Candidate Privacy Notice: Rev February 5, 2020

Effective as of February 5, 2020

This Candidate Privacy Notice (“Notice”) is provided to let you know what personal information Conviva Inc., including any of its affiliates (collectively “Conviva,” “we” or “us”), collects about its applicants and how it handles such information during the application process. You are being provided this Notice because you are applying for work with us (whether as an employee or contractor). When you sign-up for job alerts or apply to a job posting directly with Conviva, the personal data contained in your application will be collected by Conviva’s third party provider(s) who will collect your personal data on our behalf and share it with us.

Data Protection Principles

We will comply with data protection law and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

Types of Information Collected

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • Information you have provided in your CV/resume and cover letter.
  • Information you have provided on any application form, including name, title, address, telephone number and personal email address.
  • Information you provide during an interview.
  • Information available from your LinkedIn profile (subject to you explicitly consenting to linking your LinkedIn profile).
  • Information you provide to us for purposes of conducting a background check, including prior education and employment history.
    Information you provide which is required to initiate your employment, such as proof of eligibility to work in a specified country (such as a passport or visa); date and place of birth; citizenship; social security or national insurance number; tax information; bank account information; benefits eligibility information and other information you provide for the purposes of starting employment or executing an employment agreement.

We may also collect, store and use the following types of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions if you have provided such information voluntarily through your CV/resume, interview process and/or LinkedIn profile.
  • Information about criminal convictions and offenses.

How is your personal information collected?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • Information provided to our third-party applicant tracking provider.
  • Information available from your LinkedIn profile (subject to you explicitly consenting to linking your LinkedIn profile).
  • Our external recruitment agencies.
  • HireRight, our background check provider, from which we collect the following categories of data: criminal record information and education and employment verification.
  • Your named references, from whom we collect the following categories of data: confirming employment and dates of employment.

Purpose and Basis for Processing

We will use the personal information we collect about you to do the following:

  • Administer and process your application, including verifying your identification, experience and other information you submit and, if your application progresses, any interview information and background check information.
  • Communicate with you about your application, including contacting you via phone, email or social media platforms about your application and, if your application progresses, any interview and background check information.
  • Assess and evaluate your suitability for the role for which you have applied, or for other vacancies, including verifying your identification, experience and other information you submit and, if your application progresses, any interview information and background check information.
  • Conduct reference and background checks as part of your application, subject to applicable law, including verifying your identification and other information you submit and, if your application progresses, we will conduct background checks on your criminal history and verify your education and employment history.
  • Comply with applicable laws and employment-related requirements, including verifying identification information and information required to initiate employment, for purposes such as confirming ability to legally work in a specific location, setting up payroll, withholdings and benefits, and complying with statutory reporting requirements.
  • Inform you of career opportunities, including other vacancies for which you may be eligible.

We will normally only collect and process your information where:

  • we need to comply with legal obligations applicable to us (such as applicable immigration and/or employment laws and regulations);
  • we need the information to fulfill our responsibilities in any actual or prospective agreement with you (such as an employment agreement or an offer of employment, if you are considered for employment);
  • the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (such as to ensure a safe working environment for all our staff, and to ensure the reliability of our candidates, and otherwise to administer and process your application, or to communicate with you about your application); or
  • we have your consent to do so.

Where we collect and process special categories of data (for example, race, gender), then we will only process such information:

  • where we reasonably need to do so in order to comply with our legal obligations as a prospective employer;
  • where we need to do so in order to assess your working capacity;
  • where we need to do so to protect your or another person’s vital interests (and we are unable to obtain your consent); or
  • where you have given us your consent.

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

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process.
  • 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.

What happens if you do not 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 a background check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Background Checks

If we extend an offer to you and you agree to continue the application process, we will perform a background check and collect information about your criminal conviction history and verification of your prior education and employment history. We require background checks in order to confirm that there is nothing in your criminal convictions history which makes you unsuitable for the role and that your education and employment history is consistent with what we have in your application file. Any employment offer is conditional upon a successful background clearance check.

Data Sharing with Third Parties

We will only share your personal information with third parties acting on our behalf for the purposes of processing your application. All our third-party service providers are required to take appropriate security measures to protect your personal information in accordance with our policies.

Data Transfer Abroad

We operate internationally and, as a result, if such data does not originate from within the United States, we will transfer candidate information across international borders, including from the European Economic Area (EEA) to the United States, for processing and storage. To the extent that your data is transferred outside the EEA, we will transfer such data consistent with applicable data protection laws.

Data Security

We have put in place appropriate security measures to 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.

Data Retention

We may retain your personal information for up to three (3) years, or longer with your consent, for the purposes of evaluating your application for (1) the position you have applied for, or in the event such position is not a fit, then for future employment opportunities with Conviva, or (2) future job openings with Conviva if you have signed up to receive job alerts via www.conviva.com. We retain your personal information also as needed 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.

Your Data Rights

You have several rights in relation to your personal data. You have a right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • 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.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • Withdraw your consent to our collection and processing of your information at any time.
  • Lodge a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues arising from job applicant data processed in the EEA.

If you wish to exercise any of these rights, please contact privacy@conviva.com. We may request proof of identification to verify your request.

Further Information

If you require clarification regarding this Notice, please contact privacy@conviva.com. If you are a job candidate in the EEA, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.