Purpose and Scope

This is the Recruitment & Hiring Privacy Notice (“Notice”) of Foundever® or any of its parent, sibling, subsidiaries, or affiliate companies, (“Foundever”, “We”, “Company”) in their role as Controllers. This Notice applies to all job applicants, prospective employees and contractors including those that are (i) active seekers who register via our careers website or apply to a role that we have advertised; (ii) referred to us via third-party (such as head-hunters, recruiters); and/or (iii) individuals we identify as a potential job seeker through external resources (e.g., business social network).

We are a Data Controller which means we are responsible for deciding how we collect, hold, and use your Personal Data. This notice explains how and why we collect, use, and hold your Personal Data in the context of the recruitment and hiring process and outlines our ongoing obligations in respect of how we manage your Personal Data.

Your Personal Data

In this Notice, “your Personal Data” means information about you from which you can be identified. The table below lists your Personal Data that we may process. Your Personal Data does not include data where the identity has been removed (anonymous data).

It is important that your Personal Data is accurate and up to date. Please inform us if your Personal Data changes during the recruitment process.

Providing your Personal Data is voluntary. However, if you choose not to provide all of the data that is requested from your application, Foundever’s ability to consider you as a candidate may be limited.

Where does your Personal Data come from?

Your Personal Data will come from you or us, and may also come from the following sources:

• A contact of yours may provide us with the following Personal Data as part of our employee referral program; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references;
• A contact of yours may provide us with the following Personal Data as part of our employee referral program; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references;
• Student organizations may provide us with the following Personal Data; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
• Job boards/portals may provide us with the following Personal Data; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status or from job search or professional networking websites (e.g. LinkedIn, Jobstreet, etc.) where you may have made data about yourself publicly available;
• From your previous employers;
• Foundever career websites or any Recruitment platform/tools/systems;
• When you apply or reach out to us through our official social media channels (where allowed by applicable law)
• Background check providers, as applicable, may provide us with the following Personal Data; criminal records, media articles, address history, credit history, account payment history and any public record. The content of background checks varies by country to comply with local requirements, but may include information gathered from publicly available sources;

How do we use/process your Personal Data?

We may process your Personal Data during and after the recruitment and hiring process. This may include collecting, recording, storing, using, transmitting it, updating/amending, consolidating, destroying and, in some circumstances, disclosing your Personal Data.

In general, your Personal Data may be used in connection with any recruitment and hiring activities to:

• Assess your employment application for actual or possible work placement and to verify information contained in your application;
• Retain records relating to the recruitment process;
• Establish, exercise or defend legal claims;
• Conduct criminal reference checks (convictions, including alleged offences) and other background checks, including credit checks for positions involving significant financial risks and otherwise permitted by law. You will receive more information about the nature of such background checks before they commence; and / or
• Comply with the law or requirements of a regulator.

We also process your Personal Data for the following purposes, and on the legal bases set out in the following table:

Processing Purpose	Legal basis and legitimate interest (where applicable)
Contact you regarding the recruitment and hiring process and any offer of work.	To enter a contract
Contact you regarding new positions that we may recruit for in the future.	For our legitimate interests: to source suitable employees, workers and contractors
Make a decision about your recruitment or appointment, including assessing your skills, qualifications, suitability for the work and whether you could work from home.	To enter a contract To comply with a legal obligation For our legitimate interests: to select suitable employees, workers and contractors
If you register on our Careers website or any Foundever websites/tools/properties, we will enter you into a database to receive future mailing account work openings, events and other relevant information you might be interested in. You will always be able to opt-out of any marketing communications from Foundever.	To enter a contract For our legitimate interests: to select suitable employees, workers and contractors
Transfer your contact information, education data, employment data, application information and the CV, as supplied by you in our recruitment system, to Foundever talent tool/ applicant tracking system or any site we maintain to notify you about new positions, or any similar recruitment systems used by Foundever.	To enter a contract For our legitimate interests: to select suitable employees, workers and contractors
If you have accepted an offer of work from us that is subject to such checks: · Take up references (from referees whom you have given us permission to contact); · Carry out background checks; · Confirm your professional memberships, registrations and / or qualifications.	To enter a contract To comply with a legal obligation For our legitimate interests: to select suitable employees, workers and contractors
Determine the terms of any potential contract between you and us.	To enter a contract To comply with a legal obligation
If you have accepted an offer of work, check if you are legally entitled to work in the relevant country.	To enter a contract To comply with a legal obligation
Establish whether you can undergo an assessment which forms part of the application process. Consider reasonable adjustments to the recruitment process for disabled applicants.	To enter a contract To comply with a legal obligation For our legitimate interests: to select suitable employees, workers and contractors *For special categories of information: to exercise or perform employment law rights or obligations
Establish whether you will be able to carry out a function that is intrinsic to the particular work. If you have accepted an offer of work from us that is subject to such a check: assess your fitness to work via test or assessment (including medical in nature), health questionnaire.	To enter a contract To comply with a legal obligation For our legitimate interests: to select suitable employees, workers and contractors *For special categories of information: · To exercise or perform employment law rights or obligations · For the purposes of preventive or occupational medicine, or for the assessment of your working capacity
Perform any legally required reporting and respond to legal process.	To comply with a legal obligation

Where the above table states that we rely on legitimate interests for a particular purpose, we consider your interest and rights and if those can be impacted by our processing activities. We balanced your interests, rights and freedoms against our interests, taking into account the purposes of the processing, security of your information and our existing relationship with you.

In certain jurisdiction, to the extent consent is mandatory under applicable law, we will only process your Personal Data for the purposes mentioned in the above table based on your prior consent. If you are asked to accept this Notice in one of our tools, such acceptance will be considered as your consent to processing of your Personal Data in the countries where such consent is mandatory only. In all other countries, clicking acceptance/agreement buttons, will be considered acknowledgment of this Notice.

With whom do we share your Personal Data?

Subject to local laws and regulations, and where there is a need, we may share your Personal Data with third parties if required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person.

We may disclose Personal Data to third parties for the following business purposes:

• Other Foundever entities where the hiring manager is in another country, for system maintenance support and hosting of data;
• Our service providers, including applicant tracking system providers, talent assessment providers, background check providers, test providers and payroll providers;
• With our clients for the purposes of validating our selection processes;
• Health professionals and occupational health providers involved in your care, for the purposes of establishing whether you can undergo an assessment which forms part of the application process; considering reasonable adjustments to the recruitment process for disabled applicants; establishing whether you will be able to carry out a function that is intrinsic to the particular work;
• Our professional advisors, including lawyers;
• Other third parties as necessary to comply with the law.

Such third parties may be located in other countries. Before we share your Personal Data, we will take the necessary steps to ensure that your Personal Data will be given adequate protection as required by relevant data protection laws and according to Foundever’s global privacy policies and standards.

Any access to your Personal Data is restricted to those individuals that have a need-to-know basis. Foundever^® will only disclose your Personal Data as required or permitted by applicable law to legal or business consultants, government authorities and courts.

Where will your Personal Data be processed?

Subject to local requirements and legislation, as a global organization with global IT system, your Personal Data may be transferred to other countries Foundever does business or to any of its parent, sibling, subsidiaries or affiliate companies for employment consideration and other business or legal purposes, or to its external service providers who support Foundever with the administration of recruitment & hiring application and verification.

To ensure that there are adequate safeguards, Foundever has put in place data transfer agreements, including the European Commission Standard Contractual Clauses where applicable, between our entities for transfer of Personal Data within the Foundever of companies, and with our vendors when required, providing heightened levels of security and protection to the processing and retention of your Personal Data.  International transfer of Personal Data will only take place in accordance with the appropriate data transfer mechanism and safeguards.

Do we process your Personal Data without any human intervention?

We will not take any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

Should we implement any process involving decision making based on automated processing, we will inform you of such processing activity and how you can ask for human intervention in the automated decision-making process, as appropriate, via the respective system or platform.

How long do we keep your Personal Data?

We maintain a Data Retention Policy and Data Retention Schedule which set out the retention timelines for the categories of Personal Data that we process.

If you don’t start work with us following the recruitment process, we will retain your Personal Data for as long as necessary according to the following retention criteria:

• Our ongoing relations with you, in case you are subscribed to our Recruitment portal;
• When required to do so by a legal obligation to which we are subject;
• to allow us to establish, exercise or defend legal claims; and
• for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for, or a similar role, becomes available again.

If your application is successful, your Personal Data will be used for personnel administration including the establishment of your personnel record and management purposes. We will give you a copy of our Worker Privacy Notice and will retain your Personal Data as detailed in the said Notice.

How do we protect your Personal Data?

We strive to protect your Personal Data while it is under our control. We maintain appropriate organizational, physical, technical security measures to protect your Personal Data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction or damage thereto. We have internal controls and relevant policies and procedures to maintain these measures taking into account the risk associated with the categories of personal data and processing we undertake.

In some cases, your Personal Data is accessible online through the use of password. To help protect the confidentiality of your Personal Data, you must keep your password confidential and secured. You are responsible for all uses, acts on the sites by any person using your password. Please contact us immediately if you believe that your password has been compromised or misused.

If a data breach involving your Personal Data occurs, or we suspect that a data breach has occurred, whether the entity who experience the data breach is Foundever or third parties we use, or our clients, we will expeditiously conduct an investigation, and assessment and take necessary remediation actions.

What are your rights with regard to the processing of your Personal Data?

Dependent upon where you are located and subject to certain exceptions set out in applicable privacy laws, you may have the following rights:

• Access: you can request a copy of your Personal Data that we hold, and check we are processing it lawfully.
• Correction: you can ask us to correct your Personal Data if you don’t think it is accurate, complete or up-to-date.
• Deletion: you can ask us to delete your Personal Data, if:
  • it is no longer necessary for the purposes for which we obtained it;
  • you withdraw your consent, and we have no other legal basis for the processing;
  • you validly object to the processing as described below;
  • we have unlawfully processed the data; or
  • we must delete the data to comply with a legal obligation.
• Objection: if we process your Personal Data to perform tasks carried out in the public interest or on the basis of legitimate interests, you can object to this processing on the basis of your particular situation. We will only then continue the processing if we have overriding legitimate grounds for this, or the processing is to establish, exercise or defend legal claims. You may also object if we process your Personal Data for direct marketing purposes.
• Restriction: you can ask us to restrict our processing of your Personal Data if:
  • you contest the accuracy of the data (for a period that enables us to check it);
  • our processing is unlawful, but you don’t want the data deleted;
  • we no longer need the data, but you require it to establish, exercise or defend legal claims; or
  • you have objected (as above) and are awaiting confirmation as to whether we have overriding legitimate grounds for processing.
• Transfer/Portability: if our processing is based on your consent or necessary to carry out our contract with you, and is carried out by automated means, you can request a copy of the Personal Data you have provided to us and the transfer of this to someone else. Where technically feasible, you can ask us to transfer it directly.
• Right to complain to the Supervisory Authority: we aim to resolve all complaints internally via our Regional Data Protection Officer who can be contacted as directed below, but you have the right to lodge a complaint with the relevant Supervisory Authority at any time.

How to reach out?

If you have any questions about this Privacy Notice or how we handle your Personal Data, or if you wish to exercise your rights, including withdrawal of your consent, please contact Foundever’s Data Protection Officer at privacy@Foundever.com or write to us at 50/52 Boulevard Haussmann, 75009 Paris, France, Attention: Data Protection Officer.Please note, however, that certain Personal Data may be exempt from such access, correction, deletion requests pursuant to applicable data protection laws and regulations.

Updates to this Notice

We will update this Notice from time to time to reflect changes in our business. You can always check and review our Privacy Notice for updates by visiting this page.