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TriNet Privacy Policy
Effective date: June 28, 2023
We believe that protecting the personal information relating to our customers, colleagues, and worksite employees (“WSEs”) is our number one priority. We believe that you should know what we do with your information, who we share it with, and the business reason for sharing.
Our business is delivering industry-leading HR outsourcing services to our customers, not selling information.
We only collect and store the personal information we need to provide our services.
In order to assist with the review of this Privacy Policy, we have added quick links to each section below:
Quick Links
How We Collect Personal Information
Personal Information We Collect
Disclosure of Personal Information
How Long TriNet Retains Your Personal Information
How We Protect Your Personal Information
Changes to this Privacy Policy
Opt-Out of Marketing Communications
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Scope and Overview
This Privacy Policy (“Policy”) applies to our privacy practices both offline, such as through a phone call, and online through the TriNet.com website, the TriNet technology platform, and all other sites owned by TriNet Group, Inc. and its subsidiaries, including TriNet HR I, Inc., TriNet HR II, Inc., TriNet HR III, Inc., TriNet HR XI, Inc., TriNet Professional Employer Services, Inc., and TriNet USA, Inc., (collectively, “TriNet,” “we,” “our,” or “us”). For ease of use, when we refer to “Site” or “Sites,” we mean any and all of the TriNet owned sites where this Policy is posted.
This Policy does not apply to any information that you may provide directly to third parties including via links appearing on the Site.
By accessing this Site, or providing information to a TriNet representative, you are giving TriNet your consent to collect, use, and disclose your information as described in this Policy.
How We Collect Personal Information
Employer or Self-Provided Information. In order to provide our services to you, TriNet may collect personal information directly from you or your employer. Please note that the provision of such personal information may be a contractual requirement of your employment. Failure to provide such personal information may limit your eligibility for certain positions or disqualify you from receiving TriNet’s services.
We collect information you provide when you interact with the Site, use our chat feature to speak with a TriNet representative, and apply or inquire about job opportunities. If you send us proposals or personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect and store such information.
Automatically Collected Information. TriNet automatically collects certain technical information when you access the Site, including your IP address, browser type, operating system, the type of device you are using, and the device identifier. TriNet, and its affiliates, suppliers, and service providers, also use technologies such as cookies, beacons, tags, and scripts in order to gather information regarding your use of the Site. This includes information such as page views, which URL you just came from (whether on our site or not), and which URL you go to next (whether on our site or not). This allows us to analyze trends, administer the Site, to advertise our services to you, and gather demographic information about our user base as a whole. We use cookies on certain pages of the Site. Some features of the Site may only be available through the use of a cookie. Most cookies are “session cookies,” meaning they are automatically deleted at the end of a session. We also use persistent cookies. A persistent cookie remains on your hard drive for an extended period of time and remembers your preferences. You are always free to decline cookies if your browser permits, although in that case you may not be able to use certain features of the Site and you may be required to reenter your password more frequently during a session.
Data Obtained from Third-Party Sources. This Policy only covers collection of information by TriNet and does not cover the collection methods or use of the information collected by third parties.
We may collect and receive information about you, including personal information, from third parties, such as financial institutions, insurance carriers and third-party administrators, as well as our service providers and social media sites for the purposes described in this Privacy Policy.
TriNet may also collect business contact information about you from other sources including third parties from whom we have purchased business contact information and from publicly accessible websites, such as your company’s website, professional network services, or press releases. Business contact information may include: first and last name, business email, telephone number, company name, job level, functional role, business street address or zip code, online identifier, employment history. In some instances, we may combine personal information you have provided to us with personal information collected from other sources as described above. We use this data for our internal analytics, to identify prospective customer marketing opportunities, and to improve the relevance of our Site content and our advertising.
We partner with third parties to manage our advertising on other websites. These third parties may set and use cookies or similar technologies to collect information about your online activities over time and across different websites in order to provide you with advertising based upon your browsing activities and interests. For more information about third party advertising, please visit the Network Advertising Initiative at www.networkadvertising.org.
Use of Personal Information
We use the information we collect to respond to your requests, protect the security or integrity of our Site, improve our marketing and promotional efforts, statistically analyze Site usage, improve our content product offerings, and customize our Site's content, layout, and services.
The personal information we collect may be used for one or more of the following business purposes:
Delivering our products and services, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, or providing other HR outsourcing services.
To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax document, we will use that information to prepare the document and submit it to the applicable taxing authorities.
To provide you with information about TriNet’s products and services.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To validate user information for fraud and risk detection purposes and prevent or stop any activity that may be illegal, unethical or legally actionable.
To improve our website and present its contents to you.
For testing, research, analysis, and product development.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We may additionally use your information for the following purposes:
Business operations, such as managing the company’s assets; allocating human resources; safeguarding IT infrastructure, equipment, and other TriNet property; preventing and managing security incidents; issuing equity awards; administering occupational health and safety initiatives; authenticating worker status to authorize access to TriNet resources and facilities; selecting and managing contractors, vendors, and suppliers; maintaining business records, compiling audit trails, and implementing other reporting tools; contacting personnel and others in case of emergency; for purposes of helping to reduce the spread of disease; and other general administrative and operational tasks.
We may use the information you provide to us in connection with a job application or inquiry, such as information contained on a resume or a curriculum vitae, throughout TriNet for the purpose of employment consideration or responding to your inquiry. We may keep your information on file for future consideration.
Personal Information We Collect
The categories of personal information we collect, the business purposes (from the list above) for which they may be used and the categories of service providers and other third parties that we have disclosed information to include:
Category | Example | Business Purposes(s) | Categories of Service Providers | Categories of Third-Party Recipients |
Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, taxpayer identification number, date of birth, photos, or other similar identifiers. | 1, 2, 3, 4, 5, 6, 7, 8, 9 | Client companies Recruiting service providers Health and welfare service providers Employment screening service providers Financial service providers | Marketing service providers Sales service providers |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. | 1, 2, 3, 4, 6, 7, 8, 9 | Client companies Recruiting service providers Health and welfare service providers Employment screening service providers Financial service providers | None |
Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | 1,2, 3, 5, ,7, 8, 9 | Client companies Recruiting service providers Health and welfare service providers Employment screening service providers | None |
Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Not Collected | None | None |
Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | Not Collected | None | None |
Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | 1, 2, 3, 5, 6, 7, 8, 9 | Client companies Website analytics service providers | Marketing service providers Sales service providers |
Geolocation data. | Physical location or movements. | 1, 2, 6, 7, 8, 9 | Client companies | None |
Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | 1, 2, 6, 7, 8, 9 | Client companies | None |
Professional or employment-related information | Current or past job history or performance evaluations. | 1, 2, 7, 8, 9 | Client companies Recruiting service providers Health and welfare service providers Employment screening service providers | None |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | 1, 2, 7, 8, 9 | Client companies Health and welfare service providers Employment screening service providers | None |
Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | 2, 3, 4 | None | Marketing service providers Sales service providers |
In addition, for corporate Colleagues we may collect communicable disease related information. This includes contact tracing data, including travel information and close personal contacts, and symptomatic, medical or health information.
Examples included in a category in the list above indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all individuals.
For the purposes of the California Consumer Privacy Act of 2018 (“CCPA”), personal information does not include: publicly available information from government records; de-identified or aggregated consumer information; information excluded from the CCPA's scope, like 1) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; an 2) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice and an opportunity to consent.
We will retain your personal information for no longer than is necessary for the purposes stated in this Policy. Please see below under “How Long TriNet Retains Your Personal Information” for more details on our retention practices.
Please visit our Data Rights page to learn how to exercise your data rights.
Social Security and Social Insurance Number Protection Policy Statement
TriNet collects Social Security or Social Insurance numbers and other sensitive personal information from you in order to provide you our services. We limit our use of Social Security or Social Insurance numbers and other sensitive personal information to circumstances where it is necessary and is used and disclosed for the purposes described in this Policy.
Disclosure of Personal Information
We may use service providers, contractors and other third parties to operate our Site, provide our services and cater them to you. When we provide information to service providers and other third parties, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may disclose information to law enforcement, regulatory authorities, or other third parties under certain circumstances, such as to comply with a subpoena or similar legal process, or to comply with government reporting obligations. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose information in accordance with the law when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others; or to detect, prevent, or respond to fraud, intellectual property infringement, violations of this Privacy Policy, our Terms of Use, violations of law, or other misuse of our Site.
We may disclose your information to TriNet subsidiaries and affiliates in order to identify business opportunities and market our products and services to you. We may transfer your personal information as part of a sale or transfer of all or a relevant portion of our business or assets. In such events, we will use commercially reasonable efforts to help ensure that your personal information will be subject to appropriate privacy protections, in accordance with applicable privacy law.
To the extent that the collection or sharing of Personal Information through any cookies or similar technologies, as applicable, constitutes a “sale” or “share” under the CCPA, a California consumer can exercise the right to opt out by using a web browser that supports do-not-track functionality, by manually opting out in our Cookies Preference Center by visiting our Privacy page and clicking on the Cookie settings button and opting out of Advertising Cookies, or by clicking on the Do Not Sell or Share My Personal Information link at the bottom of each page of TriNet.com.
Your Privacy Rights
Depending on where you are located, or what state you are a resident of, you may have certain legal rights regarding the personal information we process about you. If you are a California resident, the CCPA provides you with specific rights regarding your personal information:
Right to know about personal information being collected, disclosed or sold, and to access such information
Right to correct inaccurate personal information
Right to delete the personal information
Right to opt-out of the selling or sharing of personal information
Right of no retaliation following opt-out or exercise of other rights
Right to opt-out of the use of decision-making technologies
Right to limit the use and disclosure of sensitive personal information
We do not provide programs, benefits, or other offerings, including payments to you, for the collection, retention, sale, or sharing of your personal information.
TriNet uses and discloses sensitive personal information about you in a reasonable manner to provide our products and services.
The CCPA allows California consumers to use Authorized Agents to submit requests to TriNet on their behalf.
Please visit our Data Rights page to learn how to exercise your data rights.
Non-California residents may access the TriNet Platform to view and correct the information TriNet stores about you.
Our promise not to discriminate against you for exercising your rights
We will not discriminate against you for exercising any of your rights related to accessing or deleting your personal information. Unless permitted by applicable law, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How Long TriNet Retains Your Personal Information
We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law and subject to our retention and disposal policies as may be in place from time to time. The data storage period may vary with scenario, product, and service. The standards TriNet uses to determine the retention period are as follows: the time required to retain personal information to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the Site; handling possible questions or complaints; compliance with legal obligations; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention.
We review our retention periods for personal information on a regular basis, and all data is retained in compliance with applicable laws.
How We Protect Your Personal Information
We employ commercially reasonable technical, administrative, and physical measures designed to protect your information from unauthorized access and use, and to comply with applicable privacy laws. We monitor our Services for potential vulnerabilities and have implemented security controls which require our service providers and other third parties to have appropriate safeguards to protect your personal information. You may read more about our security and privacy safeguards in our TriNet Information Security and Privacy Whitepaper that can be found by visiting our Privacy page.
Despite these efforts, no security measures are impenetrable, and no method of data transmission can be guaranteed to be 100% secure from interception or other type of misuse.
Our Site may provide you with links to other websites. We are not responsible for those sites and cannot control the use of information that you submit once you reach those sites, nor can we control the content of what is offered on those sites or on links from those sites.
Cookies and Do Not Track
We and our service providers also use technologies such as cookies, beacons, tags, and scripts in order to gather information about your use of the Site. This includes information such as page views, which URL you just came from (whether on our Site or not), and which URL you go to next (whether on our Site or not). This allows us to analyze trends, administer the Site, and gather demographic information about our user base as a whole.
Most cookies are "session cookies," meaning they are automatically deleted at the end of a browsing session. We and our service providers use session cookies to make it easier for you to navigate the Site. We also use persistent cookies. A persistent cookie remains on your hard drive for an extended period of time after you finish browsing a website and remembers your preferences.
You may opt-out of these technologies (except for essential website cookies) using a web browser that supports do-not-track functionality such as Global Privacy Control, by manually opting out in our Cookies Preference Center by visiting our Privacy page and clicking on the Cookie settings button and opting out of Advertising Cookies, or by clicking on the Do Not Sell or Share My Personal Information link at the bottom of each page of TriNet.com.
You can learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block them using different browsers. If you choose to block cookies, you may not be able to use the full functionality of our Site.
Automated Decision Making
We may, in some cases, use automated processes to assist our internal teams with making decisions, if it is necessary for the performance of a contract, if it is authorized by law, or if you have provided explicit consent. We do not use fully automated decision-making technologies (i.e., automated technologies that do not require human intervention) to analyze or predict aspects concerning your personal preferences, economic situations, or behavior.
Do Not Track
Some browsers may transmit “do-not-track” signals to the Site when you visit us online. Our Sites currently respond to some “do-not-track” signals such as Global Privacy Control.
You can learn more about Do Not Track and Global Privacy Control by visiting https://allaboutdnt.com and https://globalprivacycontrol.org.
Children’s Privacy
TriNet’s Sites are not intended to be used by children. We do not knowingly collect personal information from children under the age of 13, or 16 in California. If we obtain knowledge that we have personal information about a child under 13 who visit our Site, we will take steps to delete that information from our existing files.
If you are a WSE or Colleague who enrolls your dependents in health care insurance, we will collect information from you about your dependents—including those under the age of 13—so that we can provide those benefits.
Social Media Widgets
Our Site may include social media features, such as the Facebook™ button, and widgets such as the ShareThis™ button, or interactive mini programs that run on our Site. These features may collect your IP address and which page you are visiting on our Site. They may also set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company, social media platform or third-party service, providing it.
Changes to this Privacy Policy
We reserve the right to change this Policy at any time without prior notice. If we update this Policy, we will notify you by posting a new version on this page. Please check here regularly to learn of any changes. When we make material changes to this Policy, we will take reasonable efforts to provide notice to you, such as displaying a banner on our Site. We encourage you to periodically review this page for the latest information on our privacy practices.
Opt-Out of Marketing Communications
We may use the contact information we collect from you to contact you regarding administrative notices, new product offerings, and communications relevant to your use of our Site, to the extent permitted by applicable law. In some cases, we may use your information to inform you of new services, promotions, and other matters targeted to your interests. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these emails or by sending an email to communications_preferences@trinet.com.
How to Contact Us
If you have any questions or complaints regarding this Policy, please contact us at:
TriNet Group, Inc.
One Park Place, Ste 600
Dublin, CA 94568
Attention: Privacy Office
You may also contact us via email by sending a message to TriNet customer support.
If you are a Canadian resident and are not able to resolve your concern by contacting us, you may contact your provincial Privacy Commissioner or the Privacy Commissioner of Canada here.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
TriNet participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland, respectively, to the United States. TriNet has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit http://www.privacyshield.gov.
International Data Transfers & Privacy Shield Notice
This section is applicable to personal information of individuals in the European Union (“EU”) and Switzerland transferred to the United States. TriNet is responsible for the processing of personal information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. TriNet complies with the Principles for all onward transfers of personal information from the EU, including the onward transfer liability provisions.
Notice: We will inform you of the purpose for which we collect and use your personal information and the types of non-agent third parties to which we disclose or may disclose that information. We will provide you with the choice and means to limit our use and disclosure of your personal information for a purpose other than that for which it was originally collected.
Choice: We will offer you the opportunity to choose (opt out) whether your personal information is 1) to be disclosed to a third party (other than a vendor or service provider we have contracted with in connection with providing payroll, benefits, and other related services), or 2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. We will obtain express consent when required by applicable law.
Onward Transfers: Prior to disclosing personal information to a third party (other than the service providers referred to above), we will notify you of such disclosure and allow you a choice (opt out) regarding such disclosure. We will contractually require that any third party to which personal information may be disclosed will provide the same level of privacy protection as is required by the Principles.
Data Security: We will take reasonable steps, proportionate to the sensitivity of the personal information, to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure personal information from loss, misuse, and unauthorized access or disclosure, alteration, or destruction.
Data Integrity and Purpose Limitation: We will only process and use personal information in a way that is compatible with and relevant to the purposes for which it was collected, or authorized by you, including the purposes to provide payroll, benefits, and related services. To the extent necessary for those purposes, we will take reasonable precautions to ensure that personal information is accurate, complete, and current. Additionally, personal information may be retained in a form identifying or making identifiable individuals only for as long as it serves a purpose for which the data was collected or as authorized by the individual.
Access: We will provide you access to your personal information and allow you to correct, amend, or delete inaccurate information, except, to the extent permitted by applicable law, where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated. If access to personal information is denied, we will provide you with the reason for such denial. You may request the correction, amendment, or deletion of your inaccurate personal information by contacting TriNet customer support. We will respond to any such requests within a reasonable timeframe.
Enforcement: We use a self-assessment approach to assure compliance with this Privacy Policy. We will periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented, and accessible, and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided below. We will investigate and attempt to resolve any complaints and disputes regarding the collection, use, and disclosure of personal information in accordance with the Principles and this Privacy Policy.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints should first contact TriNet by emailing TriNet customer support or by contacting us using the details provided below. TriNet has further committed to refer unresolved Privacy Shield complaints to the panels established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC), alternative dispute resolution providers located in the EU and Switzerland. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Principles. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit EU DPA or FDPIC for more information or to file a complaint. The services of EU DPA and FDPIC are provided at no cost to you.
TriNet commits to cooperate with EU DPAs and the FDPIC and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
TriNet is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the statements in this Policy.
