APPLICANT PRIVACY NOTICE
Introduction
This notice (Notice) describes how Kaney, Inc. and its subsidiaries and related companies handle and protect data to which Kaney, Inc is provided access in connection with the recruiting process.
By making available your Candidate Data, as defined below, you confirm that:
- You have reviewed this Notice and agree that Kaney, Inc may process your Candidate Data in accordance with this Notice;
- You have provided any notices and obtained any consents needed to provide information concerning others (e.g., information about employment references); and
- Your Candidate Data may be transferred and processed worldwide, including the US and other countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Notice.
Kaney, Inc will process Candidate Data in accordance with this Notice, unless in conflict with requirements of applicable law, in which case applicable law will prevail.
Your consent to the provisions of this Notice is required in order to submit or make available Candidate Data. If you decline to submit or make available your Candidate Data, it may affect your ability to apply for or receive an offer of employment.
This Notice does not form part of any contract of employment offered to candidates hired by Kaney, Inc.
Definitions
Candidate Data is identifiable information that an individual makes available to Kaney, Inc. either directly or indirectly in connection with the recruiting process or sharing your work experience or interests. Kaney, Inc may collect Candidate Data directly from a job candidate or from third parties, for example, in connection with a background or employment check or employment reference, subject to your consent where required by law. Candidate Data may include a variety of information, such as candidate status, work history/job data, education, compensation, employer feedback, questionnaire results, contact information, previous addresses or names, additional information provided by the candidate (e.g., a cover letter), expertise or project work publicly shared, driver’s license number as required for certain positions, references, and criminal history where permitted by law.
Processing refers to any action performed on Candidate Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, or deleting.
Sensitive Candidate Data is Candidate Data concerning nationality or citizenship, race or ethnic origin, criminal history, or trade union membership. Kaney, Inc does not request or consider information concerning religion, sex life or political opinions in connection with recruiting.
Collection
You may use various electronic and paper methods to submit Candidate Data to Kaney, Inc. You agree that, in addition to collecting Candidate Data directly from you, Kaney, Inc may collect Candidate Data from third parties, for example, from recruiters, in connection with a background or employment check or an employment reference (subject to your consent where required by law) or, to the extent permitted by law, from a recruiting or other web site where you may have provided information about your work experience or interests.
Processing and Retention
Kaney, Inc processes Candidate Data for legitimate human resources and business management purposes. These include identifying and evaluating candidates for Kaney, Inc positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where permitted by law. In addition, Candidate Data may be used to comply with Kaney, Inc’s legal, regulatory and corporate governance requirements. If a candidate is hired, Candidate Data may be used in connection with his/her employment consistent with Kaney, Inc’s employment data protection policies.
In addition to using Candidate Data for the position for which you have applied, Kaney, Inc may retain and use your Candidate Data to consider you for other positions. If you do not want to be considered for other positions or would like to have your Candidate Data removed, you may contact Kaney, Inc as specified under Inquiries, Complaints, Objections and Restrictions below. Unless required for tax or other legal purposes or in connection with employment as specified above, Candidate Data will be retained for a maximum of three years (or less where required by law).
Sharing with Third Parties
Kaney, Inc may transfer Candidate Data to external third-party providers performing certain services for Kaney, Inc. Such third-party providers have access to Candidate Data solely for the purposes of performing the services specified in the applicable service contract, and Kaney, Inc requires the providers to undertake security measures consistent with the protections specified in this Notice.
Kaney, Inc may be required to disclose certain Candidate Data to other third parties (1) as required by law; (2) to protect Kaney Inc.’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of a candidate or other individual may be endangered. In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of Kaney, Inc.’s business, Kaney, Inc may transfer Candidate Data to successor entities or parties.
Sensitive Candidate Data
Kaney, Inc may perform background and criminal checks where permitted by law, and may process other Sensitive Candidate Data, such as citizenship or nationality information or health information, when relevant for a position and permitted by law. If Kaney, Inc intends to collect Sensitive Personal Data from third parties, you will be provided notice and the opportunity to consent. If you have a disability and would like Kaney, Inc to consider an accommodation, you may provide that information during the recruiting process. To the extent you make Sensitive Candidate Data available to Kaney, Inc, you consent to Kaney, Inc processing such Data in accordance with this Notice.
Security and Confidentiality
Kaney, Inc employs technical and organizational measures designed to protect the integrity, confidentiality, security and availability of Candidate Data, and to comply with applicable legal requirements for information security. Kaney, Inc limits access to internal systems that hold Candidate Data to individuals who need access for a legitimate business purpose.
Candidate Rights
You may exercise the following rights in relation to your Candidate Data:
Access, Correction, Deletion and Portability: Kaney, Inc will provide you access to your Candidate Data that Kaney, Inc holds, as well as a means to make that data portable, to the extent required by law in your home country, regardless of the location of the Candidate Data processing. You may request correction or deletion of that Candidate Data, except where retention is required by your contractual relationship with Kaney, Inc, in the context of a legal dispute, or as otherwise required by law. If access, correction, deletion or portability is denied, the reason for the denial will be communicated to you.
Inquiries, Complaints, Objections and Restrictions: You may withdraw consent to the processing of your Candidate Data or submit inquiries, complaints, objections and/or requests to restrict processing to the processing of your Candidate Data by sending a request in writing to: Human Resources, 1300 Capital Drive, Rockford, IL 61109; by email at dawn.johnson@kaney.us. The processes described in this Notice supplement any other remedies and dispute resolution processes provided by Kaney, Inc and/or available under applicable law.
Direct Marketing
Kaney, Inc will not use Candidate Data to offer you any products or services for personal or family consumption (“direct marketing”) or provide Candidate Data to third parties for their direct marketing. These restrictions do not apply to contact or other personal data obtained in the context of a customer, consumer or other non-employment relationship with Kaney, Inc.
Changes to this Notice
Kaney, Inc reserves the right to modify this Notice by posting changes to relevant Kaney, Inc websites. If you submit additional Candidate Data or request to be considered for a Kaney, Inc position following the effective date of a modified Notice, your Candidate Data will be handled in accordance with the Notice in effect at that time.
Effective Date: May 1, 2020