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HiBob Job Candidate Privacy Policy

JOB CANDIDATE PRIVACY NOTICE

Last updated: March 2024

This Job Candidate Privacy Notice (“Notice”) describes what personal data Hi Bob Ltd. and its local affiliates relevant to the job in question (“HiBob”, “we”, “our” or “us”) collect and process on our job candidates and applicants (“candidate(s)”, “you” or “you”) with respect to your application and recruitment process, why we collect it and how we use it. It also describes how candidates may exercise their rights to such data held with us.

We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please avoid providing us with your data.

You are not legally required to provide us with any personal data, but without it, we may not be able to process your application.

1.    What data do we collect, how do we collect it, and how do we use it?

Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you, such as your identifying data, contact details, resume/CV, work-related data, education and qualifications, salary expectations, social media activity, etc. We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process, or from other sources such as recruitment agencies, background check services (where relevant and subject to applicable law), or your references.

We may use such data to evaluate your skills and qualifications, as well as to review, assess and process your application for any of our suitable positions. This also includes communicating with you about these processes. Additionally, your data will be used to manage risk, enhance our security and anti-fraud measures, and create aggregated or inferred statistical data about our candidates to continually improve and develop our recruitment strategies.

In addition, we may use your personal data to act as permitted or required by any legal or regulatory requirements. Should we wish to conduct any additional activities that may require the use of your data, we will notify you in advance and, if required by applicable law, request your prior specific consent.

In some regions, we may also require you to submit sensitive data relating to your ethnicity, gender, and whether you have a disability, to ensure our compliance with our obligations under applicable law. We may also collect sensitive data about your prior criminal convictions and offences as part of our background checks for specific roles, if permitted or required by law. To the extent legally required, we will obtain your explicit consent prior to any such collection and use.

For the purposes of the California Consumer Privacy Act (“CCPA”), specifically in the last 12 months, we have collected the following categories of personal information about our candidates: Identifiers; Professional or Employment-Related Information; Audio, Electronic or Similar Information; Characteristics of Protected Classifications under California or US Federal Law (Sensitive Personal Information); and Inferences from Personal Information Collected. We do not use or disclose any of your data that qualifies as Sensitive Personal Information under the CCPA outside the purposes allowed by the CCPA.

2.    For what purposes do we use your data?

We will use and process your personal data as part of the employment application process at HiBob for the following purposes and in reliance on the lawful bases detailed below:

PurposeLawful Basis for Processing
To evaluate your suitability for a role at HiBob, and progress your applicationPre-Contractual Measures
To contact you about other suitable roles within HiBob in the futureLegitimate Interests
Consent (where applicable)
To maintain our internal records of recruitment and employment applicationsLegal Obligations
Legitimate Interests
To create your employee personnel file, if hired
To comply with applicable legislation and industry codes
To manage risk and enhance our security and anti-fraud measuresLegitimate Interests
To further develop and improve our recruitment processes
To protect the rights and interests of HiBob and its affiliates

If you reside in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein, then your application will be deemed as your consent to the processing of your personal data for all purposes detailed in this Notice. If you wish to revoke such consent, you may do so at any time by contacting us at [email protected]. However, please note that revoking your consent will not affect the lawfulness of our use of your personal data up to that point, and we will be required to delete it only if no other legal basis exists to justify its continued processing at the time of withdrawal.

3.    Where do we store your data?

Your personal data will be maintained, processed and stored by HiBob and our Service Providers (as defined in Section 6 below) in the applied position’s location(s), in relevant HiBob offices worldwide (including in the European Union (EU), United Kingdom (UK), Israel, Australia, Canada and the United States (US)), and other jurisdictions as necessary for the proper handling of your candidacy.

While privacy laws may vary between jurisdictions, HiBob, its affiliates and Service Providers processing personal data on our behalf are each committed to protecting personal data in accordance with this Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

To the extent we transfer candidates’ personal data originating in the European Economic Area (EEA), or the UK to countries that have not been recognized as offering an adequate level of data protection based on the adequacy decisions published by the European Commission (and associated) or the UK, as relevant, we rely on appropriate contractual undertakings and data transfer mechanisms as established under applicable law, such as the standard contractual clauses adopted by the EU (available here) and the UK (available here). You can obtain a copy by contacting us as indicated in Section 11 below. For data transfers to countries that been recognized to be providing an adequate level of data protection, we rely on such adequacy findings regarding the level of data protection offered by the recipient country.

4.    For how long may we keep your data?

We may retain candidates’ data even after the applied position has been filled or closed. This is done so we may reconsider candidates for other positions and opportunities at HiBob; so that we may use their personal data as reference for future applications submitted by them; in case the candidate is hired, for additional employment and business purposes related to their work; and as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.

5.    How do we secure your data?

HiBob has implemented physical, procedural and electronic security measures designed to protect the personal data of our candidates, including encryption as appropriate. These measures provide sound industry standard security. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us.

6.    Who will have access to your data?

HiBob will disclose your personal data to several selected third-party service providers, whose services and solutions complement, facilitate and enhance our own. These include any recruitment firms that have referred you to us (or vice versa), candidate evaluation centers, applicant tracking and recruitment software providers, background checks providers (where permitted by applicable law), data storage and cybersecurity services, web analytics, and our business, legal, compliance and financial advisors (collectively, “Service Providers“). Such Service Providers may receive or otherwise have limited access to our candidates’ personal data, depending on each of their particular roles and purposes in facilitating and enhancing our recruitment process, and may only use it for such purposes.

Additionally, we may disclose or otherwise allow competent public authorities access to any candidate’s personal data pursuant to a binding legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that: (a) we are legally compelled to do so;  (b) such disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud or other wrongdoing; or (c) such disclosure will help protect the rights, personal safety or property of HiBob, any of our employees, or any member of the general public.

In addition, we may disclose your personal data internally within our group of companies, for the purposes described above. Finally, should HiBob undergo any change in control, including by means of merger, acquisition or purchase of all or part of its assets, your personal data may be disclosed to the parties involved in such event.

For the purposes of the CCPA, in the last 12 months, we may have disclosed to the above-mentioned third parties the following categories of personal information about our candidates: Identifiers; Professional or Employment-Related Information; Audio, Electronic or Similar Information; Characteristics of Protected Classifications under California or US Federal Law (Sensitive Personal Information); and Inferences from Personal Information Collected. We will never sell our candidates’ personal information nor share it with third parties for cross-contextual behavioral advertising purposes, for the intents and purposes of the CCPA, regardless of their place of residence.

7.    Which cookies and tracking technologies do we use?

HiBob uses certain monitoring and tracking technologies, such as “cookies” and other downloaded data files, including ones offered by our Service Providers. These technologies are used to maintain, provide and improve our processes and operations on an ongoing basis, and in order to provide a better experience to our website visitors, including our candidates. For example, these technologies enable us to better secure our website and services and detect abnormal behaviors, to identify technical issues, and to monitor and improve the overall performance of our services and processes. To learn more about our cookie practices, please visit our Cookie Policy.

8.    How can you exercise your rights?

If you wish to exercise your privacy rights under any applicable law (including the EU or UK General Data Protection Regulation (GDPR), the CCPA or other US state privacy laws), you may do so by contacting us at [email protected] and we will respond within a reasonable timeframe and in accordance with applicable law.

Such rights may include – each to the extent available to you under the laws that apply to you – the right to know or request access to specific pieces of personal data collected, categories of data collected, and sources from whom it was collected, as well as the purposes of collecting it and categories of third parties to whom we have disclosed it; the right to request rectification or erasure of your personal data held with us; the right to port it or to restrict its processing; the right to object at any time to any processing of your data which is based on our legitimate interests, or to withdraw at any time your consent to any processing of your data on the basis of such consent, (each as detailed in Section 2 above); or the right to equal services and prices (e.g., freedom from discrimination). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or UK, as applicable.

You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. In such cases, we may request further information to verify such power of attorney and authorization.

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information, along with any communications and records related to your request, may then be retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above.

9.      Who is responsible for your data?

Certain data protection laws and regulations, such as the EU and UK GDPR, the CCPA and other US state privacy laws, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means for processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller.

HiBob’s local affiliate relevant to the role for which you apply is typically the Data Controller of your personal data, and with respect to which, assumes the responsibilities of a Data Controller – solely to the extent applicable under the law and as set forth in this Notice. In such instances, our Service Providers processing such data will assume the role of Data Processors.

10.   Will this Notice be updated?

We may update this Notice to reflect changes in our privacy practices. If we make any changes that we deem as “material”, and affect how your personal data may be processed, we will provide you with notice via the communication means available to us prior to the change becoming effective.

11.   What if you have any questions?

Data Protection Officer: HiBob has appointed PrivacyTeam Ltd. as our external Data Protection Officer (DPO), for monitoring and advising on HiBob’s compliance with data protection laws and regulations around the world, and serving as a point of contact on privacy matters for everyone whose personal data we process – including our candidates. If you have any comments or questions regarding this Notice, if you have any concerns regarding your privacy, please contact our DPO at [email protected].

Questions, concerns or complaints: If you have any comments or questions regarding our data practices or your privacy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by HiBob, you can contact our Data Protection Officer at [email protected].