WHAT IS THE PURPOSE OF THIS DOCUMENT?
Slalom, LLC and its affiliates (Slalom) are a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with this privacy notice because you are applying for work with us (whether as an employee, worker or contractor) or because we have your personal information through a referral, from a jobs board, networking sites or from a prior connection with you. This privacy notice is designed to make you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the data protection laws to which we are subject.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work with us or our interest in connecting with you about working with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae (CV) and cover letter
- Any information you have made publicly available on a jobs board or networking sites
- Any information you provide to us during an interview
- Any information you volunteer to us on our post-recruiting process survey
- Personal Details - Name, title, address (work and home), telephone numbers (work and home), email address, former addresses, languages that are spoken
- Employment details - Recruitment information (including copies of right to work documentation), recruitment date and method, recruitment source, professional qualifications and certifications, social contacts and business partners as references and other information included in a CV or cover letter or as part of the application process, previous employment background including past employers, military service, gaps in employment and all other information volunteered in relation to previous work experience, compensation history
- Government Identification – National identification number, passport number, driver’s license number
- Education and Training History – completed degrees at schools, institutions, colleges and universities attended, diplomas or certificates awarded, special licenses, other diplomas awarded, professional interests, specializations, teaching experience, research interests, academic interests consultations, other related previous education including books, articles, reports and published audiovisual materials, details regarding groups, committees, functions held, special interests (EPP) and participation records
- Personal Financial Data – Required or negotiated base compensation, other compensation, benefits, pension plan details, background check information including expenditures, rents, loans, mortgage and other forms of credit
- System Identification data – Email account and instant messaging account, candidate ID
Where permitted and required by applicable law, we may also collect, store and use the following “special categories” of more sensitive personal information:
- Disabilities and disability status, infirmity
- Convictions and sentences
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
- You, the candidate.
Where permitted, and subject to your consent if required, via a third-party background check provider, such as a Disclosure and Barring Service, from which we collect the following categories of data: information relating to your identity, address history, professional standing, work history, educational history, qualifications, driving record, military record, credit history and/or criminal record history (but only to the extent applicable law allows).
Your named referees, from whom we collect the following categories of data: relationship to the referee, confirmation of work experience (job title, dates of employment, work duties), work performance, strengths, working style, eligibility for rehire.
The following data from third parties is from a publicly accessible source: information you have made publicly available on a jobs board and networking sites.
HOW WE WILL USE INFORMATION ABOUT YOU
Subject to applicable law, we will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the work or role.
Carry out background and reference checks, where applicable.
Communicate with you about future roles, opportunities and the recruitment process.
Keep records related to our hiring processes.
Solicit feedback from you on your experience with Slalom’s recruiting process
Comply with legal or regulatory requirements.
Having received your CV and cover letter or your information from a public jobs board or networking site, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work or role. If we decide to offer you the work or role, we will then take up references and/or carry out a background check before confirming your appointment.
LEGAL BASES FOR COLLECTING AND PROCESSING PERSONAL INFORMATION
If you are located in the EU/EEA, we rely on the following legal bases under the EU General Data Protection Regulation ("GDPR") for collecting and processing your personal information:
- It is in our legitimate interests (Article 6(1)(f) of the GDPR) to decide whether to appoint you to the work or role since it would be beneficial to our business to appoint someone to that work or role.
- We also need to process your personal information to decide whether to enter into a contract of employment or a contract for services with you (Article 6(1)(b) of the GDPR).
In addition, if you are located in the EU/EEA, we rely on the following legal bases for the collection of any special categories of data:
- the purposes of carrying out the obligations and exercising our or your specific rights in the field of employment and social security and social protection law (GDPR Art. 9(2)(b) and the corresponding provisions under local data protection law)
- protecting your vital interests as a data subject (GDPR Art. 9(2)(c) and the corresponding provisions under local data protection law;
- for the assessment of the working capacity of an employee or the provision of health or social care or treatment (GDPR Art. 9(2)(h) and the corresponding provisions under local data protection law), as applicable.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
HOW WE USE SENSITIVE PERSONAL INFORMATION (IF COLLECTED)
If we collect the categories of sensitive personal information identified in this notice, we will use it in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments or accommodations during the recruitment process, for example, whether adjustments or accommodations need to be made for accessibility.
Subject to applicable law, if you anonymously provide information about your [gender identity, race or national or ethnic origin], we will use information, subject to applicable law, in an anonymous and aggregated way to ensure meaningful equal opportunity monitoring.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We will seek and process information about criminal convictions where permitted by applicable law.
We will collect information about your criminal convictions history if we would like to offer you the work or role conditional on checks and any other conditions, such as references, being satisfactory. Where permitted by applicable law, we are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
- All work and roles require a high degree of trust and integrity since they involve dealing with confidential client business and so we would like to ask you to seek a basic disclosure of your criminal records history.
WHY MIGHT YOU SHARE MY PERSONAL INFORMATION?
We will only share your personal information with third parties that are necessary for the purposes of processing your application. The categories of these third parties are generally background check vendors, criminal background check vendors, outside counsel for immigration and other legal matters and service providers for applicant tracking systems,
We may also share your personal information with other entities within our business 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.
We may also disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Slalom or its subsidiaries, or substantially all of the assets of any of the foregoing, is acquired by a third party, in which case personal data held by it about its candidates will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of Slalom or its subsidiaries, our customers, or others.
We have put in place technical and organizational security measures including the Information Technology Usage Policy, the Access Control Policy, the Encryption Policy and the Software Development Lifecycle Policy to prevent your personal information from being accidentally lost, used or accessed in an unauthorised 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.
WHERE YOUR PERSONAL INFORMATION IS STORED
Slalom LLC is located in the United States and is governed by United States law. Your personal information will be transferred to, stored, and processed in the United States when you are applying for work with Slalom LLC or one of our subsidiaries (whether as an employee, worker or contractor) or because we have your personal information through a referral, from a jobs board, networking sites or from a prior connection with you.
Therefore, for the processing purposes, your personal information will be processed and stored on systems used by us in the USA and located in our headquarters in Seattle, Washington, USA and in other secure locations, as may be required from time to time. Such locations may be in countries that do not provide a level of data protection comparable to the level in your home country. However, if you are in Europe, and your personal information is shared with other group entities, any such transfer outside the EEA, Switzerland, Andorra, Argentina, non-public organizations in Canada, Faeroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey and New Zealand (or any other country deemed "safe" by the European Commission) will be safeguarded by contractual measures based on the European Commission's approved standard contractual clauses. You can ask for a copy of these by contacting us as at [email protected].
HOW LONG WILL YOU USE MY INFORMATION FOR?
If you are not offered a position with Slalom, or are not otherwise engaged to work with Slalom, we will retain your personal information for a period of 18 months from the date that you were provided with notification of our processing of your personal information in accordance with this privacy notice. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds, and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
It is likely that we will wish to retain your personal information on file on the basis that a further opportunity may arise in future and we may wish to consider you for that. If so, we will write to you separately, seeking your explicit consent to retain your personal information on that basis. We will delete your personal information if you do not provide your consent for us to retain your personal information for this purpose.
If you are engaged by Slalom to work with Slalom in some capacity, we will retain your personal information in accordance with the specific policy applicable to you (e.g. if you are engaged as an employee by Slalom, we will retain your personal information in accordance with the employee privacy notice or policy provided to you).
YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
Under applicable law, you may have certain rights in relation to your personal information. These can differ by country. For instance, if you are in Europe, the EEA or Switzerland, your rights can be summarized in broad terms as follows:
Right of access
You have the right to confirm with us whether your personal information is processed, and if it is, to request access to that personal information including the categories of personal information processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
Right to rectification
You may have the right to rectify inaccurate or incomplete personal information concerning you.
Right to erasure (right to be forgotten)
You may have the right to ask us to erase personal information concerning you.
Right to restriction of processing
In limited circumstances, you may have the right to request that we restrict processing of your personal information, however where we process your personal information for the processing purposes we think that we have a legitimate interest in processing that personal information which may override a request that you make.
Right to data portability
You may have the right to receive personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that personal information to another entity.
Right to object and rights relating to automated decision-making
Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information, including profiling, by us and we can be required to no longer process your personal information. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.
You also have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.
If you'd like to exercise any of these rights, please get in touch via [email protected]. If you want further information about these rights, and how they may apply you, or if you have a concern or complaint about how we have used your personal information please contact [email protected] in writing.