Daniel J. Edelman Holdings, Inc. and its affiliated companies worldwide, (hereinafter referred to as either, “DJEH”, “Company”, “We”, “Us” or “Our”) is an Equal Employment Opportunity/Affirmative Action Employer. The Company adheres to a policy of making all employment decisions without regard to race, color, religion, national origin, age, disability, veteran status, citizenship or any other protected classification which may be applicable under the law of the particular state or locality in which you are applying for employment with the Company.
Company is committed to protecting the privacy of personal data you may provide Us on any recruitment website that We provide (the “Site”) or as needed for use by the Company to perform legitimate Human Resource (“HR”) functions, including information collected from or related to prospective employment applicants. We believe it is important for you to know how we treat your personal data.
This policy does not form part of your employment terms.
Application Assistance for People with Disabilities
If you are unable or limited in your ability to use or access Company’s career site or otherwise process an employment application as a result of a physical or mental impairment, you can request reasonable assistance (an “Accommodation”). We will be happy to assist you, so please send an email to email@example.com or call our Corporate HR department at +1-312-517-2691 to request an Accommodation. Please leave a voice message and a member of our HR department will endeavor to call you back within 3 business days. Please note that only requests for an employment application Accommodation will be returned. If you are calling to check on the status of your application or to report a technical issue, unfortunately, we will not be able to return your call.
Company is an equal opportunity employer of all protected classes, including veterans and individuals with disabilities.
International Privacy Matters
The Company has put in place measures to ensure that Personal Information that is transferred internationally is subject to an adequate level of protection in accordance with applicable data protection laws. These include use of EU Union Standard Contractual Clauses (“SCCs”) and supplementary measures to the extent applicable. Company requires all service providers who process personal data from the UK or EEA to execute SCCs and apply applicable supplementary measures as well. Company conducts assessments and maintains legal, administrative and technical measures designed to protect personal data processed as part of our business in any part of the globe.
Daniel J. Edelman Holdings has self-certified with the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries in connection with the Privacy Shield Principles as part of the Privacy Shield program. While this certification, in and of itself, is not considered by the EU authorities to provide an adequate level of protection, Daniel J. Edelman Holdings nonetheless considers that it provides protection with regard to the processing of personal data and transparency with regard to our data processing standards. To learn more about the Privacy Shield program, and to view Company’s certification, please visit http://www.privacyshield.gov.
1. What personal data and other information does Company collect about me?
In order for us to consider your CV or application for employment, submitting an employment application, or responding to our outreach, you consent that the Company, and its applicable service providers, may collect and maintain (in both paper and electronic format) and use personal information about you as allowable by applicable law and where needed for HR Purposes (as defined below). Depending on the legitimate business need, such personal information includes but is not limited to name, personal contact and demographic details, employment history, employment application or resume submission, contact requests, surveys, and other activities you may provide as part of the application process, voluntarily provide, permit others to provide or make public about yourself) (“Personal Information”).
In addition to the Personal Information, Our web servers, along with our service providers’ web servers, automatically identify computers by their IP addresses. Company and its service providers may use IP addresses to analyze trends, administer the Site, track users’ movement and gather broad demographic information for aggregate use. To emphasize, IP addresses are not linked to Personal Information.
Further, Our Site may use technologies such as “cookies” to provide visitors with tailored information upon each visit. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Site. Every time you visit Our Site, Our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. You do not need to enable cookies to visit Our Site; however, some parts of the Site and some services may be more difficult or impossible to use if cookies are disabled. To emphasize, cookies are not linked to any Personal Information while on this Site.
Please note that under certain circumstances our clients request background checks relating to employees who work on their premises or their accounts. Under such circumstances, the Company has a legitimate interest in performing such background checks, and they are performed in accordance with applicable law and in a confidential manner designed to protect the privacy interests of the employee. The applicant is also given the opportunity to object in advance of the background check in which case it will not be carried out. The specific results of the background check are not disclosed to the client, and the employee is also given the opportunity to object in advance of the background check.
2. What does Company do with the information collected?
We will only use your Personal Information when the law allows us to. Most commonly, We will use your Personal Information in the following circumstances:
- Where We need to perform take steps at your request prior to entering into an employment contract or any agreement with you.
- Where We need to comply with a legal obligation.
- To defend the legal rights of an individual, Company, its service providers or clients or to obtain legal advice on behalf of Company or its service providers.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Instances where We may process your Personal Information on this basis are described below.
- Where you give your consent to processing.
We may also use your Personal Information in the following situations:
- Where We need to protect your interests (or someone else's interests).
- Where necessary in the public interest.
The Company considers that the following processing is necessary for its legitimate interests and Company and its service providers may use/process your Personal Information for business and human resources management purposes related to your application for employment, including but not limited to: (1) processing any employment applications and/or resumes; (2) considering your qualifications for employment opportunities within Company on a global basis; (3) registering you for online recruitment activities such as employment applications; and (4) responding to your specific requests; and for additional purposes where permitted by law including but not limited to (5) understanding the use of the Site and making improvements; (6) protecting the security or integrity of the Site if necessary; (7) complying with applicable law or legal requirements; and (8) facilitating business transactions protecting the Company, its employees or the public against injury, theft, legal liability, fraud, abuse or other misconduct. The Company may also share your information within DJEH Companies for these purposes.
In some instances, we may be required under local employment or other laws (e.g. health and safety, anti-discrimination) to maintain records that can include sensitive personal information such as information about your race, physical and mental health, political or religious opinion, trade union membership or information in relation to offences. We may process his special category personal data in the following circumstances:
- with your explicit written consent;
- where necessary to carry out obligations under employment or social security law; or
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
Your Personal Information may be accessed by authorized personnel of the Company on a global basis as necessary for purposes related to the processing of your Personal Information as described. Company retains Personal Information for relevant periods.
Note that we may use a number of manual and automated systems/processes to monitor business activities in the event of suspected inappropriate activities or on a periodic basis in order to ensure ongoing compliance (as permitted by local law), including but not limited to email monitoring, Internet monitoring and video surveillance in and around our premises in order to: prevent and detect crime; protect the health and safety of employees, contingent workers, and visitors on site; manage and protect Company property (including our computer systems and confidential information) and that of employees, contingent workers, and visitors; and where applicable, for quality assurance purposes.
- in connection with a lawful request by public authorities, such as a court order, subpoena, government investigation, or other request to meet national security or law enforcement requirements, provided that US government requests for EU and UK Personal Information shall be subject to applicable supplementary measures;
- in the event of a corporate sale, merger, acquisition, or similar or contemplated event;
- in working with third party service providers, including the provider of any recruitment Site, to support the Site’s technical operation;
- in working with third party service providers, to fulfill compliance obligations; or
- otherwise in connection with processing a submitted resume and/or employment application.
In the case of processing a submitted CV and/or employment application, Company and its affiliates may disclose your Personal Information to the provider of any Site and any other third parties as necessary to further process your resume and/or employment application. Further, Company may disclose your Personal Information to other related DJEH companies for their consideration and response for any positions within their market. In some cases, Personal Information may be shared with a client, such as situations where a candidate is being considered for a particular client engagement. In other cases, non-identifying roll-up data may be shared with clients or prospective clients to fulfill Request for Proposals or contract negotiations.
In the U.S., Company participates in E-Verify, a United States Department of Homeland Security system to confirm employment eligibility.
From time to time, Company may make third party activities, events or applications available to you that are managed by third parties not acting as vendors to Company. These third parties (such as social media platforms or other company websites and applications) are responsible for their own privacy practices. Be sure to read the privacy policies, supplemental notices, and settings of all websites or platforms that you visit so you can understand their privacy practices and your options.
4. How do I access, correct, update, limit use of or delete my Personal Information?
You have the right to make a complaint in relation to our processing of your personal data to the relevant authorities for your country. You have rights to obtain a copy of your personal data and in certain situations to obtain correction, erasure and restriction of processing of your personal data. You have a right of data portability. Where processing is based on your consent you have a right to withdraw this at any time. You are able to opt-out of our processing of your personal data in relation to direct marketing or where we process on the basis that processing is necessary for our or a third party’s legitimate interests unless we have compelling legitimate grounds to continue. If you wish to exercise any of these rights, then please notify your recruiter or the HR contact noted below. You may also automatically request to update or delete personal data by clicking on the link provided in our communications to you. We will promptly evaluate and respond to your request. Please note, however, that certain personal data may be exempt from such access, modification or deletion rights pursuant to applicable data protection laws.
Notice to California Residents- California Privacy Rights: While the Company provides comparable rights to all personnel with respect to their personal data, California law specifically requires that we provide notice to California residents that they may request from us information concerning: the categories of information we have collected; the categories of sources from which the personal information is collected; the purpose for which we collect or sell the personal information; the categories of third parties with whom we share personal information; and the specific pieces of personal information we have collected. We will not discriminate against an individual for exercising any of these rights.
5. How does Company protect the security of my Personal Information?
Company uses and/or requires service providers to use administrative, technical, physical and organizational security measures (such as encryption and access controls) which are designed to protect all Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information. We safeguard information according to established security standards, and periodically assess our methods of protecting information. If you should become aware of any known or suspected incidents of unauthorized access to, use of or disclosure of any personal information, you should report them immediately to the following email address: firstname.lastname@example.org. We will investigate all reported incidents.
7. How does the Company assess and audit its own compliance?
8. How do I contact the Company with questions or concerns?