Applicant Privacy

APPLICANT PRIVACY NOTICE

 

This Applicant Privacy Notice (“Privacy Notice”) describes the collection, use, retention, and sharing of your personal data when you apply for a position at Swann Communications Ltd and its subsidiaries (including, but not limited to Swann Communications U.S.A. Inc., Swann Communications Pty Ltd, Swann Communications (Europe) Limited) (“Swann Communications”, “Swann”, “we”, “our”, or “us”). For additional information, please see our global Privacy Policy. 

This Privacy Notice explains: 

• our role in data processing;
• the personal data we collect and why;
• how we share your personal data;
• information security and retention of your personal data;
• your rights with respect to personal data; and
• where to address your questions or complaints.

 

OUR ROLE IN DATA PROCESSING 

The entity responsible for the collection and use (processing) of your personal data is Swann Communications Ltd, which, for the purpose of the European Union’s General Data Protection Regulation (“GDPR”) and the United Kingdom’s Data Protection Act 2018 (“DPA”), is the data controller. Swann’s Data Protection Officer (DPO) sits within the Human Resources team ([email protected]).

 

PERSONAL DATA WE COLLECT AND WHY 

Throughout the application process with Swann, we collect personal data from you in a variety of ways. Personal data means any information relating to an identified or identifiable natural person. Except as otherwise indicated, the personal information we collect is such that we need to carry out the requested action. If you do not provide us with your personal information, we would not be able to do so. We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for one or more disclosed operational purpose, or a service provider or contractor’s operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including related to safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete your personal information. However, if you are hired, your information will become part of your personnel file and subject to our Employee Privacy Notice. 

Specifically, we collect your personal data when you: 

• Complete an application. When you apply for a position at Swann, we collect, from you, your personal identifiers (name, email address, telephone number, and physical address), your professional or employment information (resume/CV, cover letter, certifications or licenses, qualifications, employment history), and any other information you choose to include with your application. We use this information to review your background and skills, to determine your qualifications for the role you are applying to, and to confirm information related to your employment and education. The legal basis for this processing is that it is necessary to perform a contract or to take steps at your request, before entering a contract. For equal employment purposes, you also have the option (when it is clearly and specifically requested) to provide us with your protected classifications (gender, age, veteran status, disabilities) and sensitive protected classifications (race, ethnicity). We use this protected classification and sensitive protected classification information for government reporting purposes, to comply with legal requirements, to analyze requested disability accommodations as applicable, and to document any accommodations we have provided to accommodate your needs. The legal basis for this processing is our legitimate interest in the more efficient management of our application process or, where applicable, to comply with our legal obligations or our legitimate interest in compliance with non-EU legal obligations that apply to Swann. The processing condition for the processing of this sensitive information is, depending on the laws of the relevant member state, the safeguarding of your rights (Art. 9(2)(b) GDPR) or assessing your work capacity as an employee (Art. 9(2)(h) GDPR). We use this information, in the aggregate, to conduct internal analytics and benchmarking. 

• Create an account. When you create an account to apply for a position with Swann, we collect, from you, your identifiers (name, email address, telephone number) and your sensitive information (password). We use this information to communicate with you and to facilitate your access to your application. The legal basis for this processing is that it is necessary to perform a contract or to take steps at your request, before entering a contract. We also process this personal data to improve our application process as part of our legitimate interest in the facilitation and optimization of our recruitment process. 

• Information from references. When you provide references with your application, we will obtain from your references, your professional or employment information (work skills), and will draw inferences from your references, such as their thoughts on how your skills might enable you to succeed in the position you have applied for. We use this personal data to assess your suitability for the position for which you have applied. The legal basis for this processing is that it is necessary to perform a contract or to take steps at your request, before entering a contract. 

• Verify your education. When you first join Swann and throughout your tenure with us, we collect from you as well as from background check providers, and education institutions, your non-public education information (verification of education level completed, verification of dates enrolled in educational institutions, certifications obtained, report cards, transcripts). We use this information to verify your education for employment purposes. The legal basis for this processing is our legitimate interest in verifying applicants’ qualifications for positions at Swann. 

• Conduct a background check. When a background check is requested as part of the candidate review process, we will collect, from you, your personal identifiers (name, date of birth, and physical address) and sensitive identifiers (such as Social Security number). We share this information with a background check provider in order to conduct a background check to verify your identity, credentials, and criminal history, and to facilitate the background check. The legal basis for this processing is that it is necessary to perform a contract with you. The processing condition for the processing of this sensitive information is to assess your work capacity as an employee (Art. 9(2)(h) GDPR). 

• Interact with our Job Portal. If you provide your affirmative, opt-in consent to our use of tracking technologies, we will also collect information from you automatically as you interact with our Job Portal via non-essential cookies, pixels, and web beacons. Otherwise, we will only use essential cookies on the Job Portal. The legal basis for the placement and access of essential cookies is the performance of a contract. These cookies are necessary to provide the Job Portal to you. You may opt in or out of non-essential cookies at any time by visiting Cookie Preferences. 

If you opted-in (as explained above), we will use functional, analytics, and advertising cookies to collect your usage, device, and location information when you interact with the Job Portal. We use this information to: (i) track you within the Job Portal; (ii) enhance user experience; (iii) conduct analytics to improve the Job Portal; (iv) prevent fraudulent use of the Job Portal; (v) diagnose and repair errors, and, in cases of abuse, track and mitigate the abuse; and (vi) measure the effectiveness of our marketing campaigns. To adjust your privacy preferences (opt-in or out), please our Do Not Sell or Share My Personal Information form.

 

Swann will also use the personal data we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in SHARING OF YOUR PERSONAL DATA.

 

SHARING OF YOUR PERSONAL DATA 

A. General Sharing. Swann shares personal data in the following circumstances: 

• Within Swann. We share applicant personal data among our hiring decision-makers (i.e. human resources department, senior management, and hiring managers) to assess applications and make hiring decisions. Access to applicant personal data is limited to those on a need-to-know basis. The legal basis for this sharing is our legitimate interest in carrying out our business and application process efficiently. 

• For legal purposes. We may share your personal data with third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, for risk management purposes, and to comply with our legal obligations. The legal basis for this sharing is compliance with legal obligations and our legitimate interest in compliance with non-EU laws applicable to Swann. 

• During a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, we may share personal data. The legal basis for this sharing is our legitimate interest in the efficient operation of our business or, consent, where this is required. 

• With service providers.We share your personal identifiers, professional or employment information, and educational history with service providers that assist us in the application process. These service providers include our application host, background check, and drug-screening provider. When we transfer personal data from the European Economic Area (EEA), the United Kingdom (UK) or Switzerland for processing in countries outside the EEA, UK, or Switzerland which are not recognized by the EU, Switzerland or the UK as providing an adequate level of protection to personal data, for example, to the United States, we rely on approved data transfer mechanisms, such as Standard Contractual Clauses. 

• With your consent. Apart from the reasons identified above, we may request your permission to share your personal data for a specific purpose. We will notify you and request consent before you provide the personal data or before the personal data you have already provided is shared for such purpose. You may revoke your consent at any time with effect moving forward and may do so by contacting us via email at [email protected].

 

B. Sharing in the Preceding Twelve (12) Months 

For Business Purposes. In the preceding twelve (12) months, Swann has disclosed the following categories of personal information for a business purpose to the following categories of third parties: 

• We have disclosed your personal identifiers and internet or other electronic network activity information to IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair errors that impair functionality.
• We have disclosed your sensitive personal information to our background check provider to conduct a background check on you.
• We have disclosed your education information to your educational institutions to confirm your education information provided on your application.

 

C. Sale of Personal Information 

Swann only sells or shares applicant personal information via cookies as described above. Revlon does not sell or share applicant personal information for monetary consideration. To opt out of this sharing, visit Do Not Sell or Share My Personal Information.

 

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption and 24-7 threat monitoring, to protect the personal data that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal data we have collected from you.

 

RIGHTS OF INDIVIDUALS IN CALIFORNIA 

The California Privacy Rights Act (CPRA) entitles California applicants to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights: 

• Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. Once we receive your request to delete and confirm your identity, we will delete (and notify any service providers or third parties, who we have shared or sold your personal information to, to delete) your personal information, unless an exception applies under applicable law, including to comply with a legal obligation.
• Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties. Swann Communications does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. To exercise your right to opt-out of the sale or sharing of your personal information visit Do Not Sell or Share My Personal Information.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA. 
• Right to correct. You have the right to correct inaccurate personal information that we collect or maintain.
• Right to Data Portability. You have the right to ask that we transfer the personal information you gave us, to you, or in certain cases, directly to another organization, in a format that is easily understandable and to the extent technically feasible, in a structured, commonly used, machine-readable format.
• Right to limit use of sensitive personal information. You have the right to limit the use of how we use your sensitive personal information. We do not collect sensitive personal information, except financial account information, which we only use to process your purchase. However, Swann Communication’s use of your sensitive personal information, if any, does not give rise to this right.
• Right to Appeal and File a Complaint. You have the right to appeal an action taken (or not taken) by Swann Communications in response to your request. We will inform you of any action we have taken in response to your request without delay and, in any event, within forty-five (45) days after we receive your request. You can submit an appeal by calling Swann Communications toll-free 1800 267 2799, completing our online Privacy Rights Request webform, or emailing us at [email protected]. If you believe your privacy rights have been violated, you can submit a complaint to the California Privacy Protection Agency at https://cppa.ca.gov/webapplications/complaint, the California Attorney General at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company,. 

To exercise your rights, you may submit a request by calling Swann Communications toll-free 1800 267 2799, completing our online Privacy Rights Request webform, or emailing us at [email protected]. For requests submitted via telephone or email, you must provide us with sufficient information (your contact information, a description of the right to be exercised, and any details related to the exercise of that right) that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. 

To opt out of the sale or sharing of your personal information, visit Do Not Sell or Share My Personal Information, or utilize the opt out preference signal to instruct us to not sell or share any of your personal information collected online. The opt out preference signal will apply to the device, platform, app or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings.

 

Using an Authorized Agent 

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. If a consumer is using an authorized agent to submit a CCPA/CPRA privacy request to know (disclosure report) or delete their personal information, the following is required. 

• Using an authorized agent with power of attorney to submit a request to know or delete. If you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, provide only the following: the valid power of attorney executed lawfully under California Probate Code sections 4121 to 4130. 

• Using an authorized agent to submit an opt-out request. Please provide written permission, signed by the consumer, authorizing the agent to submit the opt-out request.

 

RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION AND UNITED KINGDOM

Individuals in the European Union and United Kingdom are entitled to certain rights under General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”), respectively. To the extent these laws apply to our processing of your personal data, you are entitled to the following rights:

• Right to access. You have the right to ask us for copies of your personal data, regardless of the legal basis for the processing. However, this right has some exemptions, which means you may not always receive all the personal data we process. 

• Right to rectification. You have the right to ask us to rectify personal data you think is inaccurate or incomplete, regardless of the legal basis for the processing. 

• Right to erasure. You have the right to ask us to erase your personal data except when the legal basis for the processing is to fulfill our legal obligations or to carry out a task in the public’s interest. 

• You have the right to ask us to restrict the processing of your personal data, regardless of the legal basis for the processing. 

• Right to object to processing. You have the right to object to our processing of your personal data when the legal basis for the processing is pursuant to our legitimate interests or to carry out a task in the public’s interest. 

• Right to data portability. You have the right to ask that we transfer the personal data you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal data to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means. 

• Right to lodge a complaint. You have the right to lodge a complaint with the relevant Supervisory Authority. 

To exercise these rights, please contact [email protected] or [email protected].

 

RIGHTS OF INDIVIDUALS IN AUSTRALIA 

For applicants in Australia, you are entitled to certain rights under the Privacy Act and Australian Privacy Principles. If our processing of your personal information is subject to the Privacy Act and Australian Privacy Principles, you are entitled to the following rights: 

• Right to access. You can request access to your personal information, subject to certain exceptions set out in specific Government legislation, such as the Privacy Act 1988 (Australia). Swann Communications may charge reasonable costs for providing access to your personal information. Swann Communications will require some proof of your identify before providing information to you. 

• Right to correction. You may also request us to correct the personal information that Swann Communications holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, Swann Communications will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. 

• Right to lodge a complaint. If you are concerned that the way Swann Communications collects, holds, uses or discloses your personal information may be in breach of the government Privacy Principles in your country, please send written details of your complaint to The Privacy Officer, Swann Communications, via email to [email protected]. 

• How Swann Communications will handle complaints. After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:
  • conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles; and
  • notify you of the results of our investigation of your complaint. 

If the conclusion of our investigation is that our collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles, we will take steps to remedy the breach as soon as reasonably practicable. We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe. If you are not satisfied with our response to your complaint you are entitled to seek recourse as per the local privacy laws in your country. 

To exercise these rights, please contact us at [email protected].

 

RIGHT OF INDIVIDUALS IN CANADA 

If our processing of your personal data is subject to Canadian law, the following section applies to you:

• Accessing and correcting your personal data. You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information we have about you, or if you would like to have it corrected, please contact us at [email protected], which will help us to handle your request properly. In some cases for Canada residents, we may not be able to allow you to access certain personal information in certain circumstances: for example, if it contains personal information of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. You will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal information we collected, and you must describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and correction requests using the information provided, we may ask you for additional pieces of information. 

• Right to withdraw consent. If you have given consent for the processing of your personal information, you may withdraw your consent with effect for the future. Your withdrawal of consent does not have retroactive effect, and there may be cases where we are permitted under the applicable law to process certain personal information without consent. 

• Security. In order to help prevent unauthorized access to or disclosure of personal information, we have put in place physical, electronic, and organizational procedures to help safeguard and secure the personal information we collect. Personal information may be accessed by persons within our organization or our third-party service providers who require such access to carry out the purposes described in this Privacy Notice or are otherwise permitted or required by applicable law. Even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us. 

To exercise these rights, please contact us at [email protected].

 

CHANGES TO THIS PRIVACY NOTICE 

Swann reserves the right to update or modify this Privacy Notice in our sole discretion at any time without prior notice. If we do, we will post the changes to this site, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you via email, and obtain your consent, if required.

 CONTACT US 

If you have any questions regarding this Privacy Notice, please contact us: 

By e-mail: [email protected] 

By mail: