Privacy Notice for Job Applicants

Effective Date April 1, 2021

Introduction

Triple-S Management Corp., its subsidiaries and affiliates (as identified to you during your application process), (“Triple-S”, “we” or “us”) is the company that is recruiting for the job vacancy you have applied for. This Job Applicant or Candidate Privacy Notice (“Candidate Privacy Notice”) describes how Triple-S and its subsidiaries and affiliates, located in the United States’ Commonwealth of Puerto Rico, collect and process personal information online or offline during your application and recruitment process.

Triple-S values your trust, respects your privacy and is committed to the responsible management, use, confidential treatment and protection your personal information. Triple-S will only process your personal information in accordance with this Candidate Privacy Notice, unless otherwise required by applicable law.

Personal Information We Collect About You and How We Collect It

Personal Information

For purposes of this Candidate Privacy Notice, personal information means any information about an identifiable individual collected in connection with your application and recruitment process. Personal information excludes anonymous or de-identified data that is not associated with a particular individual.

When you apply for a vacant position at Triple-S, we will ask you to provide personal information about yourself so that we can evaluate your application. If this information is not provided, Triple-S’s ability to consider you as a candidate may be limited.

The types of personal information that Triple-S may collect as part of its recruitment activities include:

Information contained in your Application Form/Résumé/Cover Letter, including your name, title, contact details, employment history, experience, skills, qualifications/training, professional and other work-related licenses, permits and certifications held;
Information relating to character and employment references and work authorization status;
Background information such as your educational background, including degrees, certificates, transcripts, credit history and/or criminal background screenings (where relevant to your application and permitted under applicable law).
Publicly available information from public sources;
Any additional personal details that you otherwise voluntarily provide to us, such as personal and social preferences or hobbies.

For more information about certain technical information that Triple-S may collect from you about your visit to our websites using “cookies” and other similar technologies, please refer to our Website Terms of Use.

Sensitive Personal Information

Consistent with applicable law, we may ask questions about race/ethnic origin, veteran status, gender and disability of our applicants for the monitoring of equal employment opportunity compliance. However, for purposes of your application the submission of this information is completely voluntary. If you provide us with this information, it will not be considered in the recruitment process.

Consistent with the foregoing, and except as specifically requested or legally required, we ask that you avoid submitting information in your application which may qualify as sensitive information under applicable law. Sensitive information may include data about religion, health, ethnicity, age, gender identity, nationality, sexual orientation or political affiliation, among other. To the extent that you provide us with sensitive personal information, it is understood that you expressly authorize Triple-S to handle such information in accordance with this Candidate Privacy Notice.

If you have a disability and would like for Triple-S to consider an accommodation, you may provide that information during the recruitment process.

As set forth above, Triple-S may also inquire about criminal records following a conditional offer of employment, where permitted by applicable law.

Personal Information Collected from Third-Parties or Other Sources

As permitted by applicable law and/or in accordance with your consent, Triple-S may obtain information about you from third parties or other sources. By way of example, and where relevant to your application, Triple-S may conduct background screenings through a third-party service provider or verify information that you have in your application that relates to your past education, employment, credit and/or criminal history.

How Triple-S Uses Your Personal Information

The information you submit to Triple-S as part of your application and recruitment process will be used by us, as permitted by applicable law, for the following legitimate business purposes:

Assess your skills, capabilities and qualifications against the job requirements;
For applicant screening, verifying your information and carrying out employment, background and reference checks, subject to your consent or as required by law, where applicable;
Create a candidate profile which can be used to identify or consider you for additional professional opportunities that may be aligned with our needs and your interests (unless you have informed Triple-S that you do not want your information to be kept for such purposes);
Internal data and statistical analysis;
Keeping records related to our hiring process;
To comply with or monitor compliance with legal, regulatory or other corporate governance requirements;
Communicating with you about your application and the recruitment process.

In the event that Triple-S hires you, the personal information collected as part of your application and recruitment process may be incorporated into our human resources system and used to manage the new-hire process. Any such information can become part of your employee file and used for other employment related purposes.

Triple-S does not make automated decisions in relation to your application and recruitment process without human involvement.

Transfers of Personal Information Among Affiliates

Triple-S may share information of candidates with its affiliates that are involved in evaluating candidates for available positions. In doing so, Triple-S remains responsible for any personal information that is used among affiliates.

All access to your personal information for the purposes described in this privacy statement is strictly limited to personnel who need to have access so said information for purposes of exercising their obligations.

Disclosures of Personal Information to Third-Parties or Service Providers

At times, Triple-S may also share your personal information with third-parties or other service providers, such as recruitment agencies, consultants and background services. Should your information be shared in this way, Triple-S does so only on a “need-to-know” basis, providing only that information which is strictly necessary for the functions or services to be provided. Triple-S does not allow third-parties or other service providers to use your personal information for their own purposes. Triple-S will always seek to ensure that any third-parties or service providers who handle your personal information protect and treat said information in a confidential manner and in accordance with this privacy statement and applicable law.

Other Uses and Disclosures

As indicated above, Triple-S may also use and disclose your personal information as necessary or appropriate to comply with applicable law or legal obligations. By way of example, this can include responding to requests from public or government authorities (e.g. subpoenas, search warrants); as necessary to protect your vital interests (e.g. in the event of an emergency or for health and safety reasons if you attend an interview at our sites); or as necessary to exercise or defend our legal rights, including to prevent fraud or in connection with any reorganization, merger, joint venture or similar proceeding.

How Long Does Triple-S Keep Your Personal Information

Triple-S keeps your personal information in connection with the purposes described in this privacy statement in accordance with all applicable legal, regulatory or other corporate governance requirements. Once those requirements are met, Triple-S securely destroys your personal information in accordance with all applicable document retention periods and applicable laws and regulations.

Security and Confidentiality

Triple-S maintains and also requires that its service providers maintain, implement and comply with a written data and information security program that contains appropriate administrative, technical and physical safeguards designed to protect the security and confidentiality of your personal information.

Applicant Access and Choices Over their Personal Information

By registering with Triple-S’s career site you may access, review and change your personal information stored therein by logging into the site and updating your account information, as appropriate. To change personal information already submitted for consideration for a specific position, please update your profile and resubmit your application for that position. Triple-S encourages you to promptly update your personal information if it changes or is inaccurate.

When permitted by applicable law, you may review, access, correct, update, restrict or delete your personal information; request that we cease using your personal information, as permitted by applicable law, or request a copy of your personal information. You may make such request by contacting us as indicated below in the Inquiries or Concerns section. Triple-S will respond to your request consistent with applicable law.

For your protection, Triple-S may need to verify your identity before processing any request concerning your personal information.

Please note that certain personal information may be exempt from any of the foregoing requests pursuant to applicable data protection laws or other laws and regulations.

Job Applicant Representations and Responsibilities

By voluntarily submitting personal information during your application and recruitment you warrant and represent that all of the information provided is complete, accurate, truthful and not misleading in any way. Submitting inaccurate, incomplete or misleading information during the application and recruitment process may lead to the rejection of your application or, if identified following your employment by Triple-S, disciplinary action including termination of employment.

If you provide us with personal information of a reference or any other individual, it is your responsibility for providing notices and/or obtaining consent from that individual prior to submitting the information to Triple-S. By providing Triple-S with personal information of a reference, you hereby represent and warrant that you have obtained such person’s consent for Triple-S to collect and process such information as described in this privacy statement.

Furthermore, you hereby affirm that none of the information submitted to Triple-S as part of the application and recruitment process violates any third party’s rights.

Changes to the Candidate Privacy Notice

Triple-S may revise and update this Candidate Privacy Notice from time to time in its sole discretion to address organizational developments, changes in the recruitment or application process, or changes in applicable laws or regulations. All changes are effective immediately when posted on Triple-S’s career site.

If at any time Triple-S decides to use your personal information in a manner materially different from that stated at the time it was collected, you will be given notice.

Links from Third Party Websites

This Candidate Privacy Notice does not address, and Triple-S is not responsible, for the privacy, information or other practices of any third party operating any website or service that may link or make reference to Triple-S’s career site. The inclusion of a link by a third party to Triple-S’s career site does not imply and shall not be interpreted as an endorsement of the third-party website or service by Triple-S.

Candidates are encouraged to read the privacy notices or terms of use of those third-party websites or services when accessing them.

Acknowledgment and Consent

By applying for a vacant position at Triple-S and submitting personal information as part of your application and recruitment process, you are consenting to the use of your personal information as described in this Candidate Privacy Notice.

Inquiries or Concerns

If you have any questions about this Candidate Privacy Notice or concerns about how Triple-S manages your personal information, please contact Triple-S’s Corporate Compliance & Ethics Director at or 787-749-4949. In doing so, however, please refrain from including sensitive information in your email(s) to us.