and salary reviews;
• Comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
• Deal with your questions and requests;
• Administer travel and expenses;
• Provide employees with benefits, including medical and life insurance, and disability
• Allocate resources;
• Conduct trainings;
• Support internal communications;
• Audit compliance with legal obligations and our policies;
• Provide access to facilities and resources;
• Promote business development, including by providing names and contact information on our digital properties;
• Maintain the security of our premises, facilities and data.

In some locations, we must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

• For purposes of entering into employment agreements with you or fulfilling our contractual obligations to you in connection with your employment;
• To comply with our legal obligations, for example obtaining proof of your identity to enable us to meet our tax reporting obligations or obtaining proof of your right to work status to enable us to meet relevant obligations;
• To comply with our legal obligations to you (or example, health and safety obligations that we must comply with as your employer or to a third party (e.g. the taxation authorities);
• To meet our legitimate interests, for example to manage our business and employees effectively, to provide you with the resources you need to achieve your job roles, to manage our information technology and communications assets, to safeguard our IT infrastructure and other assets, to investigate potential misconduct, to protect us and others against theft or other crime, to coordinate our global operations, to manage our relationships with our parents
  and affiliates, and to comply with legal process or audits. (NOTE: When we process Personal Information to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.);
• To protect your or another person's vital interests, for example by providing your health information to a doctor in a medical emergency; and
• To verify your employment for financial institutions and/or future employers.

Please note that we may be required by law to collect certain Personal Information about you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

We may obtain your explicit consent to collect and use certain types of Personal Information when we are required to do so by law (for example, when we process sensitive Personal Information). If we ask for your consent to process your Personal Information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Notice.

3. Your Rights Over Your Personal Information

Depending on your relationship with us and the jurisdiction in which you reside, you may have certain rights regarding your Personal Information, subject to local law. These include the following rights to:

• Access your Personal Information;
• Correct the information we hold about you;
• Delete your Personal Information;
• Restrict our use of your Personal Information in certain circumstances;
• Object to our use of your Personal Information;
• Receive your Personal Information in a usable electronic format and transmit it to a third party (right to data portability); and/or
• Lodge a complaint with your local data protection authority.

Please be aware that these rights are not absolute. For example, we are required by law to hold certain Personal Information about you in order to maintain you as an employee. If you would like to discuss or request to exercise such rights, please contact us at the details below. We encourage you to contact us to update or correct your information if it changes or if the Personal Information we hold about you is inaccurate. We may contact
you if we need additional information from you in order to honor your requests.

4. Automated Decision-Making

We may use tools that involve profiling to evaluate the suitability of employees or applicants for certain job roles. We may use such tools with human intervention to make decisions about your employment, compensation, or other matters that have a significant impact on you. You will not be subject to decisions based solely on automated data processing without your prior consent. Depending on your jurisdiction and your relationship with us, you may have the right to opt out of such processing.

5. Monitoring

In some circumstances, we may monitor, record, or inspect communications (including e-mails, paper correspondence, voicemail, telephone calls, Slack messages, internet and intranet usage records) using monitoring devices or other technical or physical means. Such monitoring may take place only where necessary and proportionate for purposes permitted by law from time to time, including without limitation:

• Establishing the existence of facts (e.g. keeping records of transactions);
• Ascertaining compliance with regulatory or self-regulatory practices or procedures which relate to our business;
• Ascertaining or demonstrating standards which are achieved or ought to be achieved by persons using our systems;
• Preventing or detecting crimes or unlawful activities;
• Investigating or detecting unauthorized use of our electronic information systems and other materials (e.g. monitoring to ensure compliance with our policies or procedures and evaluate the quality of customer service); and
• Ensuring the effective security and operation of our telecommunications and electronic (including telephones, e-mail and internet) systems; together with any other purposes for which we may be entitled to monitor communications from time to time. Where appropriate, e-mails, paper correspondence and/or instant messages may be checked (e.g. in an individual employee’s absence) to ensure
  we respond promptly to clients and other contacts.

All information stored on or transmitted using our electronic information systems and all recordings and transcripts of telephone conversations is our property. In addition to the above monitoring of communications, information may also be gathered through monitoring devices such as CCTV and security passes.

6. Information Sharing

We may share your Personal Information with third parties under the following circumstances:

• Service providers and business partners. We may share your Personal Information with our service providers and business partners that perform business operations for us. For example, we may partner with other companies for payroll administration; to provide pension, insurance, or other benefits; to host HR/employee engagement databases, for employee vetting, and/or to analyze information to improve performance.
• Turnitin group companies and affiliates. The Turnitin Group of Companies (such as Examsoft, ProctorExam, and Ouriginal) work closely together, along with our parent company, Advance Publications, Inc. (Advance), and the Advance group of companies. We may share certain information about your employment profile with these companies (e.g., your employment details, salary, logs of interactions with IT resources and assets, and/or communications) for human resource management, investigations, legal, financial, insurance, and internal reporting purposes.
• Requesting entities. Law enforcement agencies, courts, regulators, government authorities or other third parties may request information from us. We may share your Personal Information and sensitive Personal Information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Asset purchasers. We may share your Personal Information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses it in a manner that is consistent with this Privacy Notice.

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on "International Data Transfer" below for more information.

7. Information Security and Storage

We implement technical and organizational measures (such as implementing security software and implementing reasonable access controls). Our servers also use up-to-date encryption methods, minimum standards for passwords, and secure storage methods to protect personal data. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your Personal Information for as long as you remain employed with us. Once our relationship with you has come to an end, we will retain your Personal Information for a period of time that enables us to:

• Provide you with any continuing benefits such as pension or insurance;
• Maintain business records for analysis and/or audit purposes;
• Comply with record retention requirements under the law;
• Defend or pursue existing or potential legal claims; and/or
• Address any queries or complaints you may have.

We will delete your Personal Information when it is no longer required for our legitimate business interests. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes we process your Personal Information for, and whether we can achieve those purposes through other means. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

8. International Data Transfer

We may need to transfer your Personal Information to a location outside of the jurisdiction where you are located, including to countries that do not offer the same level of protection with respect to Personal Information as required in your jurisdiction.

We have put in place appropriate safeguards (and where required, we have also implemented contractual commitments recognized by local law to establish adequate protections) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

9. Contact Us

Turnitin, LLC is responsible for the Personal Information we collect and process and, where applicable, are the Controller(s) of your Personal Information. If you have questions or concerns regarding the way in which your Personal Information has been used, please contact us at the details below.

We are committed to working with you to honor the exercise of your rights regarding Personal Information and/or to obtain a fair resolution of any complaint or concern you have about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority.

10. Changes to the Policy

You may request a copy of this Privacy Notice from us using the contact details set out above. We may modify or update this Privacy Notice from time to time.

If we change this Privacy Notice, we will notify you of the changes. Where changes to this Privacy Notice will have a fundamental impact on the nature of the processing or otherwise
have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have (e.g., to object to the processing).

Annex A

Employer Contact Information