EU-US Data Privacy Framework Policy
This Data Privacy Framework Policy (“Policy”) describes how Tetra Tech, Inc. and its subsidiaries and affiliates in the United States (“US”) (“Tetra Tech”, “Company,” “we”, “us”, “our”) collect, use, and disclose certain personal identifiable information that we receive in the US from the European Economic Area (“EEA”) and the United Kingdom (“UK”) (“Personal Data”).
This Policy supplements our Website Privacy Statement and, unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Statement.
Tetra Tech recognizes that the EEA and the UK have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA and the UK. To provide adequate protection for certain Personal Data about clients, suppliers, business partners, job applicants and employees received in the US from the EEA and the UK, Tetra Tech has elected to self-certify to the EU-US Data Privacy Framework1 administered by the US Department of Commerce (“Data Privacy Framework”).
Tetra Tech adheres to the Data Privacy Framework Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Data Privacy Framework, Tetra Tech is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Data Privacy Framework, see the US Department of Commerce’s Data Privacy Framework website located at: https://www.dataprivacyframework.gov/s/.
To review Tetra Tech’s representation on the Data Privacy Framework List, see the US Department of Commerce’s Data Privacy Framework self-certification list located at: https://www.dataprivacyframework.gov/s/participant-search.
Personal Data collection and use
We may receive/collect the following categories of Personal Data in the US: identity data, contact data, employment related data, marketing and communications data, technical data, such as IP addresses.
The way in which we collect and process identity data (such as first name, last name, username or similar) will depend on how you interact with us through our website e.g., via contact us link, careers site. This is information you will provide via the website or other channels, and this also includes any contact data you provide, such as email address. We will use this information to respond to an enquiry you may have made or a job application you have submitted.
Employment related data captured via our careers site is required to make a decision on the job application submitted.
Additional personal data is collected and processed on appointment. The processing of employment data is necessary for compliance with employment legal obligations.
We will use your data to send you marketing information if you have requested to receive this from Tetra Tech.
Tetra Tech will only process Personal Data in ways that are compatible with the purpose that Tetra Tech collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for, or that you later authorized, we will provide you with the opportunity to opt out. Tetra Tech maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete and current.
We may collect the following categories of Sensitive Personal Data
We may collect the following categories of sensitive (special category) data revealing gender identity, racial or ethnic origin, religion, ethnicity, trade union membership, physical or mental health conditions, and Personal Data relating to criminal offences and convictions.
We process sensitive Personal Data for the purposes of monitoring Equality, Diversity and Inclusion and, in some instances, the information may be required for legal compliance.
When we collect sensitive Personal Data, we will obtain your opt-in consent where the Data Privacy Framework requires, including if we disclose your sensitive Personal Data to third parties, or before we use your sensitive Personal Data for a different purpose than we collected it for, or than you later authorized.
Data transfers to Third Parties
Third-Party Agents or Service Providers
We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf. Where required by the Data Privacy Framework, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Data Privacy Framework requires and limiting their use of the data to the specified services provided on our behalf.
We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Data Privacy Framework obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.
Third-Party Data Controllers
We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the Data Privacy Framework requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the Data Privacy Framework requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received.
Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Tetra Tech maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Data Privacy Framework.
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Data Privacy Framework.
These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.
If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us using the contact information listed in the ‘Contact Us’ section below.
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint.
For any unresolved complaints, we have agreed to cooperate with the independent dispute resolution mechanism of the International Centre for Dispute Resolution, the International Division of the American Arbitration Association (ICDR-AAA) (https://www.icdr.org/)
If you are unsatisfied with the resolution of your complaint, you may contact the U.S. Department of Commerce’s International Trade Administration (ITA), the EU data protection authorities (https://edpb.europa.eu/edpb_en) or the UK Information Commissioner (https://ico.org.uk/) for further information and assistance.
You may have the option to select binding arbitration before the International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA) for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Tetra Tech and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.
If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:
USA: [email protected]
UK/EU/EEA: [email protected]
Changes to this policy
We reserve the right to amend this Policy from time to time in line with the Data Privacy Framework’s requirements.
Effective Date: September 22, 2023