Effective as of June 28, 2023.
1. PURPOSE
The purpose of this notice is to provide Sawtooth Software (“Sawtooth”) applicants for roles in our business with information about how Sawtooth will handle their information.
1.1 During the course of our activities we, Sawtooth, will process personal information (which may be held on paper, electronically, or otherwise) about applicants for roles in our business, and we recognize the need to treat it in an appropriate and lawful manner, in accordance with the California Consumer Privacy Act as amended (CCPA) and other applicable data protection laws. The purpose of this California privacy notice (“Notice”) is to make you aware of how we, as a business, will handle your personal information. This Notice applies to job applicants (“Applicant”) who are residents of the State of California.
1.2 This Notice also serves as our “Notice at Collection” under the CCPA.
1.3 We may amend it at any time, for which we do not require Applicant approval, but we will keep Applicant, whose personal information Sawtooth continues to process, informed of material changes and the opportunity for Applicants to opt-out if so inclined.
1.4 Sawtooth Applicant acknowledges that their personal information is processed by Sawtooth in accordance with this Notice.
2. OUR PRIVACY PRINCIPLES
At Sawtooth we are committed to protecting the information we hold on our Applicants. We will comply with the privacy principles of the Sawtooth Software Global Privacy Program, which are:
(a) Treating all personal information in a fair and transparent manner.
(b) Only using the personal information in accordance with the specified purposes laid out in this Notice.
(c) Only asking for data that we need for the specified purposes.
(d) Maintaining accurate data.
(e) Only storing information for as long as is necessary.
(f) Treating data confidentially and treating it with integrity.
(g) Taking accountability for the data we are responsible for and ensuring we are complying with the above principles in recognition of this responsibility.
3. DEFINITIONS
Throughout this Notice we will use certain terminology. Please see below for confirmation of the definition of these terms:
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It may include contact details, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you. Common types of personal information processed in a HR context may include proof of address, copy of passport, health information, references, etc.
“Processing” means doing anything with the data, such as storing, accessing, disclosing, destroying, or using the data in any way.
4. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
4.1. We may collect the following categories of personal information for the purposes explained below:
– Personal identifiers: such as your name, home address, phone number, email, passport number, driver’s license number, date of birth, signature, education, bank details, medical information, health insurance information, and unique personal identifiers (such as device IDs, cookies, beacons, pixels, mobile device IDs, and similar technologies).
– Personal information protected under California Civil Code Section 1798.80(e): such as information about your age, race, ethnicity, marital status, sex, or gender.
– Characteristics of protected classifications under California or federal law: such as your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license information or state ID number, insurance policy number, education information, employment information, bank account number, other financial information, medical information, biometric information or health insurance information.
– Professional or employment-related information: such as your academic background, employment record, references, information relating to your achievements, accreditations, and awards.
– Education information: such as your academic background, education transcripts, and information related to your achievements, accreditations and awards, and training.
– Sensory data: such as video or audio information relating to your interview or CCTV footage as monitored by our security cameras in the facilities we operate.
– Inferences taken from other personal information, including information to create a profile: information inferred from information gathered sources to create your profile (e.g., this could refer to things like your characteristics, behavior, abilities).
– Sensitive personal information: as defined in the CCPA, such as your driver’s license information, passport information, bank details, or information about your race, health, or ethnic origin.
4.2 We may also collect notes linked to job interviews, information obtained from our background screening, test results, or any other information you provide when applying for a job with us.
5. SOURCES OF PERSONAL INFORMATION
5.1 We will collect personal information directly from you during your application process or when you otherwise contact us.
5.2 In most instances, you are required to make your personal information available (such as part of your job application), and the supply of the information is accordingly mandatory. In instances where it is voluntary, we will inform you accordingly.
5.3. We may combine personal information that you provide us with information we collect from elsewhere. Such sources may include:
- Recruitment partners;
- Academic institutions;
- Social media platforms or publicly accessible sources (e.g., Twitter, Facebook, and LinkedIn);
- Previous employers and references;
- Pre-employment screening and background check vendors and
- Other sources from you. For example, accreditation boards etc.
6. BUSINESS PURPOSES FOR COLLECTING PERSONAL INFORMATION
We process the categories of personal information listed above for the following purposes:
- Recruiting our employees: we use your personal information to manage your job application and application profile, assess your academic background, arrange and conduct interviews, and to communicate with you.
- Conducting prior screening and background checks: we use your personal information to undertake screening and background checks.
- Equal opportunities legislation: we may process your personal data in order to report on and monitor globally our progress in promoting equal opportunities and compliance with equal opportunities legislation.
- Complying with legislation: we use your personal information for the purposes of adhering to applicable laws, to respond to legal orders, resolve legal disputes, exercise our rights in applicable employment or related contracts. and adhere to legal and regulatory requirements more generally.
- Our vital interests: we use your personal information to undertake internal investigations, prevent, or detect fraud or security incidents, protect our employees’ rights and safety, manage whistleblowing cases, and adhere to our company policies.
7. DISCLOSURE OF PERSONAL INFORMATION
We may share your personal information for the business purposes described in section 7 of this Notice, with the following third parties:
- Affiliates and subsidiaries: we may share your personal information with our affiliates and subsidiaries.
- Service providers: we may share your personal information with service provides (these could include head-hunters, vendors who undertake screening services or background checks, third party benefit providers, payroll firms, and finance vendors).
- Professional service firms: we may share your personal information with advisors such as auditors or legal counsel.
- Persons involved with business acquisitions or mergers: we may share your personal information to third parties in the event of a merger, acquisition, joint venture, dissolution, liquidation, or other type of re-organization).
8. PURPOSE LIMITATION
We will only process your personal information for the specific purpose or purposes notified to you.
9. DATA MINIMIZATION
Your personal information will only be processed to the extent that it is necessary for the specific purposes notified to you.
10. DATA ACCURACY
We will keep the personal information we store about you accurate and up to date. Please notify us if your personal details change or if you become aware of any inaccuracies in the personal information we hold about you.
11. STORAGE LIMITATION
We will not keep your personal information for longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems when it is no longer required. Please note that we are required by the US Code of Federal Regulations, 29 CFR Part 1602, to keep your application form and documentations for at least one (1) year.
12. YOUR RIGHTS
The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This landmark law secures new privacy rights for California consumers, including:
- The right to know about the personal information a business collects about them and how it is used and shared;
- The right to delete personal information collected from them (with some exceptions);
- The right to opt-out of the sale or sharing of their personal information; and
- The right to non-discrimination for exercising their CCPA rights.
In November of 2020, California voters approved Proposition 24, the CPRA, which amended the CCPA and added new additional privacy protections that began on January 1, 2023. As of January 1, 2023, consumers have new rights in addition to those above, such as:
- The right to correct inaccurate personal information that a business has about them; and
- The right to limit the use and disclosure of sensitive personal information collected about them.
Prior to executing your individual rights request, we will first verify your identity by asking you to provide information about yourself and comparing that information with what we have on file about you. The information we may ask you to provide to verify your identity may include your name, or some other personal identifier. You may also authorize an agent to submit a request on your behalf by submitting a written permission that authorizes the agent to act on your behalf and includes your signature. If you use an authorized agent, we will still take steps to verify your identity.
Please note that we do not “sell” or “share” your personal information, as those terms are defined under the CCPA. Additionally, we do not use your “sensitive personal information” for any purposes that would permit you to limit our use of such information. You may review Cal. Civ. Code Section 1798.121(a) to learn more about these permitted purposes.
13. DATA SECURITY
13.1 We will ensure that appropriate measures are taken against unlawful or unauthorized processing of personal information, and against the accidental loss of, or damage to, personal information.
13.2 We have in place procedures and technologies to maintain the security of all personal information from the point of collection to the point of destruction. We will only transfer personal information to a third party if they agree to comply with those procedures and policies, or if they put in place measures we deem adequate.
13.3 Maintaining data security means guaranteeing the confidentiality, integrity, and availability (for authorized purposes) of the personal information.
14. CONTACT AND QUERIES
We will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA. Should you have any queries regarding this Notice or processing of personal information by Sawtooth, please contact us by email at privacy@sawtoothsoftware.com.