Job Applicant Privacy Notice

Notice effective 19 December 2019

Certinia recognizes that privacy is important. We developed this Job Applicant Privacy Notice (the “Notice”) to inform you of how Certinia will use the information you submit through the Certinia Careers Section (the “Section”) of the Certinia website, to one of the email addresses provided in the Section, or to Certinia in any other way as well as the information which we may collect or be provided as part of a job application and/or job search process or if you participate in the Certinia talent community (“Applicant Information”).

Your use of other Certinia services is governed by any applicable terms and our Privacy Statement.

All Applicant Information you submit to Certinia is collected by Certinia for the purposes set out in this Notice and may be shared between Certinia affiliates, subsidiaries and joint ventures (including Certinia in the USA even when interested in or applying for roles outside of the USA). Please note that the controller or owner of the data is the Certinia company in the country you that you are applying to or joining the talent community for. Data for all Certinia companies, company details and the person responsible for privacy related matters are found here). However, your data will be shared with the other companies within the Certinia group (which data is available here) for the same purposes and under the same conditions.

Certinia has intercompany agreements in place to manage transfer of personal data between Certinia affiliates where it involves the transfer of personal data from the European Economic Area or UK to the United States or other countries in accordance with the transfer mechanisms approved by the European Commission or other applicable authority from time to time.

By submitting Applicant Information, you expressly acknowledge that you have read and understand all of the terms of this Job Applicant Privacy Notice.

INFORMATION WE COLLECT

Schedule 1 to this Notice describes the information we may collect about you or you may provide to Certinia.

HOW WE USE THE INFORMATION WE COLLECT

We collect and maintain different types of Applicant Information. As a general rule, Certinia collects personal information directly from you. In most circumstances where the personal information that we collect about you is sourced from a third party, we will obtain your permission before we gather this information (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilise the services of third parties in our business including to source personal information we collect pursuant to this Notice. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

In general we collect, process, use and store information about you:

• With your consent;
• To fulfill our legal duties;
• To comply with any legal obligations we are required to comply with;
• As is necessary to protect your vital interests or those of someone else; and/or
• For our legitimate interests or those of third parties.

We have described the ways in which we use your information below. For some processing activities, more than one reason or basis for processing may be relevant, depending on the circumstances. Certinia uses the Applicant Information (and may in certain circumstances disclose the Application Information) for the following purposes:

• Determine your eligibility for initial employment (including the verification of references and qualifications);
• Conduct verification and vetting, including criminal background checks and credit checks where required by law and/or so assess your suitability for your role;
• Correspond with you by phone, email, social media and post/mail;
• Administer your application for a job with us;
• To assess your skills, qualifications suitability and interests against our career opportunities;
• To verify your information, check right to work, and conduct reference checks;
• Conduct an assessment of your ability to perform required job functions
• Making a job offer to you;
• To conduct background checks if you are offered a job;
• To communicate with you and inform you of career opportunities;
• To create and submit reports as required by law or regulation;
• To improve our recruitment process including diversity and inclusion initiative (in aggregated, anonymised, or otherwise non-personalised form); and
• Conduct verification and vetting, including criminal background checks and credit checks where required by law and/or to assess your suitability for your role
• Manage and administering our equal opportunities reporting
• Respond to binding requests or search warrants, subpoenas, orders from courts, governmental, regulatory and/or enforcement bodies and authorities
• Responding to non-binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities
• Comply with disclosure orders arising in civil proceedings
• Investigate, evaluate, demonstrate, monitor, improve, report on and meet Certinia’s compliance with relevant legal and regulatory requirements
• Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting Certinia’s compliance with best practice and good governance responsibilities
• Responding to employment and industrial relations matters where permitted by applicable law, including criminal investigations, grievances, arbitrations, negotiations, elections and strikes
• Protection of Certinia’s assets and rights, including taking legal action or defending legal action as necessary
• as permitted or required by applicable law or regulatory requirements; and
• to protect the rights and property of Certinia.

If you accept employment with Certinia, the information collected will become part of your employment record and will be used for employment purposes.

In addition to the above, we also may use the following types of data in the manner described below.

Background checks. Certinia conducts background checks on all employees where permitted and in accordance with applicable laws and regulations. These checks are completed once you are offered a job at Certinia. Certain roles and/or projects at Certinia may also require a security clearance. Some security checks may require you to disclose personal information, including financial information, about your partners and/or parents. Employment at Certinia is contingent upon the completion of a satisfactory background check (where a background check is permitted) and obtainment of a security clearance, if applicable. If something on your background check appears to be a reason that Certinia cannot hire you, we will notify you that we may not be able to offer you a position because of that information. Where required by law, and where this data is available to Certinia, we will also provide you with a copy of your background check, and where applicable and available in the country in which you are applying, information on the process for correcting a criminal record. Where Certinia uses a third party to conduct background checks Certinia may only receive the outcome of background checks and any discrepancy found.

Professional and Technical Assessments. During the recruitment process with Certinia, you may be invited to participate in certain professional or technical assessments as further described below.

Professional Assessments: If you participate in any such professional assessments, the results or information gained from such assessments may be used during the interview process to guide conversations around specific competencies related to the role you are being interviewed for. This information is not used as part of any automated decision making process.

Technical Assessments: If you participate in any such technical assessments to assess your capability for the role you have applied for, the results of such assessments may be used to include or exclude you from progressing further in the recruitment process. You may be excluded if you fail to achieve the required standard in such assessment(s) as provided to you during the assessment process. If you are excluded based on the results of the assessment you have the right to discuss your results with our recruitment team and receive feedback on your results.

Information About Others. You may provide and/or we may receive information regarding referees you provide as part of the application and/or job search process with Certinia. You have a duty, before you provide us with their data, to obtain their consent and inform them that we are going to process this data in accordance with this Notice, as appropriate.

YOUR CHOICES

You can choose what types of Applicant Information, if any, to submit. Submitting your Applicant Information is voluntary. However, if you choose not to submit your Applicant Information, our ability to consider you as a candidate may be limited.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with your application or job search process including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America and any other country where Certinia operates. When we share personal information with such parties we typically do so pursuant to a contract with such parties, which contracts, in case such parties are located in third countries without a finding of adequacy by the European Commission, shall be drafted to include data transfer measures approved by the European Commission from time to time.

In addition, personal information may be disclosed or transferred to another party (including to another party outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of Certinia through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Notice.

Further, your personal information may be disclosed in aggregated, anonymized, or otherwise non-personalized form and/or with your consent.

ACCESS

You have the right to access the personal information we collect about you as well as the right to correct and update it, and you have the right to request your data be deleted. Only those Certinia employees who need access to your personal information in order to perform their job have access to view that information that is stored in our systems.

UPDATING YOUR PERSONAL INFORMATION

We only intend to maintain personal information that is accurate, current. You are responsible for informing Certinia of any corrections or updates to your personal information and you can do so by updating your profile or by contacting Certinia at any time by contacting:

EMEA Talent Acquisition at Employee Success 2 Cardale Park Beckwith Head Road Harrogate, North Yorkshire HG3 1RY UK [email protected]

United States, Canada and Australia Talent Acquisition at Employee Success 301 Congress Avenue, Suite 800 Austin, TX 78701 United States +1 (925) 785-8543 [email protected]

HOW LONG IS YOUR PERSONAL INFORMATION RETAINED?

Except as otherwise permitted or required by applicable law or regulatory requirements, Certinia endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations), as long as required by law or, otherwise, at least until any responsibilities or liabilities connected to such data expire in accordance with the appropriate statute of limitations. We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.

If you are not successful in your job search with Certinia and/or if you join our talent community we may also retain Applicant Information to contact you about other jobs/roles which may be of interest. If you don’t want us to contact you please contact [email protected] icluding the words “unsubscribe me” or use the unsubscribe process within the talent community.

If we have made a provisional offer of employment and that is subsequently revoked following the outcome of background checks we will retain a record of the background check and results where required by applicable law and/or our record retention policies and procedures. Otherwise we will retain a record only that any offer of employment was revoked and the discrepancy recorded as the reason for such revocation.

DATA CONTROLLER & PERSON(S) RESPONSIBLE FOR PRIVACY RELATED MATTERS

Please note that the controller for your personal information is the company in the country in which you are seeking a role at Certinia, such entities being as described below:

Controllers:

Certinia UK Limited – UK
Certinia Spain S.L. – Spain
Certinia.com, Inc. – USA
Certinia Australia Pty Limited – Australia
Certinia.com Canada, Inc. – Canada

The person(s) responsible for privacy related matters are as described below:

Privacy Officer
[email protected]

INQUIRIES OR CONCERNS?

If you wish to exercise your rights of access, rectification, erasure, restriction of processing, data portability, objection to automated decision-making, or you have any questions about this Notice or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail to [email protected]. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may make a complaint to appropriate data protection supervisory authority.

CHANGES TO THIS NOTICE

Certinia may from time to time make changes to this Notice to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any changes to the Notice on this page. Each version of the Notice is identified at the top of the page by its effective date.

CONTACT US

For more information about our privacy practices, please contact us at [email protected] any time, or write to us at:

EMEA Privacy Officer 2 Cardale Park Beckwith Head Road Harrogate, HG3 1RY, UK

United States, Canada and Australia Privacy Officer 301 Congress Avenue, Suite 800 Austin, TX 78701 United States

SCHEDULE 1

Type of personal data	Collected from
CONTACT INFORMATION
Name(s) Address(es) Email address(es) Contact details including mobile telephone number(s)	You
PERSONAL INFORMATION
Date of birth Gender Next of kin or other dependants Marital or relationship status Lifestyle and social circumstances Emergency contact information	You
IDENTITY AND BACKGROUND INFORMATION
Details of education and qualifications and results Career history, experience and skills Passport information Driving licence information Professional and psychometric assessments and tests Test results from any pre-qualification tests and assessments taken as part of application process Right to work, residency and/or other visa information (where unrelated to your race or ethnicity) Curriculum Vitae (CV) or resume and professional profile Image or photographs Application form Evaluative notes and decisions from job interviews Preferences relating to job location and salary Conflicts of interests (including where related to family networks)	You Recruitment consultants and agencies Your previous employers Publicly available information from online resources
SPECIAL CATEGORIES OF INFORMATION
Racial or ethnic origin (including your nationality and visa information) Political opinions Religious or philosophical beliefs Trade union membership Biometric data (including fingerprint and retinal scans) Data concerning physical and/or mental health Sexual orientation Information relating to actual or suspected criminal convictions and offences	You Third-party providers of background checks
APPLICATION ADMINISTRATION INFORMATION
Your working preferences and feedback in relation to Certinia and our staff Your preferences in relation to our use of your personal data Working time preferences	You
FINANCIAL INFORMATION
National insurance number and/or other governmental identification numbers	You