Purpose of Personal Information Collection
Categories of Personal Information
- 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, criminal record checks, 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, name at birth and preferred name, phone number, email address, and address.
- Qualified HR data, such as nationality, passport number and issue information, residency status, date of birth, birth city and country, gender, marital status, relationship information, primary language, language skills, visa type and information (work permit/business/etc.), home address and home telephone number, and personal mobile phone number.
- Information collected during phone screenings and interviews.
- Information related to previous applications to Pew or previous employment history with Pew.
- Health information, such as health and disability information.
By choosing to submit your application, you acknowledge and agree to Pew and its subsidiary processing data relating to you in connection with your application for legal, personnel, administrative and management purposes and in particular you acknowledge and agree to the processing of any sensitive or special categories of personal information relating to you, including, as appropriate:
- Information about your physical or mental health or condition in order to take decisions as to your fitness for work and/or any adjustments that may need to be taken to enable you to work in a particular role, and to comply with internal recruitment practices and procedures and any legal requirements;
- Your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation;
- To the extent permitted by law, information relating to any criminal proceedings in which you have been involved for insurance purposes and in order to comply with internal recruitment practices and procedures, legal requirements and obligations to third parties; and
- Any other special categories of personal information to be processed.
Sensitive or special categories of personal information will only be processed where required for the relevant purposes.
Personal Information Use
We only use your personal information where applicable law permits or requires it in connection with carrying out our application and recruitment process. We may use your personal information for the following legitimate business purposes:
- Identifying and evaluating job applicants, including assessing skills, qualifications, and interests.
- Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
- Communicating with you about the recruitment process and your application.
- Keeping records related to our hiring processes.
- Creating and submitting reports as required by applicable laws or regulations.
- To comply with our legal, regulatory, or other corporate governance requirements.
- Analyzing and improving our application and recruitment process.
- Complying with applicable laws, regulations, legal processes, or enforceable government requests.
- To protect the rights and property of Pew, other job applicants, employees, or the public, as required or permitted by law.
In addition to using your personal information for the position for which you have applied, we may retain and use your personal information to inform you about and consider you for other positions that may be appropriate for you. If you do not want to be considered for other positions or would like us to remove your personal information, you may contact us as specified below under “Contact Us.”
We will only use your personal information for the purposes we collected it for. If we need to use your personal information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent. We may use your personal information without your knowledge or consent where required by applicable law or regulation.
You will not be subject to hiring decisions based solely on automated data processing without your prior consent.
Sources of Personal Information
We may collect personal information 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 employment or engagement with us (job application, employment contract, benefits application forms, personal details form, internal resume/management profile, emergency contacts, etc.);
- Through your activities in the course of the application process, such as through the interview process; and
- From third parties, including references and other background screening checks, former employers, and employment recruitment agencies, subject to the requirements of applicable law.
Retention of Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If you are offered and accept employment with Pew, the personal information we collect during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal information policies. If you do not become an employee, or, once you are no longer an employee of Pew, we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations.
Transfer and Sharing of Personal Information
Your personal information will be disclosed within Pew and its subsidiary outside Canada only to those individuals who need access to your personal information for the purpose of conducting pre-employment background checks and / or during the recruitment process or where required or permitted by applicable law.
Your applicant profile data will be hosted by Workday, meaning that the technical processing and transmission of your personal information 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 for storage, processing and use by Workday, its affiliates, and their agents. The Workday Security & Trust Page explains its commitments to privacy and security.
By submitting this application you further acknowledge and agree to the transfer of such personal information and sensitive personal information to Workday and Pew and its subsidiary outside Canada in order to host your profile data and further Pew and its subsidiary’s business interests, respectively, even where the country or territory in question does not provide a level of data protection equivalent to that of your home country. In particular, you acknowledge and agree to the transfer of your personal information and sensitive personal information to Workday and Pew and its subsidiary’s offices in the USA. All of Pew and its subsidiary’s recruitment decisions are made in the USA, which is the purpose of the overseas transfer to which you acknowledge and agree by submitting this application or any other personal information relating to your employment at Pew or its subsidiary.
In addition, Pew may need to transfer personal information and sensitive personal information to third party providers solely for purposes related to the assessment of your suitability for employment or in contracting with you for employment, respectively, even where the country or territory in which the third party is located does not provide a level of data protection equivalent to that of your home country. The types of third parties to whom Pew may need to transfer personal information include, but is not limited to: background check providers; payroll providers; HR information system providers; pension, insurance and benefits administrators; IT service providers; auditors; travel providers; legal advisors and/or other professional advisors. Pew will take appropriate steps to make sure that such recipients of your personal information act in accordance with applicable law. To the extent Pew transfers personal information outside Canada, Pew will provide, and will take appropriate steps to ensure that such recipients provide, an adequate level of protection of your personal information, including appropriate technical and organisational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law. If you wish to access written information about our policies and practices regarding service providers outside of Canada, or if you have any questions about the collection, use, disclosure, or storage of personal information by service providers outside of Canada, please contact [email protected].
We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.
- During emergency situations or where necessary to protect the safety of persons.
- Where the personal information is publicly available.
- If a business transfer or change in ownership occurs.
- For additional purposes with your consent where such consent is required by law.
Pew and its subsidiaries will process your personal information and special categories of data for its internal records and for the purposes for which you have provided it as set forth above. Your privacy is paramount to us. This data will be processed in a fair and lawful manner. Pew and its subsidiary will not share your personal information or sensitive personal information with third parties except as set out above or as necessary to carry out our business or as required by law or other legal processes. Your personal information and any sensitive personal information will be retained only for as long as necessary to fulfill the purposes for which you have provided it as set forth above, or as required by law.
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit personal information access to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
Your Rights of Access, Correction, Erasure, and Objection
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the recruitment process. By law you have the right to request access to and to correct the personal information that we hold about you or withdraw your consent to the use of your personal information under certain circumstances. If you want to review, verify, correct, or withdraw consent to the use of your personal information, please contact us at [email protected]. Any such communication must be in writing.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Under applicable law, you may have certain rights to: (i) access your personal information (subject to applicable laws); (ii) request correction of your personal information that is inaccurate; and (iii) in certain circumstances, you also may have the right to object for legitimate reasons to the processing of your personal information in accordance with applicable laws.
Right to Withdraw Consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected].
This policy is owned and administered by the Senior Vice President, General Counsel and Corporate Secretary, who may be contacted by emailing [email protected] or by calling +1 (202) 552-2000. If you have any questions or concerns about this Policy, any concerns about your information being processed as outlined above, if you require access to your personal information held by Pew, or if you would like to correct your personal information, 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.
We do not collect any additional information about you other than that outlined above. Under no circumstances will the information you provide be used for marketing purposes.