ExteNet Job Applicant Privacy Notice

Last Updated: August 1, 2021

 

Scope and Overview

This Privacy Notice describes how ExteNet Systems and its subsidiaries (“ExteNet”, the “Company”, “we” or “us”) collect and process personal information about applicants and potential employees (“consumers” or “you”) during the application and recruitment process.

This Privacy Notice describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, and when we may disclose your personal information to third parties. We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

This notice complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Collection of Personal information

For purposes of this Privacy Notice, personal information means any information about an identifiable individual collected in connection with the recruitment process. ExteNet may collect personal information directly from you, as a job applicant, or may receive personal information from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. Personal information excludes anonymous or de-identified data that is not associated with a particular individual.

We may collect, store, and process the following categories of personal information in connection with our recruiting activities:

At the initial stages of recruitment, we may collect, hold and use the following types of personal information about you:

  • Information contained in your application form/resume/cover letter, including your name, title, contact details, employment history, experience, skills, qualifications/training (including educational, vocational, driving licenses where appropriate), referees’ names and contact details, etc.
  • Publicly available information about you, such as your business social media presence (including any of photographs of you posted to such site(s)).
  • Selection information, including correspondence, interview notes, internal notes, the results of any written or online selection tests.
  • Equal opportunities monitoring data which could include information about your race or ethnicity, religious beliefs, sexual orientation or health. We only use this information to monitor equality of opportunity and diversity in our recruitment process.
  • Information relevant to any request by you for accommodations to the recruitment process as a result of an underlying medical condition or disability. We may use this information to enable us to carry out a fair, non-discriminatory recruitment process by considering/making reasonable adjustments to our process as appropriate.
  • Any additional personal details that you otherwise voluntarily provide to us.

If you receive a conditional offer of employment, we may collect, hold and use the following additional types of personal information about you:

  • Pre-employment check information, including references and verification of qualifications.
  • Right to work checks and related documents.
  • Medical test results.
  • Driving test results/driver motor vehicle records (if applicable to proposed line of work)
  • Information about your health or mental state in a pre-employment medical questionnaire and/or examination, as well as any information about underlying medical conditions and adjustments that you have brought to our attention. We use this information to assess whether you are fit to do the job with adjustments, to consider/arrange suitable adjustments and to comply with health and safety requirements.
  • Criminal records information (if applicable to your line of work). We use this information to assess your suitability for the role and verify information provided by you.
  • Any additional personal details that you otherwise voluntarily provide to us (including personal information provided on your resume).

 

Use of Personal information

We only process your personal information where applicable law permits or requires it in connection with carrying out our application and recruitment process. We may process 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 ExteNet, 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 in writing by submitting This Form or by calling 866-892-5327.

We will only process your personal information for the purposes for which we collected it. If we need to process your personal information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal information without your knowledge or consent where required by applicable law or regulation.

We may also process your personal information for our own legitimate interests, including for the following purposes:

  • To prevent fraud.
  • To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
  • To support internal administration with our affiliated entities.

Where we have a legitimate need to process your personal information for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Data Sharing

We do not sell, rent or otherwise disclose personal information we collect to third parties for monetary or other valuable considerations. We will only disclose your personal information to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification, background checks and IT systems hosting.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.

We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:

  • To a recruiting firm to assist in our recruiting efforts.
  • To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
  • 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.
  • To protect the rights and property of ExteNet.
  • During emergency situations or where necessary to protect the safety of persons.
  • Where the personal information is publicly available.
  • For additional purposes with your consent where such consent is required by law.

 

Data Security

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 access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access. 

Data Retention

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 ExteNet, the personal information we collected 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 ExteNet, we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations.

Notification

We only ask you to provide personal information that we need to enable us to make a decision about whether or not to offer you a role. If you do not provide particular information to us, then we will have to make a decision on whether or not to offer you a role without that information, which in some cases could result in us deciding not to recruit you. If you do not provide us with names of referees or a reference when asked, we will not usually be able to offer you the role. In addition, some of the personal information you provide to us is required by law. For example, if you do not provide us with the documentation we need to check your right to work, then we cannot by law employ you.

If you choose not to provide us with personal information requested, we will tell you about the implications of any such decision at the relevant time. 

Inquiries, Concerns or Complaints

If you have any questions about this Privacy Notice or concerns about how we manage your personal information, please contact us using This Form or calling 866-892-5327. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose. We may process your personal information without your knowledge or consent where required by applicable law or regulation.

 

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

As a California resident, you have the right to know the following information about how we have collected and used your personal information during the past 12 months:

  • The categories of your personal information that we have collected.
  • The categories of sources from which we collected your personal information.
  • The business or commercial purpose for collecting and/or selling your personal information.
  • The categories of third parties with whom we share personal information.
  • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient.
  • Whether we’ve sold your personal information; and, if so, the categories of personal information received by each category of recipient. We do not sell your personal information.

The chart below summarizes our collection, use and sharing of personal information during the last 12 months before the effective date of this Privacy Notice.

 

Categories of Information We May Collect Do we collect this information? Do we share this information for business purposes?
Identifiers Yes Yes, as described in this Privacy Notice
Online Identifiers Yes Yes, as described in this Privacy Notice
Protected Classification Characteristics Possible Yes, as described in this Privacy Notice
Commercial Information No No
Biometric Information No No
Internet or Network Information Yes Yes, as described in this Privacy Notice
Geolocation Data Possible No
Professional or Employment Information Yes Yes, as described in this Privacy Notice
Education Information Yes Yes, as described in this Privacy Notice
Inferences No No
Financial Information No No
Medical Information Possible Yes, as described in this Privacy Notice
Sensory Information No No

 

 

Glossary
Categories of Personal Information Date Elements within the Category
Biometric Information An individual’s physiological, biological or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish an individual’s identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Transaction History Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Financial Information Bank account number, debit or credit card numbers, insurance policy number, and other financial information.
Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data.
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name other similar identifiers.
Government-issued ID Social security number, driver’s license, passport, or other government-issued ID, including an ID number or image.
Medical Information Personal information about an individual’s health or healthcare, including health insurance information.
Internet or Network Information Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
Physical Description An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).
Professional or Employment Information Information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations), and educational background.
Protected Classification Characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information.
Inferences Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Commercial Information Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education information Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).