People Operations Data Acceptable Use Policy 

Geotab’s People Operations department requires certain personal data about employees, consultants, and contract staff (“Staff”) to  manage professional relationships, and drive organizational efficiency. This People Operations Data Acceptable Use Policy (“Policy”) outlines how Geotab collects and processes such data. In all cases, Geotab handles personal data in accordance with our Privacy Policy and applicable law.

Acceptable Use of People Operations Data By Geotab

Geotab utilizes People Operations Data (as defined below) (i) to administer the relationship between staff and Geotab (including processing payroll and benefits and managing performance); (ii) to evaluate and improve internal operations (including to maintain workplace security); and (iii) to monitor Geotab’s practices in regards to diversity and inclusion efforts to provide fair and equal opportunity to all. Geotab will not use People Operations Data for any reason or in any manner that is prohibited by law, or that is inconsistent with our Privacy Policy or this Policy. Geotab does not sell People Operations Data and does not share personal information for cross-context behavioural advertising purposes.

How Geotab Collects People Operations Data

Application & Recruitment: Geotab collects personal data a candidate provides at the time of application; additional information is collected and documented throughout the recruitment process.

Onboarding & Eligibility: Staff provide additional personal information upon commencement of work and as they become eligible for subsequent programs, such as certain medical benefit programs.

Administrative Generation: Geotab generates new information relating to the professional relationship throughout its duration through performance evaluations and the administration of company programs and benefits.

Voluntary Participation: Staff have the opportunity to volunteer personal information as part of internal company surveys, questionnaires, joining company clubs, or participating in corporate events.

Automated System Collection: Geotab collects data automatically through interaction with company systems. This includes logging usage patterns, communication history, and workflow activities generated while using Geotab-provided devices, software, and collaboration platforms.

What People Operations Data Geotab Collects

People Operations Data can be any data that is relevant to administer the relationship between Geotab and the staff (“People Operations Data”), including but  not limited to:

• Identification data, such as legal name, date of birth, social security number/social insurance number

• Contact information such as email address, home address , emergency contact and phone number
• Data regarding qualifications and interview questions/responses such as resume, proof of education
• Likes and interests such as clothing sizes
• Data to verify and complete third party background checks (as permitted by local law), such as:

• Previous employment history, work authorization documents
• Tax related or other financial information
• Any work relationships outside of Geotab

• Logs of Geotab system use

• Such as Google Workspace events

• Internal Communication Data
• Health data such as allergies, workplace injury details
• Protected class and/or sensitive data (only if volunteered)  such as ethnicity, veteran status, diversity related information

How Long Geotab Retains People Operations Data

Geotab will retain People Operations Data  only as long as necessary to fulfill the purposes described above, to comply with legal obligations and otherwise in accordance with Geotab’s Records Management Policy.   

Who Does Geotab Share People Operations Data With

Geotab will not share People Operations Data outside of the organization, other than to service providers under contract with Geotab to help administer the professional relationship with Geotab, assist Geotab in complying with its contractual and legal obligations, or fulfill the acceptable uses set out in this Policy.

Use of Artificial Intelligence (AI) and Automated Tools

Geotab leverages internal Artificial Intelligence and machine learning tools to drive organizational efficiency, identify workflow trends, and enhance workforce support resources. To protect the privacy and integrity of People Operations Data the following protections apply:

• Model Training Prohibitions: People Operations does not permit the use of People Operations Data (including internal communications or performance records) to train the underlying public models of third-party Generative AI providers.
• Closed Ecosystems: All AI-driven analysis is conducted within "closed" or enterprise-grade environments. This ensures that any data is not leaked into the public domain or used to improve external commercial AI products.
• No Automated Decision-Making: AI tools are used for augmentation and insights and are otherwise assistive in nature. Where Geotab utilizes automated employment decision tools or AI-assisted systems that support employment decisions (e.g. candidate screening, performance evaluation, or workforce management) Geotab complies with applicable local law governing such use. In all cases, AI tools are used to support, not replace, human judgment, and final employment decisions are subject to human review.

People Operations Data Security At Geotab

All People Operations  Data is stored in Geotab’s instance of Google Cloud Platform, and is subject to Geotab’s Role Based Access Control (RBAC) architecture to ensure that only Geotabbers that need to access Peoples Operations  Data can do so. This is part of Geotab’s Technological and Organizational Data Security Measures Statement, which governs all data that Geotab processes.  Geotab People Operations employees are trained on the permissible use of People Operations Data, in accordance with this Policy. Aggregated data is processed and stored in Geotab’s Data Analytics environment (currently Google’s BigQuery analytics solution) in accordance with the principles laid out in Geotab’s Data Analytics policy that is applicable to customer data.

In the unlikely event of a security incident, Geotab will follow procedures set in the Company’s Incident Response Program to assess, analyze and respond to the incident. This program’s embedded self improvement mechanisms serve to continuously advance processes and tools to measurably improve Geotab’s security posture.

Your Privacy Rights

Subject to applicable law, Staff may have certain rights in relation to their People Operations Data. For more information, please see the “Your Rights and How to Exercise Them” section of Geotab’s Privacy Policy. To exercise any of your applicable rights, please contact Geotab’s Privacy Team at: privacy@geotab.com. Geotab will respond to access and correction requests within 30 days, or such other period as required by applicable law.

International Data Transfers

People Operations Data may be transferred to, stored in, or accessed from jurisdictions outside of where you reside. Geotab takes steps to ensure that People Operations Data is subject to a level of protection consistent with applicable privacy law. These steps include entering into data processing agreements with service providers, incorporating appropriate contractual protections, and verifying that service providers maintain security standards consistent with Geotab’s obligations.

Staff located in Quebec should be aware that prior to transferring personal information outside Quebec, Geotab conducts or has conducted a Privacy Impact Assessment (PIA) as required by Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25) and implements contractual safeguards before such transfer takes place.

Geotab does not transfer People Operations Data to jurisdictions where Geotab cannot ensure adequate protections are in place.

Updates To The Policy

Geotab may make changes to this policy from time to time. The updated policy will become effective as of the date stated in the policy and following any additional steps Geotab may be required to take under applicable law.

Revision History