Employee Privacy Notice

United States and Canada

1. Purpose and scope

This notice explains what personal information Groundworks collects about its employees, job applicants, and contractors in the United States and Canada, why we collect it, who we share it with, and what rights you have over it. It applies to all Groundworks entities and affiliated brands operating in the US and Canada (“Groundworks,” “we,” “us”).

This is a workplace privacy notice, not an employment contract. It does not change the terms of your employment or any collective agreement that applies to you.

2. Who this notice covers

Current employees, including full time, part time, and seasonal field and office staff
Job applicants and candidates
Former employees, for as long as we hold your records
Independent contractors and temporary workers where we act as the party controlling their personal information

3. Personal information we collect

Depending on your role, we may collect:

Identity and contact information: name, address, phone, personal email, date of birth, government ID numbers (Social Security Number in the US, Social Insurance Number in Canada)
Recruitment information: resume, application, references, interview notes, work authorization/immigration status
Employment records: job title, department, start date, compensation, tax withholding, banking details for direct deposit, performance reviews, disciplinary records, training records
Timekeeping and scheduling data, including clock in/out records [and biometric timekeeping data such as a fingerprint or handprint scan, if your location uses a biometric time clock]
Benefits and health information: enrollment elections, dependent information, workers’ compensation claims, leave of absence and accommodation requests, and health information you choose to share with HR or a benefits provider
Vehicle and location data for employees who drive a company vehicle or use a company issued device with telematics, for routing, safety, and asset protection
IT and systems data: company email, network activity, and device usage on company issued systems, consistent with our IT acceptable use policy
Background check results where permitted by law (criminal history, motor vehicle records, and similar, generally through a third party consumer reporting agency)
Emergency contact information
Photos or video where used for ID badges, company marketing (with consent), or workplace security cameras

We do not collect more categories of sensitive information than we need for the purposes below, and we do not collect health or biometric information from Canadian employees without a lawful basis or your consent where consent is required.

4. Why we use your information

Running payroll, benefits, pension, and tax reporting
Managing recruitment, onboarding, and the employment relationship
Scheduling, timekeeping, and workforce management
Performance management, training, career development, and succession planning
Complying with labor, tax, safety, and immigration laws in the US and Canada
Workplace safety, including vehicle tracking for field crews, safety incident investigation, and workplace investigations.
IT security and protecting company systems and data
Internal reporting, audits, business operations, workforce planning, and human resources management
Defending or pursuing legal claims

We share employee personal information with:

Payroll and benefits administrators (for example, our payroll processor and health/retirement plan providers)
Background check and screening vendors
Government agencies where required, such as tax authorities, labor boards, and workers’ compensation bodies
IT and software vendors that host our HR, timekeeping, and email systems
Affiliated Groundworks brands and corporate entities for shared HR administration
Professional advisors (legal, accounting) as needed
A buyer or successor in the event of a merger, financing, or sale of all or part of the business

We do not sell employee personal information.

6. Cross border transfers

As the Company operates in both Canada and the United States, personal information of Canadian employees may be accessed, processed, stored, or transferred to service providers, affiliates, or Company personnel located outside of Canada, including in the United States. When personal information is transferred outside of Canada, it may become subject to the laws and lawful access requirements of the foreign jurisdiction in which it is processed or stored.

The Company takes reasonable measures to ensure that personal information transferred outside Canada remains protected through contractual safeguards, security controls, and privacy practices designed to provide a level of protection comparable to that required under applicable Canadian privacy laws.

For Quebec employees specifically, before any personal information is transferred outside Quebec, Groundworks will conduct an assessment confirming the information will receive protection equivalent to that required under Quebec’s private sector privacy law, as required by Law 25.

7. How long we keep it

We retain employee records for as long as needed to administer employment, meet legal and tax retention requirements, and defend against potential claims. Retention periods vary by record type and by jurisdiction; specific schedules are set out in our records retention policy [insert reference/link].

8. Security

We use administrative, technical, and physical safeguards designed to protect employee personal information against unauthorized access, loss, or misuse. Access to HR systems is limited to personnel who need it to do their jobs.

9. Monitoring in the workplace

Groundworks may monitor company email, company networks, company vehicles, and company issued devices for security, safety, and business purposes. Field vehicles may be equipped with telematics. Where required by state or provincial law, we will provide additional notice or obtain consent before starting a specific type of monitoring (for example, some states require notice before telematics of an employee’s personal vehicle, and Illinois, Colorado, and Texas each require specific notice and consent for biometric time clocks, under state-specific requirements outlined in Section 10). Connecticut, New York, and Delaware separately require prior written notice before we conduct electronic monitoring of an employee’s phone, email, computer, or internet activity, generally covering more than just vehicle telematics; New York also requires a signed or electronic acknowledgment from the employee and a posted notice. Connecticut updated its notice requirements effective October 1, 2026, to require the notice to identify the specific location(s) where monitoring occurs (for example, a particular facility or company vehicles) and to be posted at each monitored location.). Ontario employers with 25 or more employees are also required to maintain a written policy on electronic monitoring of employees and to provide it to staff; a copy of that policy is available from Human Resources.

10. Your rights: United States

California employees, applicants, and contractors (CCPA/CPRA)

If you work in California, or are a California resident applying for a job with us, you have the right to:

Know what personal information we have collected about you and how we use it
Request a copy of that information
Request correction of inaccurate information
Request deletion of your information, subject to legal exceptions (for example, we cannot delete tax or payroll records we’re required to keep)
Opt out of the sale or sharing of your personal information under certain state laws (Groundworks does not sell HR data, so this generally would not apply)
Limit the use of sensitive personal information, such as government ID numbers, or precise geolocation from a company vehicle or device where applicable
Not be retaliated against for exercising these rights

We will verify your identity before responding.

Illinois employees (biometric information)

Under the Illinois Biometric Information Privacy Act, before collecting a biometric identifier (such as a fingerprint scan for a time clock), we will provide written notice, state the purpose and retention period, and obtain your written consent. We will not sell, lease, or trade biometric data, and we will destroy it once the initial purpose for collecting it has been satisfied or within the timeframe required by law, whichever comes first.

Colorado employees (biometric information)

Under Colorado’s biometric data amendment to the Colorado Privacy Act, effective July 1, 2025, we do not need your consent to collect a biometric identifier for attendance monitoring, physical access, or workplace safety and security purposes, but we maintain a written biometric data policy covering retention and deletion, and we will delete your biometric identifiers on the schedule set out in that policy. If we use biometric data for any other purpose, we will ask for your consent first, and we will not make your employment conditional on giving it.

Texas employees (biometric information)

Under Texas’ Capture or Use of Biometric Identifier Act, before capturing a biometric identifier such as a fingerprint or voiceprint scan, we will inform you of the capture and obtain your consent beforehand. We will store and protect biometric data with reasonable care, will not sell, lease, or disclose it except as permitted by law, and will destroy it within a reasonable time.

Other states

A small number of other states are extending consumer style privacy rights to employees over time. Where a state law gives you additional rights not already described here, we will honor them and update this notice accordingly.

11. Your rights: Canada

Subject to applicable legal limitations, Canadian employees may request access to their personal information, request correction of inaccurate information, or ask questions about our privacy practices by contacting our Privacy Officer or designated Human Resources representative. Province specific rights are set out below.

Alberta and British Columbia (PIPA)

If you work in Alberta or BC, provincial private sector privacy law gives you the right to access the personal information we hold about you and to request correction of inaccurate information, subject to limited exceptions. We collect, use, and disclose your personal information only for purposes a reasonable person would consider appropriate in the circumstances. For Alberta employees, we also obtain your explicit consent to this processing as part of your signed offer letter, consistent with Alberta’s Personal Information Protection Act.

Ontario

Ontario does not have a comprehensive private sector privacy law that specifically governs employee personal information the way Alberta’s and British Columbia’s do. If you work in Ontario, your privacy protections instead come from a combination of employment law, common law privacy rights, your employment contract and workplace policies, any applicable collective agreement, human rights legislation, and Employment Standards Act requirements, including our written electronic monitoring policy. If you would like a copy of that policy, contact Human Resources.

Other provinces

Outside Alberta and Ontario, other provinces do not currently have a private sector law that specifically covers employee personal information the way PIPA and Law 25 do. Where that is the case, we still follow the practices in this notice as a matter of company policy, and general PIPEDA principles apply to any of your personal information we handle outside the employment relationship (for example, if you are also a customer).

Workplace investigations and employee relations records

We may collect, use, and retain personal information in connection with workplace investigations, employee relations matters, complaints, and compliance reviews where permitted by law. Access to these records is limited to individuals with a legitimate need to know, and records are kept according to our legal, regulatory, and record retention requirements.

12. Changes to this notice

We may update this notice from time to time as our practices or the law changes. We will post the current version in Workday and will let you know about material changes.