Notice: A German version is available for informational purposes only. This English version is the only enforceable Notice, irrespective of the candidate location.

What is the Purpose of This Document?

This Candidate Privacy Notice describes how Reputation.com, Inc. and its subsidiaries (“Reputation”, “we”, “us”, “our”) collect and use personal information about you during our recruitment process after you apply for a job with us, in accordance with applicable privacy laws, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and the General Data Protection Regulation (“GDPR”).

Reputation is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to all individuals going through the recruitment process with us, either directly or through any 3rd party agency or representative. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

What Data Protection Principles Do We Adhere to?

• Lawfulness, fairness and transparency
• Purpose Limitation
• Data Minimization
• Accuracy
• Storage Limitation
• Integrity and Confidentiality (security)
• Accountability

What Kind of Information Do We Hold About You?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymized data, or personal information which is impossible to identify the individual to whom the information relates.

There are “special categories” of more sensitive personal data which require a higher level of protection.

For candidates in the United States (“US”), we may collect, store, and process the following categories of sensitive and personal information about you, where allowed under applicable law:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Gender
• Right to work documentation, including birth certificate, passport, ID card, driving license, visa
• Start date
• Location of employment or workplace
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Previous employment records (including job titles, work history, working hours, training records and professional memberships)
• Photographs

We may also collect, store and use the following “special categories” of more sensitive personal information, where allowed under applicable law:

• Information about your nationality, race or ethnicity, religious beliefs, sexual orientation and political opinions
• Trade union membership
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offenses

For employees outside the US, we may collect, store, and process the following categories of personal information about you, where allowed under applicable law:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• National Insurance number
• Right to work documentation, including birth certificate, passport, ID card, driving license, visa
• Bank account details, payroll records and tax status information
• Salary, annual leave, pension and benefits information
• Start date
• Location of employment or workplace
• Copy of driving license
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Previous employment records (including job titles, work history, working hours, training records and professional memberships)
• Performance information
• Photographs

We may also collect, store and use the following “special categories” of more sensitive personal information, where allowed under applicable law:

• Information about your nationality, race or ethnicity, and gender
• Information about criminal convictions and offenses

How is Your Personal Information Collected?

We collect personal information about all individuals going through the recruitment process with us in any capacity, including employees, directors, agency workers, contractors, consultants, any other third-party representative, and business partners. Depending on your country of residence, this may be obtained through the application and recruitment process, either directly from candidates or sometimes from employment agencies, job boards, recruitment assessment centers, referees, or background check providers, where applicable according to local law. We may sometimes collect additional information from third parties including former employers, credit reference agencies or a professional body who will retain information regarding your background check, where applicable according to local law.

How Will We Use Information About You?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to administer the recruitment process.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).

2. Where it is needed in the public interest.

Which Situations Will We Use Your Personal Information?

We need all the categories of information in the list above primarily to allow us to administer the recruitment process with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information include, but may not limited to the following:

• Making a decision about your recruitment or appointment.
• Determining the terms on which you work for us.
• Checking you are legally entitled to work in the applicable country of employment.
• Paying you.
• Making decisions about compensation.
• Assessing qualifications for a particular job or task.
• Education, training and development requirements.
• Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
• Ascertaining your fitness to work.
• Complying with health and safety obligations.
• To prevent fraud.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
• Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

What Happens if You Fail to Provide Personal Information?

If you fail to provide certain information when requested, we may not be able to complete the recruitment process with you (such as scheduling interviews or hiring you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How Do We Use Particularly Sensitive Personal Information?

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations or exercise rights in relation to your potential employment with us. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme. We have in place an equal opportunities policy which we are required by law to maintain when processing such data.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.

Our Obligations As a Potential Employer

We will use your particularly sensitive personal information in the following ways:

• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do We Need Your Consent?

We do not need your consent if we use your personal information in accordance with our written policy to carry out our legal obligations, to administer the recruitment process, and to further our legitimate business interests. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information About Criminal Convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our obligations under applicable privacy laws.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Where applicable according to local law and where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you. We will use information about criminal convictions and offenses to make a decision about your employment where allowed under applicable law.

We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated Decision Making

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data Sharing

Data may be stored in a range of different places, including in your application record, in HR systems on other IT systems (including email).

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law. We will review data protection compliance of third parties prior to entering into agreements with them.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the recruitment process with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. For example, the following activities are carried out by third-party service providers: recruitment, background checks, etc.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of a possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the European Union (“EU”) and the United Kingdom (“UK”)

For EU and UK employees, we will transfer the personal information we collect about you to countries outside the EU and UK in order to administer the recruitment process with you.

However, to ensure that your personal information does receive an adequate level of protection we will ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

Data Security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to help prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you are offered and you accept a job with us, your personal information will be transferred to a personnel file electronically. When your employment with us ends, we will retain your personal data in accordance with our internal policies. The retention period varies depending on the role(s) which you have held during your employment with us, and your personal data will be permanently and securely deleted at the end of this retention period.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer involved in the recruitment process, an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of Access, Correction, Erasure, and Restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

For US employees, under certain circumstances (e.g. CCPA/CPRA), you have the right to:

• Access to Specific Information and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
• Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
• Request Correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Opt-out of Sale or Sharing of Your Personal Information. Reputation does not sell employee data or track employees for targeted advertisements.
• Limit Use and Disclosure of Sensitive Personal Information. Reputation limits the use of employee sensitive personal information to only that which is necessary for providing employment.
• Access to Information About Automated Decision-Making and Opt-Out. Reputation does not use any automated decision-making.
• Not be Retaliated Against for Exercising Rights. Reputation will not discriminate against you (e.g., through denying jobs, promotions or bonuses) for exercising any of the rights afforded to you.

Application of the above rights may vary depending on the type of personal data involved, and Reputation’s particular basis for processing the personal data.

If you are a resident of California, learn more about your rights under CCPA and CPRA.

For EU and UK employees, under certain circumstances (e.g. GDPR), you have the right to:

• Request access to and obtain a copy of your personal data;
• Request rectification (or correction) of inaccurate personal data you have provided;
• Request erasure (or deletion) of personal data that is no longer necessary to fulfill the purposes for which it was collected, or does not need to be retained by Reputation for other legitimate purposes;
• Restrict or object to the processing of your personal data; and
• If applicable, request your personal data be ported (transferred) to another company.

Application of the above rights may vary depending on the type of personal data involved, and Reputation’s particular basis for processing the personal data.

If you are a resident of the EU, learn more about your rights as a data subject under GDPR Chapter 3 (Art. 12-23). Additionally, you can review ICO guidelines for more information.

Exercise Your Rights

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the People Experience Team. You may also use our Data Protection Request form, or call us and leave a message at (877) 553-0616.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Data Protection Officer

We have appointed a Data Privacy Officer to oversee compliance with this Privacy Notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Privacy Officer at dataprivacygroup@reputation.com. You have the right to make a complaint at any time to the supervisory authority for data protection issues.

Changes To This Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.