Applicant Data Privacy Notices

France, French Polynesia and New Caledonia

Introduction

The U.S.-based office of The Pew Charitable Trusts (the "Company" or "we", or "us") will collect and hold the information that you submit within the scope of the application process, which information may contain personally identifiable information ("Personal Data"). This Applicant Privacy Notice sets out which Personal Data we collect about you and how we use it.

Throughout this Privacy Notice we may use the term "processing" to cover all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.

All the information requested for your application is mandatory. Absence of information or incomplete information will not allow us to process your application.

By choosing to submit your application, you acknowledge and understand that Pew and its subsidiaries will process data relating to you in connection with your application for the exclusive purpose of assessing your suitability for employment according to the details and modalities stated herein.

Purpose of personal data processing and legal basis for such processing

If you apply for a role with The Pew Charitable Trusts (“Pew”), the personal information you provide to Pew as a result of your application will be held and processed by or on behalf of Pew as needed solely for purposes related to the assessment of your suitability for employment. 

During the recruiting process, we will use the information you provide on your application form or otherwise, to assist in our selection and recruitment process and to assess your suitability for employment. As part of assessing your application for employment, we may seek further or confirmatory information about you from you, your referees and/or your former employers, to the extent permitted by law. We may also be provided with further or confirmatory information about you from third parties who we engage to assist us in the recruitment process, such as background check providers.  If you provide us with personal data about referees and former employers/colleagues, it is your responsibility to inform them of their rights with respect to such information. 

Your privacy is paramount to us. This data will be processed in a fair and lawful manner and in accordance with the EU General Data Protection Regulations (the “GDPR”) and the Data Protection Act, its national equivalent (the Law n°78-17 of 6 January 1978 on information technology, data files and civil liberties, as amended) (together, the “Data Protection Laws”). 

At all times, Pew will collect and use your personal data for the exclusive purpose, and on the sole legal basis of Pew's legitimate interests in assessing your skills, qualifications and your suitability for our career opportunities, as well being able to establish, exercise and/or defend our position in potential legal claims in the event of a dispute or controversy between you and Pew, related to the hiring process and/or your application.

Pew may also occasionally process your personal data on the basis of your consent, for example if you choose to provide personal data to us voluntarily. In such case, you may revoke your consent at any time as set forth in section "Your Rights" below.

Categories of personal data

The personal data we collect and process includes the following categories (where applicable to your application for employment and Pew’s consideration of your application):

  • Pre-employment background information, such as candidate details, status, ranking, email address, address, current employer, job history, work and corporate title, education, qualifications, references, copies of right to work documentation, desired function and work location, licenses, certificates, work experience, resume information, notice period and other information included in a CV or cover letter or as part of the application process.
  • Contact information, such as full name, including title, and phone number.
  • HR data such as residency status, primary language, language skills, visa type and information (work permit/business/etc.), home address and home telephone number, and personal mobile phone number.
  • Any other personal data necessary or voluntarily given by you in connection with your application.

Sources of personal data

We may collect personal data from the sources listed below:

  • Directly from you, such as through your data input into our website, the application process or via other forms or information you provide to us in connection with your application;
  • Through your activities in the course of the application process, such as through the interview process; and
  • From third parties, including references, former employers, educational institutions and employment recruitment agencies, subject to the requirements of applicable law.

Retention of personal data

Pew will retain your personal data for as long as required to satisfy the purpose for which they were collected and used, unless a longer period is necessary for our legal obligations or to defend a legal claim.  Your personal data will be stored in various secure databases containing applicant and employee data to be accessed for the purposes of considering your application for employment, in the event of future vacant positions, in the administration of your employment, should your application be successful, and/or as required in connection with any legal proceedings.  In no event will Pew retain personal data relating to unsuccessful candidates for a longer period than two years following the end of their application process.

Transfer of Personal Data

Your personal data will be disclosed outside the European Economic Area only to those individuals who need access to your Personal Data for the purpose of conducting pre-employment background checks and / or during the recruitment process . 

Your applicant profile data will be hosted by iCIMS, meaning that the technical processing and transmission of your personal data may involve transmissions over various networks, including the transfer of this information to the United States of America (the “USA”) (which does not provide a level of data protection equivalent to that of your home country) and/or other countries as determined by iCIMS for storage, processing and use by iCIMS, its affiliates, and their agents. The iCIMS Data Security & Privacy Policy explains their commitments to privacy and security.  iCIMS is certified by the U.S. Department of Commerce as compliant with the EU-U.S. Privacy Shield Framework regarding the collection, use, and retention of personal information transferred from the European Economic Area to the United States.

All of Pew’s recruitment decisions are made in the USA, which is the purpose of the overseas transfer  of personal data collected in the course of your application process.

In addition, Pew may need to transfer personal data and sensitive personal data to third party providers solely for purposes related to the assessment of your suitability for employment.  The types of third parties to whom Pew may need to transfer personal data include, but is not limited to: background check providers;  IT service providers; travel providers; legal advisors and/or other professional advisors. 

Pew will take appropriate steps to make sure that such recipients of your personal data act in accordance with applicable law. To the extent Pew transfers personal data outside the European Economic Area, Pew will provide, and will take appropriate steps to ensure that such recipients provide, an adequate level of protection of your personal data, including appropriate technical and organisational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law. 

Pew uses Standard Contractual Clauses ("SCC") in the form approved by the European Commission when it transfers personal data within the Pew group or to third parties other than iCIMS.

Your rights

Under the Data Protection Laws, you have certain rights to:  (i) access to your personal data ; (ii) requesting correction of your personal data that is incomplete or inaccurate; (iii) in certain circumstances, you may have the right to object for legitimate reasons to the processing of your personal data in accordance with the Data Protection Laws, (iv)  have your personal data erased under certain circumstances, such as when you have revoked a previously given consent, (v) restrict the processing of your personal data to only comprise storage of your personal data, e.g. during the time when the company assesses whether you are entitled to have personal data erased, and (vi) under certain circumstances, receive a copy of your personal data processed in a common machine-readable format and to require us to transmit it to another data controller where this is technically feasible (data portability).

You also have a right to lodge a complaint with the CNIL (3 Place de Fontenoy - 75334 PARIS CEDEX 07) regarding the processing of your personal data.

Contact us

This policy is owned and administered by the Senior Vice President, General Counsel and Corporate Secretary, who may be contacted by emailing privacy@pewtrusts.org or by calling (202) 552-2000. If you have any questions or concerns about this Policy, any concerns about your information being processed or transferred as outlined above, if you require access to your personal data held by Pew, or if you would like to correct your personal data, please contact the organisation using the contact information provided above. If you have any questions or comments relating to this policy, please contact us before submitting your application.