Last Updated: October 9, 2023
This California Employee and Job Applicant Privacy Notice/Policy (“Policy”) applies only to employees and job applicants that are residents of the State of California. The Policy describes how Old Dominion Freight Line (“OD”, “we,” or “us”) collects, uses, discloses, and processes your Personal Information (“you” and “your”). We reserve the right to change this Policy at any time. If we change the Policy, we will post an updated version on our Careers site as well as in Workday. Please check back periodically to see if this Policy has been updated. Updates to the Policy will be referenced by the “Last Updated” date shown above.
For individuals with disabilities, please contact us at 336-822-5932 or humanresourcesdepartment@odfl.com to discuss the best alternative method to access the information in this Policy.
This Policy supplements, and should be read in conjunction with, our website Privacy Policy.
1.) Definitions
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. “Personal Information” does not include: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregate information.
“Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of an mail, email, and text messages unless OD is the intended recipient of the communication; (f) genetic data; and (g) information about a known child. Sensitive Personal Information includes the processing of biometric information for the purpose of uniquely identifying an individual, Personal Information collected and analyzed concerning an individual’s mental or physical health and Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.
2.) Information We Collect, the Categories of Source of Collection and the Purpose for Collection
We collect a range of Personal Information about you. This includes information collected at the time you submit an employment application, your resume or writings samples, documents that you provide to us (in person or otherwise) during the employee onboarding process and/or during your employment with us. We may also obtain information from other sources.
Set forth below are the categories of Personal Information we collect and have collected in the preceding 12 months, the categories of sources from which the Personal Information was collected and the business or commercial purpose for such collection. Please note, we may not collect all of the information referenced below regarding you and we may not use your Personal Information for all of the purposes identified below.
Category of Personal Information | What We Collect | Categories of Sources from which Personal Information Collected | Business Purpose for Collection
|
PERSONAL INFORMATION | |||
Identifiers | Real name Alias Postal address Unique personal identifier Online identifier Alien Registration Numbers Internet protocol address Email address Telephone number Account name Social security number Driver’s license number Passport number Date of birth Dependent information Beneficiary information Signature
Country of citizenship Government service Names of relatives employed by us Invention disclosures Workers’ compensation information Emergency contact information (name; contact information; and relationship to employee) Characteristics or description Insurance policy number Bank account number Other financial information Medical information Health insurance information | Directly from you Automatically, such as when you visit our website (e.g., cookies on our websites) Our service providers
| To manage the recruitment process, evaluate and confirm an applicant’s qualifications for employment, and to make hiring decisions To take steps prior to entering into an employment relationship with you To manage our employment relationship with our employees Security To assess your working capacity To administer benefits To contact a designated emergency contact in the event of an emergency To keep records for our business operations To protect our, customer, and employee property, equipment, and confidential information To monitor employee performance To monitor employee statistics To enforce our electronic communications acceptable use policies To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting |
Protected Characteristics | Race Color Religion (includes religious dress and grooming practices) Sex/gender Pregnancy, childbirth, breastfeeding and/or related medical conditions Gender identity, gender expression Sexual orientation Marital status Medical Condition (including genetic characteristics, cancer or a record or history of cancer) Military or veteran status National origin Disability (mental and physical including HIV/AIDS, cancer, and genetic characteristics) Genetic information Age (over 40) Request for family care leave Request for Pregnancy Disability Leave
| Directly from you Automatically, such as when you visit our website (e.g., cookies on our websites) Our service providers
| To monitor employee statistics To make reasonable accommodations for employees who have a disability To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations
|
Commercial Information | Records of personal property, products or services purchased, obtained, or considered
| Directly from you Our service providers | In connection with employee relocations To recruit employees and perform background screening To manage wages and expenses
|
Biometric Information | Fingerprints Photographs Voice recordings Identifying medical information | Directly from you | To administer employee timekeeping and reporting* To manage our employment relationship with our employees Security To protect our customers, employees, property, equipment, and confidential information To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting *Please see our biometric policy for more information
|
Internet Information or Other Electronic Network Activity Information | Electronic network activity information Browsing history Search history Information regarding interaction with a website or application Corporate managed mobile device usage | Directly from you Automatically, such as when you visit our website (e.g., cookies on our websites) Our service providers | To manage our employment relationship with our employees To enforce our electronic communications acceptable use policies Operate and manage IT and communications systems and facilities Security To manage employee programs
|
Geolocation Data | Internet protocol address | Directly from you Automatically, such as when you visit our website (e.g., cookies on our websites) Our service providers | To manage our employment relationship with our employees Security |
Audiovisual Information | Electronic information (e.g., meeting recordings) Visual information (e.g., camera footage)
| Directly from you Automatically, such as when you visit our website (e.g., cookies on our websites) | To keep record of meetings in case necessary to refer to such information To manage our employment relationship with our employees Security |
Professional or Employment Information | Professional history Employment history Licenses and certification history Sanctions with professional bodies Pay rate/compensation Payroll deduction information Employment status (full-time or part-time, regular or temporary) Work schedule Job assignments Hours worked Business travel information Accomplishments and awards Training and development information Performance evaluation information Discipline and counseling information Employment termination information | Directly from you Our service providers Former employers | To manage the recruitment process, evaluate and confirm an applicant’s qualifications for employment and to make hiring decisions To take steps prior to entering into an employment relationship with you To manage our employment relationship with our employees To assess your working capacity To keep records for our business operations To monitor employee statistics To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting
|
Education Information | Educational history | Directly from you Our service providers | See previous row |
Inferences
Note: This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Predictive behavior information
Dominant influence, social, and compliance information Behavioral assessment information | Directly from you
| To manage the recruitment process, evaluate and confirm an applicant’s qualifications for employment and to make hiring decisions To take steps prior to entering into an employment relationship with you To manage our employment relationship with our employees To assess your working capacity To recruit employees and perform background screening
|
SENSITIVE PERSONAL INFORMATION | |||
Sensitive Personal Identifiers | Social security number Driver’s license information and status (including driver history, penalties, restrictions, and expiration dates) State identification card number Passport number or similar information Alien identification number | Consumer reporting agencies Service providers Directly from you | To monitor employee statistics To make reasonable accommodations for employees who have a disability To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations To recruit employees and perform background screening To manage wages and expenses To administer healthcare and other benefits Regulatory reporting |
Account Information | Information required to access your work account | Directly from you | To operate and manage our IT and communications systems and facilities Security |
Precise Geolocation | Electronic logging device information from trucks Key cards for employees | Automatically through electronic logging device technology Directly from you | To manage workforce activities and personnel Regulatory reporting |
Sensitive Protected Characteristics | Racial origin Ethnic origin Religious beliefs
| Directly from you
| To monitor employee statistics To make reasonable accommodations for employees To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations Regulatory reporting |
Contents of Communications | Email not intended for business purposes sent via OD systems, devices, and platforms Messages and materials in OD systems, devices, and platforms not intended for business purposes | Directly from you Our service providers Automatically when using OD systems, devices, and platforms | To monitor employee activity To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations Security Compliance |
Biometric Information (for the purpose of uniquely identifying you) | Fingerprints Photographs Voice recordings Identifying medical information | Directly from you Our service providers | To administer healthcare and other benefits To manage workforce activities and personnel Security |
Health Information | Medical history Job restrictions and medical limits Substance abuse testing Vaccine status Workplace accident and illness information Safety incident information Health insurance information Other information to determine reasonable accommodations Medical information (FMLA) Health insurance information Disability Information Other health information
| Directly from you Our service providers
| To manage our employment relationship with our employees Security To assess your working capacity To administer benefits To make reasonable accommodations for employees who have a disability To contact a designated emergency contact in the event of an emergency To keep records for our business operations To monitor employee statistics To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting |
Sex Life or Sexual Orientation Information | Sexual Orientation | Directly from you | To manage our employment relationship with our employees To administer benefits Regulatory reporting To comply with law or legal process, such as tax deductions, reporting, and record-keeping requirements |
We also collect Personal Information as necessary to respond to law enforcement, governmental agency (e.g., Federal Motor Carrier Safety Administration), etc. requests; comply with legal and contractual obligations; exercise legal and contractual rights; and initiate or respond to legal claims.
We collect Personal Information from you and service providers regarding your gap or travel activities, publicly sourced information (e.g., media or online information), civil court records, criminal history, appearance on sexual predator watch lists, foreign travel, foreign associates, names of all persons residing in the same domicile as you, names of extended family members and drug use for background checks and to comply with various legal requirements.
3.) Personal Information We Disclose About You and Its Business Purpose
We do not sell your Personal Information and we do not share your Personal Information for cross context behavioral advertising as those terms are defined by the California Consumer Protection Act (“CCPA”), as amended by the California Privacy Rights Act (CPRA”), and related regulations.
Your Personal Information may be disclosed internally for the purposes of recruitment, employee onboarding, and to manage our employment relationship with you. This includes, but is not limited to, disclosures to our Human Resources, Legal, and IT departments and staff; interviewers engaged in the recruitment process; and vice presidents, directors, managers and supervisors in a business area with a vacancy. We may disclose your Personal Information internally if such access is necessary for the performance of certain roles.
Your Personal Information may be disclosed to external service providers for the sole purpose of delivering products and services to us. For example, we may disclose your Personal Information with third-party background check providers to verify the information you have provided to us obtain the necessary background checks prior to extending an offer of employment. When we disclose Personal Information to our service providers we take commercially reasonable steps, including contract terms, to maintain the confidentiality of your information against unauthorized access, use, modification, or other misuse.
The business purposes for which we disclose Personal Information to our service providers, contractors, and vendors include:
- Auditing of Ad Impression: We disclose Personal Information for auditing purposes related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
- Functionality & Debugging: We disclose Personal Information to engage in debugging to identify and repair errors that impair existing intended functionality.
- Short-Term / Transient Use: We disclose Personal Information for short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s Personal Information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
- Services on Our Behalf: We may disclose Personal Information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing services for employees, processing or fulfilling requests and transactions, verifying employee information, processing payroll, expenses and payments, evaluating and responding to requests, providing storage, or providing similar services on our behalf.
- Advertising and Marketing Services: We disclose Personal Information to provide advertising or marketing services on our own behalf.
- Research & Development: We disclose Personal Information for internal research related to technological development and demonstration.
- Quality Control & Improvement of Products and Services: We disclose Personal Information to verify, maintain, and improve our products and services.
The following chart sets forth the categories of Personal Information we have disclosed to our service providers for a business purpose over the past 12 months.
Categories of Personal Information that We Disclose | Business Purposes for the Disclosure of Personal Information | |
PERSONAL INFORMATION |
| |
Identifiers | Auditing of Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products and Services | |
Protected Characteristics | Short-Term / Transient Use Services on Our Behalf | |
Commercial Information | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products and Services | |
Biometric Information | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf | |
Internet Information | Auditing of Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products and Services | |
Geolocation Data | Auditing of Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products and Services | |
Audiovisual Information | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products and Services | |
Professional or Employment Information | Security and Fraud Detection Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services | |
Education Information | Security and Fraud Detection Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services
| |
Inferences | Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services | |
SENSITIVE PERSONAL INFORMATION |
| |
Sensitive Personal Identifiers | Security and Fraud Detection Short-Term / Transient Use Services on Our Behalf | |
Account Information | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf | |
Precise Geolocation | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Research & Development Quality Control & Improvement of Products and Services | |
Sensitive Protected Characteristics | Security and Fraud Detection Short-Term / Transient Use Services on Our Behalf | |
Contents of Communications | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf | |
Sensitive Biometric Information | Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf | |
Sex Life or Sexual Orientation Information | Security and Fraud Detection Short-Term / Transient Use Services on Our Behalf | |
As Necessary: We may also disclose Personal Information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and to protect our/your/others rights, privacy, safety or property; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We only use Sensitive Personal Information for purposes disclosed herein. We do not use or disclose Sensitive Personal Information for purposes other than those specified herein.
4.) Our Retention Policy – How Long We Keep Your Personal Information
Your Personal Information may be stored in different places, including in your digital and paper applicant record, in HR management systems (paper and digital), with our service providers and other electronic or digital systems (including email).
We retain your Personal Information for the periods necessary to: (a) fulfill the purposes described in this Privacy Policy, (b) meet the timelines required or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.
To determine the appropriate retention period for Personal Information, we consider 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 for which we process your Personal Information and whether we can achieve those purposes through other means, and applicable legal requirements.
5.) How We Protect Your Personal Information
We take the security of your Personal Information seriously. We have implemented administrative, technical, and physical safeguards to protect your Personal Information from loss, accidental destruction, misuse, as well as unauthorized disclosure and access.
6.) Your Rights if You Are a Resident of California
California residents may be entitled to exercise certain privacy rights pursuant to the CCPA, as amended by the CPRA, and related regulations. Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.
- Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting and disclosing Personal Information; (4) the categories of third parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you. You also have the right to know the list of all third parties to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. You may submit a request by calling us at 1-800-235-5569, emailing us at privacy@odfl.com.
- Right to Know Personal Information Disclosed and to Whom. You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; and (2) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. You may submit a request by calling us at 1-800-235-5569, emailing us at privacy@odfl.com.
- Right to Request Deletion of Your Personal Information. You have the right to request that we delete your Personal Information, subject to a number of exceptions. Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records. If we cannot delete all of your Personal Information, we will let you know the reason. You may submit a request by calling us at 1-800-235-5569, emailing us at privacy@odfl.com.
- Right to Correct Inaccurate Information. If you believe that any of the Personal Information, we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct. You may submit a request by calling us at 1-800-235-5569, emailing us at privacy@odfl.com.
- Right to Opt-Out of the Sale and Sharing of Your Personal Information. As a California resident, you generally have the right to opt-out of the sale or sharing of your Personal Information. However, because we do not sell your Personal Information or use your Personal Information for cross-context behavioral advertising, this right does not apply when we collect and use your information.
- Right to Limit the Use of Your Sensitive Personal Information. We limit the Use of Your Sensitive Personal Information to the purposes listed above. Therefore, this right may not apply to you.
- Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.
When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:
- Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting, or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
- Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
- For requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
- For requests to know specific pieces of Personal Information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records for the legally required period.
- For requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete Personal Information, including an explanation of why we have no reasonable method to verify your identity.
If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; and/or (b) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.
We will respond to requests to know, requests to delete and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.
7.) Your Obligations
You are responsible for providing a copy of this Privacy Policy to your emergency contact and beneficiaries prior to disclosing their Personal Information. If you choose to provide us with a third party's Personal Information (such as name, email, and phone number), you represent that you have the third party's permission to do so.
8.) How to Contact Us
It is important that you understand this notice of OD’s compliance with applicable privacy regulations, together with all other privacy notices/policies OD may provide on specific occasions when collecting or processing Personal Information about you, so that you are aware of how and why we are using your Personal Information. If you have any questions about this Privacy Notice/Policy, how OD manages your Personal Information, or if you have questions or comments about OD’s compliance with California law related to your data protection rights, please contact us at privacy@odfl.com.
If you have any questions or concerns about our privacy policies and practices, please feel free to contact us by calling us at 1-800-235-5569, emailing us at privacy@odfl.com or by mail at:
Old Dominion Freight Line
Attention: Privacy,
500 Old Dominion Way
Thomasville, North Carolina 27360