Where we refer to ‘candidate personal data’, ‘employee’ or ‘employment’ in this Policy, we do so for convenience only and this should in no way be interpreted as purporting to confer employment status. This Policy does not form part of any contract of employment or engagement and does not confer any contractual right on you or place any contractual obligations on us.
PERSONAL DATA WE COLLECT
We collect, use and hold some or all of the following types of Personal Data in relation to candidates:
- name, address, and contact information;
- education information and previous employment background / work experience;
- curriculum vitae, résumé, cover letter and/or application form;
- any other information you have provided during the application process;
- employment preferences, willingness to relocate, desired salary;
- criminal record checks or other background verifications or references (only where applicable);
- interview notes and records, together with any information you provide to us during an interview;
- professional and other work-related licenses, permits and certifications held;
- language and other relevant skills;
- awards and professional memberships;
- eligibility to work in country where applicant’s job is located and available start date;
- feedback on our recruitment process;
- internet and other activity including browser or search history and information regarding your interaction with our websites or advertisements.
- general correspondence; and
- signed confidentiality agreements
We collect what is defined as ‘sensitive personal information’ under various state privacy laws. While such laws may provide an opt-out opportunity for this information, we use and disclose this information only for purposes permitted by law that do not require an opt-out opportunity.
HOW WILL WE COLLECT YOUR PERSONAL DATA?
We collect Personal Data about candidates through the application and recruitment process from the following sources:
- you, the candidate, including from written submissions (e.g., curriculum vitae, reference lists, cover letters, application forms, etc.) and other interactions we may have with you (e.g., written correspondences, interviews, etc.);
- recruitment agencies;
- publicly accessible third-party sources (e.g., LinkedIn, job boards, CV databases) including recruitment sites where you may have made your portfolio or employment interests available;
- consumer reporting agencies (but only for certain specified roles);
- pre-employment screening providers (but only for certain specified roles); and
- your named references
Where we collect information from third parties, we will obtain any required consents from you before doing so. To the extent you provide us with details of a reference or any other third party as part of your application, it is your responsibility to obtain consent from that third party prior to providing that Personal Data to us.
PURPOSE FOR PROCESSING
We may collect, use and disclose Personal Data for the following business purposes:
- recruitment / appointment to a role you have applied for, including processing your application, assessing your skills and competencies, qualifications and suitability for a role or type of work, and communicating with you in respect of your application or other inquiries;
- pre-employment screening and reference checks, where applicable and with your consent where required under applicable law;
- pre-employment credit checks, with your consent and where permissible by state and local laws, for positions with significant fiduciary responsibilities;
- communicating updates regarding your application and to facilitate your use of the career sites;
- record keeping in relation to our hiring process;
- protecting our legal rights and property;
- compliance with any legal or regulatory obligations;
- the use of survey information to identify opportunities and implement changes to make our recruitment processes more efficient, including through analytics and aggregate reporting;
- to de-identify or aggregate personal information collected about you and use it for any lawful purpose;
- monitoring and promotion of equal employment opportunities; and
- general business administration such as managing, administering and refining our application process
For certain activities where you have provided us with your consent, you have the right to withdraw your consent at any time by contacting us as set out below. We will inform you in advance if we intend to further process or disclose your Personal Data for a purpose other than the purposes set out above.
WHAT IF YOU DO NOT PROVIDE CERTAIN PERSONAL DATA?
Providing Personal Data to us is voluntary. However, please note that if you fail to provide sufficient information for us to evaluate your candidacy and/or comply with our legal obligations, the Enterprise entity to whom you are applying for a role may not be able to process your job application or consider your suitability for a particular role.
RECIPIENTS OF YOUR PERSONAL DATA
Your Personal Data may be disclosed to our HR team, the entity, affiliate or subsidiary to which you applied, relevant team managers, and other employees and departments who have a business need to access such Personal Data.
We may share Personal Data about you with selected service providers or consultants acting on our behalf that assist us in carrying out the purposes listed in the ‘Purpose for Processing’ Section of this Policy. For example, we may share Personal Data with the operators of our career sites (including Yello, Inc., iCIMS, Inc., and Radancy) as well as service providers that conduct background verifications. These service providers and consultants are given the information they need to perform their designated functions. These service provider or consultants are not authorized to use or disclose the Personal Data we provide them for their own purposes.
It may be necessary from time to time for us to disclose your Personal Data to other third parties, including without limitation to the following: (i) relatives or legal representatives of prospective employees; (ii) other organization(s) in connection with a proposed or completed corporate transaction involving all or part of Enterprise such as a merger, sale or bankruptcy; (iii) governmental authorities when required by law, in response to legal process, obligation, or request or to protect our rights or property.
SOCIAL MEDIA PLATFORMS AND NETWORKS
TRANSFERS OF PERSONAL DATA
The information that you submit in your application on the career sites will be stored and processed by us or our third-party service providers in the United States (as the servers for the application we use are located in the United States, see below for further details) and in the relevant country in which you are applying for a position.
UPDATING YOUR PERSONAL DATA
If you have registered for an account with our recruitment app or applicant tracking system, you may access, review and change some of the Personal Data we maintain about you by logging into your account. Any updates you make to your profile will be used the next time you apply for a job using your online account. To the extent a specific position which you have already applied for is still receiving applications, you may resubmit your application with the updated profile information to apply the changes to the previously submitted application.
Under California privacy laws, California residents have certain rights with respect to personal information about them we have collected. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
- right to access the personal information we have collected about you and learn how we collect this information, our purpose in collecting it, and the types of parties we may have disclosed it to;
- right to correct inaccurate personal information;
- right to delete the personal information we have collected from you;
- right to opt-out of our sale(s)/sharing of your personal information; and
- the right not to receive discriminatory treatment for the exercise of privacy rights conferred by California privacy laws
- The following categories of personal information disclosed are considered “sale”/ “sharing” under California law: device information and geolocation data.
- The following categories of third parties with whom personal information was disclosed are considered “sale”/ “sharing” under California law: social media platforms and networks.
We generally recognize commercially recognized opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not cross over to all devices/browsers you use to access the website.
If you have created an account and submitted personal information to our career sites, you may exercise your correction, deletion and access rights under California law by logging into your account at us-erac.icims.com. Once logged in, you will be able to view, correct or delete your personal information.
For questions or inquiries related to your rights under California law, submit your request through our GLOBAL PRIVACY PORTAL.
Our applications, career websites and online recruitment are not directed to, and we do not knowingly collect Personal Data from, children under the age of 16 (or your country’s age of minority). Nevertheless, if you believe that your child has provided us with their Personal Data and you need to let us know to delete it, please email us at email@example.com or you can submit that request through our Global Privacy Portal.
CHANGES TO THIS POLICY
As necessary, we may update this Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (to the extent your email address is available) or as otherwise may be required or permitted by law, prior to the change becoming effective with respect to Personal Data we previously collected about you. We encourage you to periodically review this Policy for the latest information on our privacy practices.
If you require any further clarification regarding this policy or you have questions or requests regarding the manner in which we or our service providers treat Personal Data, please feel free to contact us at firstname.lastname@example.org.
LAST UPDATED: July 2023