California Applicant Privacy Notice
Scope: Applicants of Penske Truck Leasing Co., L.P. and Penske Logistics LLC that are residents of California.
Purpose: Penske is committed to protecting the privacy of individuals. As part of this commitment, Penske takes steps to protect the privacy of personal information of job applicants. This policy has been adopted based on the notice requirements of the California Consumer Privacy Act and its regulations (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).
I. Introduction
As part of the career application process with Penske, Penske needs to collect personal information from you. It is important to us that you understand how this information is collected, processed, shared and secured.
II. Personal Information Collected and Disclosed
Depending on the position you are applying for, Penske collects various personal and other information about you. The categories of personal information include the following:
- Identification data, such as name, social security number, driver’s license number.
- Contact details, such as home address, telephone numbers, email addresses, and emergency contact details.
- Characteristics of protected classifications under California or federal law, such as ethnicity, race, and gender.
- Internet or other electronic network activity information, such as IP address, log-in information, or information regarding your interaction with a website, application or advertisement.
- Communication details, such as chats if you interact with a chat feature on our websites.
- Health and medical information, such as drug screening results and a physical exam depending on the role for which you are applying.
- Audio, visual, olfactory information, such as your image or voice.
- Professional or employment information, such as employment history, references, and other information included in your resume or cover letter.
- Education information, such as education history, and other information included in your resume or cover letter.
We collect the following categories of sensitive personal information from you:
- Social security number and driver’s license.
- Racial or ethnic origin.
- Health information as described above.
III. Retention of Personal Information
Penske intends to retain each category of personal information identified above only for as long as is necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average applicant’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information, the nature of the personal information, the sensitivity of the personal information, our legal obligations related to the personal information, and the risks associated with retaining the personal information.
IV. How We Collect Your Personal Information
We may collect personal information from a variety of sources and methods. This includes:
- Information You Voluntarily Provide to Us – Penske may collect personal information from you that you voluntarily provide us as an applicant.
- Information We Collect When You Use Our Systems or Enter a Penske Facility – We collect personal information from your use of our website through cookies, interact with a chat feature on our website, through CCTVs at our locations, or through video interviewing.
- Information We Collect From Third Parties – We collect Personal Information from service providers, such as medical professionals, background check providers, and others.
V. How We Use Personal Information
Penske uses personal information, for all purposes related to your application for employment with Penske and for all purposes related to Penske. These purposes include, but are not limited to, the following:
- For analytic purposes in order to improve the website experience.
- To better understand how individuals use and navigate our websites.
- To market job opportunities to you.
- Making a decision about your recruitment.
- To assess your skills, qualifications, and suitability for the work or role for which you are applying.
- To carry out background and reference checks, where applicable.
- To communicate with you.
- Confirming you are legally entitled to work in the United States.
- Business management and planning, including accounting and auditing.
- Assessing qualifications for a particular job or task.
- Education, training, and development requirements.
- Dealing with legal disputes, involving you, or others.
- Ascertaining your fitness to work.
- To prevent fraud.
- To conduct data analytics studies to better understand employee application process.
- Equal opportunities monitoring.
- To exercise Penske’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
- To meet legal and regulatory requirements including discovery in litigation involving Penske or affiliated companies.
- To facilitate administrative functions, including, but not limited to, the management and operation of information technology and communications systems, security, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning.
- We use sensitive personal information only as necessary: (i) to process your request for employment; (ii) to comply with the law; and (iii) for business purposes reasonably expected within the scope of your application.
VI. How We Disclose Your Personal Information
Personal Information We Disclose for a Business Purposes
- Service Providers: We may use third-party services providers to perform certain business services on behalf of us and may disclose personal information to such service providers as needed for them to perform these services. Service providers are only allowed to use, disclose, or retain the personal information to provide these services and are prohibited from selling personal information. Business services provided include, but are not limited to, background checks, drug testing, medical examiners as applicable.
- Internal Third Parties: We may share Personal information with our parent company, subsidiaries and other companies owned by or controlled by Penske, who may use the personal information for the purposes described above.
Personal information Sold or Shared. We have not sold or shared any personal information in the past twelve (12) months.
Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Policy.
Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
Information You Provide to a Third Party. Penske may contract with third party service providers that operate their own websites and online platforms on which you will need to create an account (“Third Party Sites”). Penske does not control any Third Party Sites and is not responsible for any information they may collect. The information collection practices of a Third Party Site are governed by its privacy policy. It is your choice to enter any Third Party Site. We recommend that you read its privacy policy if you choose to do so.
VII. Security
Penske takes a number of steps to safeguard your personal information. Penske maintains physical, technical, and administrative safeguards to protect your personal information. Encryption is used to secure certain personal information where deemed necessary. Furthermore, once the information has been received by Penske, security procedures and policies commensurate with industry standards are used to safeguard against loss, theft, unauthorized access, destruction, use, modification and/or disclosure.
VIII. Your Rights to Your Personal Information
Subject to certain limitations, if you are a California resident you may make the following requests with regard to your personal information. Please follow the instructions below to make these requests. Please note that while California law may allow individuals who are residents of California to make the following requests, Penske’s legal requirements may not permit, require, or authorize Penske to honor all requests.
- Right to know and right to access. You have the right to request certain information we have collected about you. Under the CCPA, you have the right to request: (1) specific pieces and categories of personal information we collected about you; (2) the categories of sources from which personal information was collected; (3) the business or commercial purpose for which personal information was collected; (4) the categories of personal information we disclosed; and (5) the categories of third parties with which we shared personal information. Please note that there are circumstances in which we may not be able to comply with your request, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if that is the case.
- Right to delete. You have the right to request that we delete certain personal information that we have collected. Please note that there are circumstances in which we may not be able to comply with your deletion request. For example, we may need to retain certain data for HR or litigation purposes. We will notify you following submission of your request if that is the case.
- Right to correct. You have a right to request that we correct any inaccurate personal information we may retain about you.
- Right to opt-out. You have the right to request Penske not to sell your personal information. Penske does not sell your personal information. However, some transfers of personal information are considered “sales” under applicable law even if monetary consideration is not involved. This may include the use of cookies. You may also have the right to opt out of the sharing of your personal information. Sharing is defined under these local laws to mean the disclosing of your personal information to third parties for cross-context behavioral advertising. Cross-context behavioral advertising is done through the use of third-party cookies. We use cookies as described above in this Privacy Policy. You can opt out of the use of non-essential cookies via here.
- Right to limit. You have the right to instruct us to limit the use and disclosure of your sensitive personal information if we collect or process sensitive personal information for the purposes of inferring characteristics about an associate. Penske does not collect sensitive personal information for the purposes of inferring characteristics about such associate.
- Non-discrimination. You have the right to exercise the above rights and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests, as permitted by the CCPA.
- Instructions to exercise your rights. If you would like to make any of the data requests listed above, please visit our Individual Rights Management portal or call (844) 967-0109 or email privacy@penske.com. The link will take you to an interactive webform that you can complete and submit to make a request that we will then verify. If you call the toll-free number, you will be asked to leave a voicemail and someone will return your call and log your request after speaking with you.
IX. Verification Process
Identity verification may be required prior to responding to an individual rights request. To verify your identity in Penske systems you will need to provide your first and last name, date of birth, email address, phone number, and state of residence. As long as we can confidently match the information you provided to the information in our systems, your identity will be considered verified.
X. Authorized Agents
You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Pursuant to the CCPA only an individual with power of attorney, or a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
Penske may require you or your authorized agent to do the following:
- Provide proof of your signed written permission for the authorized agent to submit a request on your behalf – We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
- Verify your identity with us directly – This does not apply if you have provided a valid power of attorney to the authorized agent.
XI. Personal Information of Minors
We do not store information from minors under sixteen (16) years old except as permitted by law. If you believe that a child has submitted personal information to Penske beyond what is legally necessary for employment, please contact us at the email address in the Additional Information section.
XII. Additional Information
If you would like additional information regarding this policy or how Penske handles your personal information, please contact us at (844)-967-0109, email us at privacy@penske.com or write to us at:
Penske Transportation Solutions
Attn. Legal
2675 Morgantown Rd.
Reading, PA 19607
XIII. Changes to our California Applicant Privacy Policy
Penske reserves the right to change, supplement and/or amend this notice at our discretion and at any time. When we make changes to this policy, the updated policy will be posted https://www.gopenske.com/privacy.
This Privacy Notice was last updated January 1, 2023.
XIV. Authorization
By submitting your personal information, you agree that Penske may process your personal information for recruitment, human recourses processes and background check purposes.