Candidate Privacy Notice

Last updated: August 2023

NAVEX, including its applicable affiliates and subsidiaries, are committed to respecting your privacy and we recognize the need to appropriately protect and manage any personally identifiable information, or personal data, we obtain about you.

This Candidate Privacy Notice (“this Notice”) describes the types of personal data (or “personal information”) we may collect, how and why we may use your personal data, how long we may retain your personal data and how we protect your personal data. In addition, this Notice provides you with certain information that must be provided under applicable laws, including the General Data Protection Regulation ((EU) 2016/679) and the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively the “CCPA/CPRA"). 

If you are located in the UK, European Economic Area, or Switzerland NAVEX Global, Inc. is the data controller in relation to your personal data.  

The kind of information we obtain about you

In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your curriculum vitae and cover letter.
• The information you have provided on our application form, including name, title, address, telephone number, personal email address, employment history, qualifications.
• The information provided to us in connection with a pre-employment aptitude test.
• Any information you provide to us during an interview.
• Information relating to criminal convictions and offences.
• Information relating to your credit record and financial worthiness.
• Information relating to your health.
• Information relating to your racial or ethnic origin.

What are the sources of your personal information?

We may collect personal information about candidates from the following sources:

• You, the candidate or your devices. 
• Our affiliates and subsidiaries.
• Recruitment and talent management agencies.  
• Vendors who provide services on our behalf.
• Social networks, such as your public professional networking profile.
• Employees and others who refer you to us.
• Credit bureaus, credit reporting service provider, background check services.

How will we use information about you?

We may use your personal data to:

• Assess your skills, qualifications, and suitability for the role.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Provide you a pre-employment aptitude or skills test.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.
• Decide whether to offer you employment and enter into a contract of employment with you.
• Contact you about suitable alternative roles in the event that your application is not successful.

Having received your CV, cover letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be screened by our in-house recruitment team. Once screened by our in-house team, we will decide whether your application is strong enough to invite you for an interview, be it by telephone, in person or other electronic means. You may be invited to take a pre-employment aptitude or skills test as part of our screening process. If we decide to engage you for an interview, we will use the information you provide to us during the interview to decide whether to offer you employment. 

If you are a resident of the European Economic Area, the United Kingdom, or Switzerland we process your personal data for the purposes described above because (i) we have a legitimate interest in operating our business and managing the recruitment process, or (ii) because we are required to do so by law or to discharge our regulatory obligations. In addition, we may process your sensitive personal data and information relating to criminal convictions and offences as described below:

• We may process information relating to criminal convictions and offences, and information relating to your credit record and financial worthiness, for purposes of background checking and ensuring you are suitable for the role applied for, and we do so on the basis of your consent.
• We may process information relating to your health and disabilities for purposes of accommodating disabilities and making any required reasonable adjustments, and we do so because we are required by law.
• We may process personal information relating to your racial or ethnic origin for purposes of equality, diversity and inclusion monitoring, and we do so either with your consent or, if you are located in the United Kingdom, because it is necessary for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment.

If you fail to provide personal information

If you fail to provide the required information when requested (please note many sections of our application form is voluntary), which is necessary for us to consider your employment (such as evidence of qualifications or work history), we will not be able to process your application successfully and unable to take your application further.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing with service providers and other countries

We will only share your personal data with third party partners as follows:

• For the purposes of processing your application; 
• We may share your information with other companies within our ownership group if we believe they may have relevant vacancies you might be interested in;
• Any service provider or other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies and applicable law. We do not allow service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.

As applicable, we may transfer your personal information to the United States in support of our employment and recruitment processes. We have taken appropriate safeguards to require that the personal information we process will remain protected when transferred internationally. NAVEX relies on transfer mechanisms approved by authorities in the country from which your personal data is transferred.  

For any personal data we receive from the EEA, the United Kingdom, or Switzerland, NAVEX complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”), including the onward transfer liability provisions, as set forth by the U.S. Department of Commerce (the “Frameworks”). NAVEX Global, Inc. has certified to the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles with regard to the processing of personal data received from the European Union, United Kingdom (and Gibraltar) and Switzerland in reliance on the Frameworks. 

If there is any conflict between the terms in this Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (the “DPF Principles”), the DPF Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov.  As required by the Frameworks, any personal information we receive under the Frameworks will be maintained in accordance with the DPF Principles. NAVEX is responsible for the processing of personal information it receives, under each of the Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

The Federal Trade Commission has jurisdiction over NAVEX’s compliance with the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF.

In compliance with the Frameworks, NAVEX commits to resolve DPF Principles-related complaints about our collection and use of candidate personal data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF should first contact NAVEX at: privacy@navex.com.

In compliance with the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF, NAVEX commits to cooperate and comply, respectively, with the advice of the panel established by the EU data protection authorities (“DPAs”), the UK Information Commissioner’s Office (“ICO”) and the Gibraltar Regulatory Authority (“GRA”), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF in the context of the employment relationship.

If you are resident in the EEA, United Kingdom or Switzerland and believe that your personal data has not been processed in compliance with the Principles, you may raise your complaint in a number of ways:

(1) You can contact us directly using the contact details provided below and we will respond to your complaint within 45 days of receipt:

Please use this web form or contact privacy@navex.com. 

(2) If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you can contact your state or national data protection or labour authority in the jurisdiction where you work. We have committed to cooperate with the panel of the EU Data Protection Authorities (DPAs), and the state or national data protection authority where you work, to investigate unresolved complaints. 

Under certain conditions, described more fully on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Data security

We maintain administrative, physical, and technology-based security measures to protect your personal information against loss, misuse, unauthorized access or disclosure, destruction, and alteration. In addition, we limit access to your personal information to those employees, agents, contractors, and other third-party partners who have a business need-to-know. Such individuals will only process your personal information on our instructions and are subject to a duty of confidentiality.

Data retention

NAVEX retains personal information about you for the time period reasonably necessary to achieve the purposes outlined in this Notice unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitations and records retention requirements under applicable law. 

• Where you are not hired by us, we may retain your personal information for a reasonable period so that we can make you aware of any suitable alternative roles that arise during this period. 
• We also retain your personal information so that we can demonstrate, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
• Unless prohibited by applicable law, you can request that we not retain your personal information by notifying us at any time and we will delete your personal information.

Your Rights

You have certain rights regarding your personal information. 

Rights provided under the DPF to personal information transferred from European Union (EU) member countries, the United Kingdom, and Switzerland to the United States. NAVEX respects your control over your information and, upon request, we will confirm whether we hold or are processing information that we have collected from you. You also may have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please use this web form.

European Economic Area, Switzerland or United Kingdom Citizen Rights. Individuals who reside in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK) have additional rights reserved under the General Data Protection Regulation (GDPR), the UK Data Protection Act, and/or ePrivacy Directive, as applicable. This section details those additional rights and information on how to exercise them:  

• You may request to access, correct, update, or request deletion of your personal information.  
• You may request additional information related to the purposes for which we process your personal information, the categories of personal information we process, where we originally collected the information, who we share it with, and how long we will retain it.
• You may object to our processing of your personal information, request that we restrict the processing of your personal information or request portability.
• You have the right to opt-out of marketing communications we sent you at any time. You can do so by clicking the “unsubscribe” or “opt-out” link in the marketing emails we send to you. You may also opt-out of other forms of marketing (such as postal or telemarketing).
• Where we have collected and processed your personal information with your consent, you can withdraw your consent at any time. However, withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Upon your request, and where it is technically feasible, NAVEX will provide you with a copy of your personal information or transmit it directly to another controller.
• If we process your personal information based on your consent, you have the right to withdraw your consent at any time.
• You have the right to submit a complaint to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authorities. Contact details for EEA data protection authorities are available here, and contact details for Swiss data protection authorities are available here. If you are located in the UK your local data protection authority is the Information Commissioner’s Office.

To make a request please use this web form or email us at privacy@navex.com with “Personal Information Request” in the subject line, and provide us with full details in relation to your request, including your contact information and any other detail you feel is relevant. NAVEX will provide a response to an access request within 30 days of receiving such request or if we cannot, we will notify you and provide you with the reason for the delay.  

Identity Verification Requirement.  We are required by law to verify that any request submitted was made by someone with the legal right to access the data. Therefore, prior to accessing or divulging any information pursuant to a data subject access request, we may request that you provide us with additional information in order for us to verify your identity and legal authority.  

Under certain circumstances we may not be able to fulfill your request, such as where doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort; in any event, we will respond to your request within a reasonable time frame and as required by law, and provide you an explanation.  

California Resident Rights.  If you are a California resident, please review the California Privacy Statement below for more information about your privacy rights. 

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO by email, at privacy@navex.com.  

Complaints

You have the right to make a complaint at any time to your local supervisory authority for data protection issues.

Cookies on NAVEX’s Career Site

A “cookie” is a small text file stored on a user’s computer or mobile device when you visit a website or use Web-based software. Cookies send information back to the originating website on each subsequent visit to that site, or to another site that recognizes that same cookie. Cookies come in many different forms and are useful because they allow a website or software provider to recognize a user’s device and keep track of preferences. A website provider may receive reports based on the use of cookies, and similar technologies, on an individual or aggregated basis.

For NAVEX’s Career Site (e.g. https://navexglobal.wd5.myworkdayjobs.com/en-US/NAVEX and related pages), NAVEX uses only cookies which are required for the website to function properly. NAVEX also uses a tracking pixel to track progress through our application process.

All cookies used on our Career Site are session-based. Session cookies make it easier to navigate our Career Site and disappear from your computer when you close your browser or turn off your computer.

These cookies cannot be switched off in our systems. They support session management (permitting timing out session after inactivity), security management (protecting web infrastructure against potential attacks), and routing (forwarding requests for a single session to the same server for consistency of service across pages within the Career Site). You can set your browser to block or alert you about these cookies, but some parts of our Career Site will not work if you block them. 

California Privacy Statement

Last Updated: August 2023

This California Privacy Statement (the “Statement”) supplements the NAVEX Candidate Privacy Notice above and applies solely to California job candidates. This Statement does not apply to visitors of NAVEX’s website, representatives of NAVEX’s business customers and business partners, and NAVEX’s personnel. The statement uses certain terms that have the meaning given to them in the CCPA/CPRA. 

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the last updated date of this Statement) the following categories of personal information about you: 

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (e.g., device identifier, unique pseudonym, or user alias/ID), telephone number, online identifier, Internet Protocol address, email address, account name, login credentials, and other similar identifiers. 
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, and state identification card number.
• Protected Classifications: characteristics of protected classifications under California or federal law, such as gender, race, age, sex, national origin, citizenship status, and military and veteran status.
• Sensory Information: audio, electronic, visual and similar information.
• Employment Information: professional or employment-related information, such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information) and emergency contact information.
• Skills Testing Information, such as typing skills, dependent upon the applicable role.

We may use (and may have used during the 12-month period prior to the last updated date of this Statement) the categories of personal information for the purposes described in the “How we will use information about you?” section of the Notice above and for the following Business Purposes as they are described in the CCPA/CPRA:  

• Performing services.
• Certain short-term, transient uses.
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes. 
• Debugging to identify and repair errors that impair existing intended functionality
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

NAVEX does not collect or process sensitive personal information with the purpose of inferring characteristics about job candidates.  

Retention of Personal Information

NAVEX retains personal information about you as described in the “Data retention” section of the Notice above. 

Sources of Personal Information

During the 12-month period prior to the last updated date of this Statement, we may have obtained personal information about job candidates from the categories of sources listed in the “What are the sources of your personal information?” section of the Notice above. 

Disclosure of Personal Information

During the 12-month period prior to the last updated date of this Statement, we may have disclosed the following categories of personal information about job candidates for a business purpose to the following categories of third parties:

• Our affiliates and subsidiaries  
• Vendors who provide services on our behalf 
• Professional services organizations, such as auditors and law firms 
• Recruiting and talent agencies 
• Credit bureaus, credit reporting service providers and background check services

| | Additional data subject to Cal. Civ. Code § 1798.80  |

• Our affiliates and subsidiaries 
• Vendors who provide services on our behalf 
• Professional services organizations, such as auditors and law firms

| | Protected Classifications  |

• Our affiliates and subsidiaries 
• Vendors who provide services on our behalf 
• Professional services organizations, such as auditors and law firms

| | Sensory Information |

• Our affiliates and subsidiaries  
• Vendors who provide services on our behalf 
• Professional services organizations, such as auditors and law firms

| | Employment Information   |

• Our affiliates and subsidiaries  
• Vendors who provide services on our behalf 
• Professional services organizations, such as auditors and law firms 
• Recruiting and talent agencies 
• Credit bureaus, credit reporting service providers and background check services

| | Skills Testing Information  |

• Our affiliates and subsidiaries  
• Vendors who provide services on our behalf 
• Recruiting and talent agencies

|

In addition to the categories of third parties identified above, during the 12-month period prior to the last updated date of this Statement, we may have disclosed personal information about job candidates to government entities (e.g., in response to law enforcement requests) and third parties in connection with corporate transactions (e.g., mergers, acquisitions, joint venture, reorganization, divestitures, dissolution or liquidation).

NAVEX Global does not sell or share for cross-context behavioral advertising purposes personal information about job candidates. 

California Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion: You have the right to request that we delete certain personal information we have collected from you. 

How to Submit a Request

To submit a request to access, correct, or delete your personal information, please use this web form or call us toll-free at 1-844-842-0916. To submit a request as an authorized agent on behalf of a consumer, please email us at privacy@navex.com with the subject line Authorized Agent Request.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. For example, if you have an online account for HR purposes with us, we may verify your identity by requiring you to sign into an applicable account. Alternatively, we may reach out to you directly as our candidate for employment to verify your identity or require you to provide us information to enable us to verify your identity, for example your resume/cv or address information. In addition, if we cannot verify you through an online or this is inapplicable, and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

If you designate an authorized agent to make a request on your behalf, depending on whether you have an online account with us, we may require that you verify your identity as set forth above. We also may require you to provide the authorized agent a written confirmation that you have authorized the agent to act on your behalf and the scope of such authorization.

Additional Information

If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. If you have any questions about this Statement or concerns about our privacy practices, please contact our DPO by email at privacy@navex.com.