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Talent Acquisition Privacy Notice for Slalom Inc.

WHAT IS THE PURPOSE OF THIS DOCUMENT?

Slalom, Inc. (255 S. King Street, Suite 1800, Seattle, WA 98104) (Slalom) is the “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 to work with us or one of our affiliates (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 professional networking sites, as permitted by law
  • 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, where necessary and permitted
  • 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, to the extent required and permitted to assess your suitability for the specific job background check information including, to the extent strictly permissible under applicable law, expenditures, rents, loans, mortgage and other forms of credit
  • System Identification data – Email account and instant messaging account, candidate ID, activity data from the candidate portal website

We recommend that you limit disclosing sensitive personal characteristics (e.g. gender, religion, philosophical or political beliefs, financial data, and age) as much as possible. However, for positions in some locations, we may request that you self-identify certain characteristics, such as gender, race, ethnicity, or veteran status, to the extent strictly permissible under applicable law. You may choose not to disclose such characteristics and choosing not to disclose will not subject you to any adverse treatment. It is noted that in some jurisdictions, this information may be considered as sensitive personal data. If you disclose this information to us and we collect it, we will request you to provide your express consent, if such requirement is applicable by local law. This information will be kept confidential and used for reporting and statistical purposes to the extent allowed by and in compliance with applicable law. This information is only viewed in aggregate and is not used to identify any specific individual. Gaining insight into the diversity of our candidates helps Slalom progress toward our goal of creating workplaces that are representative of our diverse locations. Where permitted or required by applicable law, we may also collect, store and use the following more sensitive personal information:

  • Disabilities and disability status, infirmity
  • Convictions and sentences (in limited circumstances where the position so justifies and we have a legal ground to do so)
  • National identification numbers
  • Financial information

Any misleading, false or willful omission of relevant information may be sufficient reason for refusal of employment, or suspension or dismissal from employment. Please submit only accurate information.

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 strictly allows).
  • Your named references, 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. Please note that you may share your references' data with us provided that you have previously informed them of the purposes of the processing and obtained their consent, if applicable. 
  • Data from a publicly accessible third party source, such as information you have made publicly available on a jobs board and professional networking sites, as permitted by law.

HOW WE WILL USE INFORMATION ABOUT YOU

Subject to applicable law, we will use the personal information we collect about you for the following purposes:

  • 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, including by sending you surveys relating to 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 professional networking site, a member of our team will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will further assess 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, to the extent strictly permissible under applicable law, before confirming your appointment to the extent permitted.

LEGAL BASES FOR COLLECTING AND PROCESSING PERSONAL INFORMATION

If you are located in the EU/EEA/UK, we rely on the following legal bases under the EU General Data Protection Regulation, including as applicable through local legislation in the UK, (“GDPR”) and local legislation in Germany for collecting and processing your personal information:

  • It is in our legitimate interests (Article 6(1)(f) of the GDPR) and our legitimate interests are to decide whether to appoint you to the work or role since it would be beneficial to our business or that of our affiliate entities to appoint someone to that work or role as well as to improve our recruiting process based on the feedback we receive.
  • 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, respectively the provisions under local data protection law).

In addition, if you are located in the EU/EEA/UK, we rely on the following legal basis 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)

We also rely on our legitimate interest (Art. 6(1)(f) of the GDPR) for retaining your personal information after your application has been withdrawn or rejected. You have a right to object to such retention when you are notified of our will to retain this information, and at any time after that.

If you are located in countries where data controllers are mandated to rely on consent as a sole basis for processing your personal data (e.g. Mexico, Singapore) we will rely on your tacit consent or request your express written consent, 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 that you volunteer 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, or to ensure we comply with applicable employment and social security laws (e.g. in the field of employing protected categories of employees).
  • We will use information about convictions and sentences and financial information to determine your suitability for the role you have applied to the strict extent legally permissible
  • We will use government identification information to confirm your identity and work status where legally required or permitted
  • We will use provided information about your gender identity, race, ethnicity, or veteran status ensure meaningful equal opportunity monitoring and reporting to the strict extent legally possible and permissible.

INFORMATION ABOUT CRIMINAL CONVICTIONS

We will seek and process information about criminal convictions where strictly permitted by applicable law (in limited circumstances where the position so justifies and we have a legal ground to do so).

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, certain work and roles require a high degree of trust and integrity since they involve dealing with confidential client business.

WHY AND WITH WHOM MIGHT WE SHARE YOUR PERSONAL INFORMATION?

We will share your personal information with the hiring entity as applicable (as data controller, (see list of locations of our affiliates at the end of this document)) and 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, outside counsel for immigration and other legal matters, and service providers for applicant tracking systems located worldwide.

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 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 potentially located worldwide:

  • 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.

DATA SECURITY

We strive to integrate information security and privacy best practices into all Slalom infrastructure and supporting processes. Slalom’s Information Security and Governance vision is to enable the Slalom brand by maintaining the protection, confidentiality, integrity, and availability of Slalom, client, and other personal data pertaining to individuals. All matters of personal data processing, which includes collection, usage, storage, transfer, retention, and deletion, are governed by Slalom’s Information Security and Governance and Legal teams.

Slalom has implemented organizational, technical, and administrative controls to protect your personal information and ensure that principles of data minimization, use limitation, and purpose specification are embedded into our data practices globally. For questions regarding Slalom’s Information Security and Governance Program, please contact security@slalom.com. For any questions specific to data privacy or your respective rights as a data subject, please contact  privacy@slalom.com.

WHERE YOUR PERSONAL INFORMATION IS STORED

Slalom, Inc. 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, Inc. 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, professional 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 United States and located in our headquarters in Seattle, Washington, USA and in other locations, as may be required from time to time. Such locations (see list of locations of our affiliates at the end of this document) may be in countries that do not provide a level of data protection comparable to the level in your home country. If you are in the EEA, UK, or Switzerland, and your personal information is shared with other group entities, any such transfer outside the EEA, Switzerland, Andorra, Argentina, non-public organizations in Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan (for the EEA and UK), Jersey, New Zealand and the UK (or any other country deemed “adequate” by the European Commission, UK authorities, or under Swiss laws, as applicable) will be safeguarded by appropriate safeguards, in particular by concluding contractual measures based on approved standard contractual clauses. You can ask for a copy of these by contacting us as at privacy@slalom.com.

HOW LONG WILL WE USE YOUR INFORMATION FOR?

If you are not offered a position with Slalom or our subsidiaries or are not otherwise engaged to work with Slalom or our subsidiaries, we will retain your personal information for a period of 18 months from the date from the withdrawal or the application or the rejection unless a longer retention period is required under applicable law. 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 by using technical means that will not allow data recovery 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, notifying you of our intent to retain your personal information for up to two years on the basis of our legitimate interest* to have a database of profiles. We will delete your personal information if you object to us retaining your personal information for this purpose.

If you are engaged by Slalom or one of our subsidiaries to work with Slalom or one of our subsidiaries in some capacity, we will retain your personal information as necessary and in accordance with the specific policy applicable to you (e.g. if you are engaged as an employee by Slalom or one of our subsidiaries, we will retain your personal information in accordance with the employee privacy notice 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 and the rights might be limited under applicable data protection law. For instance, if you are in the UK, the EEA, Switzerland or Mexico, subject to exceptions your rights can be summarized in broad terms as follows:

  • Right of access
    You may 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. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • Right to erasure (right to be forgotten)/cancellation 
    You may have the right to ask us to erase or cancel 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.
  • 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 without hindrance from us.
  • Right to object or to oppose
    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 by us and we can be required to no longer process your personal information.
  • Right to revoke/withdraw your consent.
    You may have the right to request to withdraw any consent granted to us for processing your personal information and we will assess such request in accordance with the relevant laws.
  • Right to provide guidelines. 
    For France specifically, you have the right to provide Slalom with guidelines as to the processing of your personal data after your death, either directly or via a trusted third-party.

You may also have the right to lodge a complaint with the competent data protection supervisory authority. 

If you'd like to exercise any of these rights, please get in touch via privacy@slalom.com. 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 the Slalom Privacy Team in writing at privacy@slalom.com or via voicemail at 1-855-256-3238.

For residents in Australia: There are no statutory rights to erasure, restriction of processing, portability, or right to object under Australian law.

For residents in Mexico: Your requests will be evaluated pursuant to applicable laws. Upon request, we can inform you about: (i) the information we may need to receive from you in order to identify yourself as well as the documents that you may need to enclose alongside your request; (ii) the time periods in which you will receive an answer from us regarding your request; (iii) how you may file your request, including any templates or mechanism that may be available (if any); (iv) the media format in which we will deliver the information to you (e.g. by email, CD, etc.)

For residents in California: We have set out below categories of personal information we collect about California resident job applicants and other potential employees under the California Consumer Privacy Act. We do not sell or share for cross context behavioural advertising any personal information of California resident job applicants and other potential employees. A "consumer" below means a candidate employee of Slalom or its affiliates residing in California. Please see our CCPA Privacy Policy  for more information.

For California residents, we retain each category of personal information about job applicants and other potential employees for 18 months and any additional time periods necessary for compliance with law, exercise or defense of legal rights, and archiving, back-up and deletion processes.

Non-Sensitive Personal Information:

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
  • Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. 
  • Characteristics of protected classifications under California or federal law. 
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement.
  • Geolocation data.
  • Audio, electronic, visual, thermal, olfactory, or similar information, including:
    • Data relating to your use of computers, software, networks, communications devices, and other similar systems that: (i) we or our affiliates own or make available to you; or (ii) you connect to or use for the purposes of providing services to us or our affiliates; and
    • Information relating to your activities on our or our affiliates' premises.
  • Professional or employment-related information.
  • Inferences drawn from any personal information to create a profile about a consumer reflecting the consumer's preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive Personal Information:

  • A consumer's social security, driver's license, state identification card, or passport number.
  • A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
  • A consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership.
  • The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication.
  • The processing of biometric information for the purpose of uniquely identifying a consumer.
  • Personal information collected and analyzed concerning a consumer's health.
  • Personal information collected and analyzed concerning a consumer's sexual orientation.

SLALOM AFFILIATE LIST 

Slalom, Inc. (United States - 255 S. King Street, Suite 1800, Seattle, WA 98104)

Slalom Consulting ULC (Canada - 745 Thurlow Street, Suite 2400 Vancouver, BC V6E 0C5)

Slalom Consulting Ltd. (United Kingdom - 2 London Bridge, 2nd Floor East, London SE1 9RA)

Slalom Australia Pty Ltd. (Australia - Level 17, 100 Queen Street, Melbourne Victoria 3000)

Slalom Netherlands B.V. (Netherlands - Singel 250, 1016 AB, Amsterdam)

Slalom GmbH (Germany - Ludwigstrasse 8, Munich 80539)

Slalom Switzerland GmbH (Switzerland - Schutzengasse 1, Zurich 8001, Switzerland)

Slalom Limited (Republic of Korea - Tower 1 Gran Seoul, 7th Floor 33 Jong-ro, Jongro-Gu Seoul 03159)

Slalom Consulting Mexico S.R.L. de C.V. (Mexico – Lago Alberto 442 4th Floor, Parques Plaza, Col. Anáhuac, Miguel Hidalgo, 11320, MexicoSlalom Japan K.K. (Japan - 21F 4 Chome 3-1 Toranomon, Minato-ku, Tokyo, 105-6021)

Slalom New Zealand Limited (New Zealand - Level 22 Floor, PWC Tower, 15 Customs Street West, Auckland Central, Auckland 1010)

Slalom Technology and Management Solutions Limited (Ireland - No 1 Lower Mayor Street, International, Financial Services Centre, Dublin 1, Dublin D01 Y300)

Changes to our privacy notice

We may make changes to this notice, including material changes, from time to time. We will inform you of any changes to the processing activities described in this notice before we start that new processing. 

Last updated: (January 1, 2024)