Allied Universal^® (“we”, “our” or “us”)
Applicant Privacy Notice

Effective Date: April 12, 2023

PURPOSE OF THIS NOTICE: This Applicant Privacy Notice (the “Notice”) describes how we collect and use certain personal information relating to job applicants and candidates for positions with us (“Applicants”). This Notice is intended to satisfy notice requirements under certain applicable laws and to provide you with other information regarding our data collection and use practices. We may provide Applicants additional notices about our data collection practices where required by other laws (e.g., if we conduct a background check or extend an employment offer). For California residents, please see the section at the end of this Notice entitled “Additional Information for California Residents”, which provides additional information regarding how we use, disclose and process California residents’ personal information, as required by the California Consumer Privacy Act, as amended. 

SCOPE OF THIS NOTICE: This Notice applies to the personal information that we collect from and about Applicants, for reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with us. The categories of personal information we collect and our use of personal information may vary depending upon the position for which you are applying and the jurisdiction where you reside.  We will collect your personal information where permitted by and in accordance with applicable laws.

CATEGORIES OF PERSONAL INFORMATION COLLECTED: Generally, we may collect the following categories of personal information about Applicants:

• Name, Contact Info and other Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier, telephone number, online identifier, Internet Protocol address, email address, account name, social security number/social insurance number (or equivalent), driver’s license number, passport number, or other similar identifiers.

• Protected Classifications: characteristics of protected classifications, such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.

• Audio/Visual Data: audio, electronic, visual, thermal, olfactory, or similar information such as CCTV images and photographs, and audio recordings (e.g., recorded meetings/interviews).
• Employment History: professional or employment-related information.
• Education Information: information about education history or background.
• Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

PURPOSES FOR COLLECTING, USING AND DISCLOSING PERSONAL INFORMATION: Generally, we use the above categories of personal information for the following purposes:

• Management of Job Applications, Recruiting and Hiring. To review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:
  
  • Scheduling and conducting interviews
  • Identifying candidates, including by working with external recruiters
  • Reviewing, assessing and verifying information provided; conducting criminal and background checks; and otherwise screening or evaluate an Applicant’s qualifications, suitability and relevant characteristics
  • Extending offers, negotiating the terms of offers, and assessing salary and compensation matters
  • Satisfying legal and regulatory obligations
  • Communicating with Applicants regarding their applications and about other similar position(s) for which they may be interested
  • Maintaining Applicant personal information for future consideration
  • Supporting our equal opportunity employment policy and practices

• Security and Monitoring. To monitor and secure our resources, network, premises and assets, including:
  
  • Monitoring for, preventing, and investigating suspected or alleged misconduct or violations of work rules
  • Monitoring for, preventing, investigating and responding to security and privacy incidents
  • Providing and managing access to physical and technical access controls
  • Monitoring activities, access and use to ensure the security and functioning of our systems and assets
  • Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring

• Auditing, Reporting Corporate Governance, and Internal Operations. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administering our records retention program.
• M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, such as mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.
• Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
• Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
• Other purposes that are authorized by applicable law.  Depending on your jurisdiction of residence, local laws may authorize the collection, use and/or disclosure of your personal information for other identified purposes.

MOBILE TERMS OF SERVICE:  We use HireVue Hiring Assistant to help manage your employment application process. You may elect to use HireVue Hiring Assistant on our websites or mobile applications. If you are a U.S. resident, text “ALLIED” (255433), to receive messages about jobs that might interest you.  You can cancel the SMS service at any time by texting "STOP" to the short code. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed and you will no longer receive SMS messages from us. If you want to join again, you can text “START” to “ALLIED” (255433). If you are experiencing issues with the messaging program you can reply “HELP” for more assistance, or you can get help directly by calling 1(800) 655-4106, emailing assistantsupport@hirevue.com, or visiting https://hirevue-allyosupport.zendesk.com/hc/en-us. As always, message and data rates may apply for any messages sent to you from us and to us from you.  Messages are recurring and their frequency may vary. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. Carriers are not liable for delayed or undelivered messages. 

Please note that we operate in multiple jurisdictions and your personal information may be transferred to or stored in jurisdictions other than your jurisdiction of residence.  Accordingly, your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such foreign jurisdictions.

CONTACTING US ABOUT THIS NOTICE: If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact  privacy@aus.com

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS: As described above, this Notice applies to the personal information that we collect from and about Applicants. In this section, we provide additional information about the personal information that we collect from California residents and how we use and disclose that information, as required by the California Consumer Privacy Act, and the regulations issued thereunder, each as amended (“CCPA”). This section of this Notice does not address or apply to our collection of personal information that is not subject to the CCPA. This section of this Notice also does not apply to the personal information we collect from contractors or employees, which is subject to different privacy notices.

Categories of Personal Information Collected and Disclosed. The table below generally identifies the categories of personal information about Applicants that we collect and have collected in the prior twelve (12) months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.

Categories	Description	Third Party and Other Entity Disclosures for Business or Commercial Purposes
Identifiers	Identifiers such as a real name, alias, postal address, unique personal identifier, telephone number, online identifier, Internet Protocol address, email address, account name, social security number/social insurance number (or equivalent), driver’s license number, passport number, or other similar identifiers.	service providers advisors and agents affiliates and subsidiaries regulators, government entities and law enforcement internet service providers, operating systems, and platforms others as required by law or client contract
Characteristics of Protected Classifications Under California and Federal Law	Characteristics of protected classifications, such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.	service providers advisors and agents affiliates and subsidiaries regulators, government entities and law enforcement internet service providers, operating systems, and platforms others as required by law or client contract
Audio/Visual Data	Audio, electronic, visual, thermal, olfactory, or similar information such as CCTV images and photographs, and audio recordings (e.g., recorded meetings/interviews).	service providers advisors and agents affiliates and subsidiaries regulators, government entities and law enforcement internet service providers, operating systems, and platforms others as required by law or client contract
Employment History	Professional or employment-related information.	service providers advisors and agents affiliates and subsidiaries regulators, government entities and law enforcement internet service providers, operating systems, and platforms others as required by law or client contract
Profiles and Inferences	Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	service providers advisors and agents affiliates and subsidiaries regulators, government entities and law enforcement internet service providers, operating systems, and platforms others as required by law or client contract
Sensitive Personal Information[1]	Such as: (a) Social Security number and other government identifiers; (b) financial account and payment information (e.g., for direct deposit purposes); (c) racial or ethnic origin or sexual orientation (e.g., on a voluntary basis to support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law, or union membership); (d) biometrics (e.g., for timekeeping and access controls); and (e) health information (e.g., as necessary to provide reasonable accommodations).	service providers advisors and agents affiliates and subsidiaries regulators, government entities and law enforcement internet service providers, operating systems, and platforms others as required by law or client contract

 

Do We “Sell” or “Share” Personal Information? CCPA defines a “sale” as disclosing or making available personal information to a third party in exchange for monetary compensation or other benefits or value, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose Applicant personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) personal information that we collect on the careers pages of our websites (the “Career Sites”), such as when we make browsing information available to third-party ad companies (through third-party tags on the Career Sites) in order to improve and measure our ability to reach you with advertisements and information about career opportunities or make usage data available to third party companies who perform analytics on the information. As defined by the CCPA, we may “sell” or “share” certain categories of personal information as follows: identifiers and usage data. We sell and share these categories with third-party advertising networks, social networks, and data analytics providers (such as when we allow third-party tags to collect browsing history and other information on our Career Sites to improve and measure our ad campaigns). We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.  

Sources of Personal Information.  In general, we may collect Applicant personal information identified in the table above from the following categories of sources:

• Directly from you
• Recruiters and recruiting platforms
• Referrals and references
• Publicly available information and data brokers
• Government entities
• Service providers, representatives and agents
• Affiliates and subsidiaries
• Your use of Allied systems and devices

 

Retention. Allied retains the personal information we collect only as reasonably necessary for the purposes described below or otherwise disclosed to you at the time of collection. For example, we will retain your information as necessary to comply with our tax, accounting and recordkeeping obligations, to consider you for additional positions (with your permission), as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.

Purposes. Subject to applicable legal restrictions, generally we collect, use, disclose and process Applicant personal information as reasonably necessary for the purposes described above under “Purposes for Collecting, Using and Disclosing Personal Information”.

Notwithstanding the purposes described above, we do not collect, use or disclose sensitive personal information about Applicants beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations).  Accordingly, we only use and disclose sensitive personal information about Applicants as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you. 

Your CCPA Rights. California Applicants have certain rights under the CCPA with respect to their personal information, subject to certain limitations and exceptions.

• Deletion: The right to request deletion of their personal information that we have collected about them. 
• Know/access: The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
• Correction: The right to request correction of inaccurate personal information we maintain about them.
• Opt out of sales and sharing: The right to opt-out of the sale and sharing of their personal information. 
• Limit use/disclosure of sensitive personal information: The right to request to limit certain uses and disclosures of sensitive personal information.  However, as discussed above, we do not use or disclose Applicant personal information beyond the purposes authorized by the CCPA.
• Non-discrimination: The right not to be subject to discriminatory treatment for exercising their rights under the CCPA. 

 

Submitting CCPA Requests.  Applicants may submit a request to us to exercise their CCPA rights by submitting a privacy request to us by using our CCPA Request Webform or by phone 855-592-6982 (toll free).    

 

We will take steps to verify your request by matching the information provided by you with the information we have in our records. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (i.e., by completing all required fields on our webform if you choose to submit a request in that manner).
• Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

 

In some cases, we may request additional information to verify your request or where necessary to process your request.  Authorized agents may initiate a request on behalf of another individual through one of the above methods; authorized agents will be required to provide proof of their authorization and we may also require that the relevant Applicant directly verify their identity and the authority of the authorized agent.

Requests to Opt Out.   As discussed above we may be deemed to be ‘selling’ or ‘sharing’ California residents’ personal information through the way that we use cookies and other tracking technologies on our Careers Sites. The Career Sites respond to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will, subject to applicable law, process that as a request to opt that particular browser and device out of sales and sharing on that Career Site. California residents may also opt out of any “sales” and “sharing” through cookies and other online tracking technologies on our Career Sites by adjusting your cookie privacy preferences for those technologies in our cookie preference manager, which you can access by clicking the “Do Not Sell or Share My Personal Information” link, accessible in the footer of our Career Sites. Note that if you come back to our Career Sites from a different device or use a different browser on the same device, you will need to enable GPC or set your cookie preferences for each browser and device you use to access our Career Sites.  More information about GPC is available at https://globalprivacycontrol.org/.