United States Candidate and Contractor Privacy Notice

Last updated: 29 September 2026

This Privacy Notice explains how TxODDS Group (“TxODDS,” “we,” “us,” or “our”) collects, uses, retains and discloses personal information about individuals in the United States who apply, are considered, or are assessed for employment, independent contractor, consultancy or other work opportunities with us (“Candidates” or “you”).

This Notice applies whether you apply directly, through a social media or professional networking platform, through a recruitment agency, or by another recruitment channel. It applies only to information handled by TxODDS in connection with recruitment or potential engagement.

A third-party platform may separately process your information under its own privacy notice.
For privacy questions or requests, contact us at scout.jobs@txodds.com.

1. WHO IS RESPONSIBLE FOR YOUR INFORMATION
This Notice is issued on behalf of TxODDS Group. References to TxODDS, we, us or our mean
the member of TxODDS Group responsible for the relevant recruitment or engagement process
and for the processing of your personal information.
You may contact us at scout.jobs@txodds.com if you wish to identify the relevant TxODDS
Group member responsible for a particular recruitment process or to exercise an applicable
privacy right.

2. PERSONAL INFORMATION WE MAY COLLECT
Depending on the role, recruitment process and applicable law, we may collect the following
categories of personal information:

• Identifiers and contact information, including name, postal address, email address,
telephone number, online identifiers and similar contact details.
• Professional, employment and education information, including résumé or CV information,
work history, job titles, qualifications, education, skills, professional memberships, references
and information about previous engagements.
• Application and recruitment information, including the role applied for, application
responses, correspondence, interview notes, assessment results, recruiter or interviewer
feedback, availability, work preferences and recruitment decisions.
• Internet, electronic and platform information provided to us or generated through
recruitment systems, including information submitted through social media, professional
networking, applicant tracking or recruitment platforms.
• Audio, visual or similar information where a recruitment process includes telephone, video
or recorded interviews, subject to any additional notice or consent required by applicable law.
• Background and verification information, where lawful and relevant to the role, including
information used to verify identity, qualifications, work history, references, eligibility to work,
or other lawful pre-engagement checks.
• Financial or compensation-related information that you voluntarily provide or that we
lawfully collect in connection with an offer or proposed engagement, but we will not request
salary history where prohibited by applicable law.
• Protected classification or demographic information where collected or required by law, or
voluntarily provided for lawful equal opportunity, reporting or compliance purposes. Where
practicable, this information is handled separately from recruitment decision-making.
• Sensitive personal information where necessary and permitted by law, such as government
identifiers or information required for eligibility, compliance, accommodation or onboarding.
We do not use or disclose sensitive personal information for purposes requiring a right to
limit under applicable law unless we provide the required right.
• Any other information you choose to provide during the recruitment or engagement
process.

3. SOURCES OF PERSONAL INFORMATION
We may collect personal information:

• directly from you;
• from recruiters, recruitment agencies, staffing providers and other persons or organisations
involved in your application;
• from references and former employers or clients, where permitted by law;
• from social media, professional networking sites, public websites and other publicly
available or legitimate professional sources;
• from background-check, verification or assessment providers, where permitted by law and
subject to any separate notices, authorisations or consents required; and
• automatically or through recruitment technology when you interact with our recruitment
systems or forms.

4. PURPOSES FOR WHICH WE USE PERSONAL INFORMATION
We may use Candidate personal information for the following business and recruitment
purposes:

• receiving, administering, reviewing and assessing applications;
• communicating with you about roles, applications, interviews, assessments and
recruitment decisions;
• comparing Candidates and determining suitability for employment, contractor, consultancy
or other work opportunities;
• conducting interviews, assessments and lawful pre-engagement checks;
• verifying information provided to us, references, qualifications and eligibility to work or
provide services;
• preparing and administering offers, employment agreements, contractor or consultancy
agreements and onboarding arrangements;
• managing and improving our recruitment processes, systems and workforce planning;
• maintaining recruitment records and, where appropriate, considering you for future
opportunities;
• protecting our systems, personnel and business and preventing fraud or misuse;
• complying with applicable legal, regulatory, reporting and recordkeeping obligations; and
• establishing, exercising or defending legal claims.

5. DISCLOSURE OF PERSONAL INFORMATION
We may disclose Candidate personal information for the purposes described in this Notice to:

• members of TxODDS Group and personnel involved in recruitment, management, legal,
compliance, finance, information technology or administration;
• recruitment agencies, staffing providers and professional advisers;
• applicant tracking, recruitment technology, communications, hosting, cloud storage,
assessment, verification and background-check service providers;
• service providers that support our information technology, security and business
operations;
• government authorities, regulators, courts, law enforcement or other persons where
disclosure is required or permitted by law; and
• a purchaser, investor, successor or other relevant party in connection with an actual or
proposed corporate transaction, subject to appropriate protections.
We do not sell Candidate personal information for monetary consideration. We do not sell or
share Candidate personal information for cross-context behavioral advertising as those terms
are defined by the California Consumer Privacy Act (“CCPA”).

6. RETENTION
We retain Candidate personal information only for as long as reasonably necessary for the
purposes described in this Notice, taking account of the recruitment process, whether you
become employed or engaged, applicable legal and recordkeeping requirements, limitation
periods, and the need to establish, exercise or defend legal claims.
As a general rule, recruitment records for Candidates who are not employed or engaged are
retained for up to one year after the relevant recruitment process ends, unless a longer or
shorter period is required or appropriate under applicable law or particular circumstances. If you
become employed or engaged, relevant recruitment information may become part of your
personnel, contractor or engagement records and may be retained under the applicable
workforce retention schedule.
Different categories of information may be retained for different periods. We may retain
de-identified or aggregated information for longer where it cannot reasonably be used to identify
you.

7. INTERNATIONAL PROCESSING
TxODDS Group operates internationally. Candidate personal information may therefore be
transferred to, accessed from, or stored in countries outside the state in which you reside and
outside the United States, including countries in Europe, where members of TxODDS Group or
our service providers operate. Privacy laws in those jurisdictions may differ from those in your
state.
We use reasonable contractual, organisational and technical measures designed to protect
personal information processed on our behalf.

8. SECURITY
We maintain reasonable administrative, technical and organisational safeguards designed to
protect Candidate personal information against unauthorised access, use, alteration, loss or
disclosure. No method of electronic transmission or storage is completely secure, and we
cannot guarantee absolute security.

9. U.S. STATE PRIVACY RIGHTS
Depending on your state of residence, the nature of the opportunity and whether the relevant
law applies to TxODDS and to the information concerned, you may have rights concerning your
personal information. These may include rights to request access to or information about
personal information we hold, correction of inaccurate information, deletion of certain
information, or a copy of certain information, subject to applicable exceptions.
Some U.S. state consumer privacy laws exclude some or all information collected in an
employment or workforce context. We will respond to a request in accordance with the law that
applies to you.
To submit a privacy request, contact scout.jobs@txodds.com. We may take reasonable steps to
verify your identity and authority to make the request. Where applicable, you may use an
authorised agent. We will not unlawfully discriminate or retaliate against you for exercising an
applicable privacy right.

10. CALIFORNIA NOTICE AT COLLECTION AND PRIVACY DISCLOSURES
This Section applies to California residents to the extent the CCPA applies to the relevant
TxODDS Group member and the personal information concerned.
Categories collected. During recruitment we may collect the categories described in Section 2,
which may correspond to CCPA categories including identifiers; personal records;
characteristics of protected classifications; commercial or financial information where relevant;
internet or other electronic network activity information; audio, electronic, visual or similar
information; professional or employment-related information; education information; sensitive
personal information; and inferences drawn from other information where we assess suitability
for a role or engagement.
Purposes. We collect and use those categories for the purposes described in Section 4,
including recruitment and selection, communications, assessments and verification, offers and
onboarding, administration and workforce planning, security, legal compliance, recordkeeping,
and establishing, exercising or defending claims.
Retention. We retain each category only for as long as reasonably necessary for the purpose for
which it was collected or another disclosed compatible purpose. The criteria used include the
duration of the recruitment process, whether you are employed or engaged, legal and regulatory
retention requirements, applicable limitation periods, dispute or claim requirements, and
operational recordkeeping needs. The general recruitment retention period is described in
Section 6.
Sale and sharing. We do not sell Candidate personal information or share it for cross-context
behavioral advertising.
California rights. Subject to the CCPA and applicable exceptions, California residents may have
rights to know/access, correct and delete personal information and to obtain information
concerning our collection, use and disclosure practices. Because we do not sell or share
Candidate personal information for cross-context behavioral advertising, we do not offer an
opt-out of such activity for Candidate information. Requests may be submitted to
scout.jobs@txodds.com.
Sensitive personal information. We use and disclose sensitive personal information only for
purposes permitted without providing a right to limit, unless we provide you with any additional
notice and right required by applicable law.

11. AUTOMATED TOOLS, ARTIFICIAL INTELLIGENCE, BIOMETRICS AND RECORDED
INTERVIEWS
We may use technology to support recruitment administration or assessment. Where applicable
law requires a separate notice, explanation, consent, authorisation, alternative process, impact
assessment or other safeguard before we use artificial intelligence, automated decision-making
technology, biometric information, recorded video analysis or similar technology, we will provide
the required information or obtain the required permission separately before using that
technology.
This Privacy Notice is not intended to replace any separate notice or consent required by a state
or local law for a particular recruitment technology.

12. BACKGROUND CHECKS
If we obtain a consumer report, investigative consumer report or other background check
subject to the federal Fair Credit Reporting Act or applicable state law, we will provide any
separate disclosure, authorisation, pre-adverse action notice, adverse action notice or other
document required by applicable law. This Privacy Notice does not replace those documents.

13. THIRD-PARTY AND SOCIAL MEDIA APPLICATION PLATFORMS
If you apply through a social media platform, professional networking service, recruitment
platform or other third-party service, that provider may separately collect and use your personal
information under its own terms and privacy notice. Information that you submit through the
service may be provided to us and handled by us as described in this Notice.

14. CHILDREN
Our recruitment processes are not directed to children under 13, and we do not knowingly
collect personal information from children under 13 through our recruitment process.

15. CHANGES TO THIS NOTICE
We may update this Notice from time to time. We will update the date at the top when we make
changes and provide any additional notice required by applicable law.

16. CONTACT
If you have questions about this Notice, want to identify the relevant TxODDS Group member
responsible for a recruitment process, or wish to exercise an applicable privacy right, contact us
at scout.jobs@txodds.com.