Sitecore Recruitment Privacy Policy

RECRUITMENT PRIVACY POLICY

Effective Date: January 1, 2020

 

Thanks for considering an opportunity at Sitecore!

At Sitecore, we understand the value of data and the importance of protecting it. We therefore want to be transparent about the data that we collect as part of Sitecore’s employment candidate application and recruitment processes, and how we process, store and share that data.

 

SUMMARY

This Sitecore Recruitment Privacy Policy (“Policy”) explains:

1. Candidate Information we collect
2. Where we collect Candidate Information from
3. How we use and share Candidate Information
4. Use of automated tools
5. Who may have access to Candidate Information
6. Pre-employment background screening
7. Cross border transfers of Candidate Information
8. How we keep Candidate Information secure
9. Retention of recruiting records
10. Your privacy rights
11. Contact us
12. Updates to this Policy

Applications for positions globally are managed by Sitecore through our online recruitment management system. For more information on how Sitecore collects, uses and discloses information on the Sitecore website, please refer to the general Privacy Policy.

In this Policy, the words “our,” “us,” “we” and “Sitecore” refer to Sitecore Holding II A/S, a Danish limited liability company (CVR. No. 37624071) and our affiliate entities worldwide, including Stylelabs, Inc. and Hedgehog Development LLC.

For the purposes of this Policy, “Candidate Information” means any data provided by a job applicant or employment candidate, including any “Personal Data” and/or “Personal Information” as they may be defined under applicable laws.

The information you provide to Sitecore during our application and recruitment processes is voluntary, and you can choose how much to provide. However, please note that some of the questions and fields in the candidate profile of our online recruitment tool are obligatory, such as your name and contact information. If you decide not to provide that information, it may affect our ability to consider you for employment.

You are responsible for the information you provide or make available to Sitecore, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party, does not contain malicious code, and is not otherwise legally actionable.

 

SECTION 1. CANDIDATE INFORMATION WE COLLECT

Sitecore collects information (both online and offline) about you during our application and recruitment process. Under applicable laws in Europe, the Sitecore entity in the country where the job you apply for is located will be the controller of any Personal Data received as part of any employment candidate application.

While not an exhaustive list, examples of what may be collected in the recruitment process include the following:

Identifiers and contact information	Your name, address, telephone number, email address and other contact details.
Educational information	Your CV or resumé, skills, experience, education and schools attended.
Professional or employment-related information.	Background: Current and/or previous employment, educational details, qualifications and educational transcripts. Work Authorization: Legal right or eligibility to work in the region where you have applied to work (including visa status). Non-compete: Any non-compete or non-solicitation obligations that may be in place. Conflicts: Any actual or potential conflicts of interest. Criminal history: Any relevant criminal history (to the extent permitted under applicable law). References: Reference information and/or information received from background checks (where applicable), including information provided by third parties. Role-specific information: We may ask for information pertinent to a specific role, subject to applicable laws. For example, for a sales roles, we may request information relating an employee candidate’s history of products/services sold, quota attainment or methodologies. For Engineering roles, we may ask about proficiency or familiarity with coding languages, applications or operating systems. Interview information: Details from interviews and outcomes of any exercise(s) completed as part of the recruitment process. Job-search information: This includes: Details of the type of employment you are or may be looking for, desired salary and other terms relating to compensation packages and benefits. Willingness to relocate or other job preferences. Details of how you learned of the job vacancy.
Characteristics of protected classifications under applicable state law	Demographic information such as gender identity and date of birth may be collected. Please note that in some countries we may ask for information such as race/ethnicity, veteran status, citizenship/nationality and disability status for the purpose of monitoring equal opportunity as may be required under local law. However, we do not require applicants to provide race or ethnicity information, and if you provide this information it will not be viewable in the hiring or selection process.
Internet or other electronic network activity information.	This includes data collected by cookies from website visits (as permitted by law), such as the frequency and duration of visits, as further described in the Sitecore Cookie Policy.
Publicly available information.	Profile information, academic qualifications and work experience from publicly available sources relevant for the hiring process, e.g. LinkedIn profile.
Inferences drawn from data collected	Job preferences and other employment-related inferences derived from the information obtained above.

 

Sitecore does not require or request:

• Sensitive Personal Data or Personal Information such as medical history, height, weight, religion, biometric or genetic data, philosophical or political beliefs, or financial data as part of our recruiting or candidate selection. If you have a disability and would like Sitecore to consider any accommodation, you may provide that information during the recruiting process.
• Commercial information.
• Geolocation data.
• Sensory data.

To the extent that the information you choose to provide may contain sensitive Personal Data or Personal Information, such as racial or ethnic origin, political opinions or beliefs, religious beliefs, physical or mental health condition, sexual orientation, criminal offenses, trade union or works council membership, job evaluations or educational records, you expressly authorize Sitecore to process such sensitive Personal Data or Personal Information in accordance with this Policy.

 

SECTION 2. WHERE WE COLLECT CANDIDATE INFORMATION FROM

Sitecore collects Candidate Information from the following sources:

From You	When you submit an application and during the application, interview and selection process.
References	We may collect Candidate Information as part of a pre-employment reference check. Candidates and job applicants are responsible for obtaining any notices or consents for Sitecore to collect and use information from references in accordance with this Policy.
From other third parties	This includes service providers used to perform credit or background checks (to the extent that they are relevant and permitted by applicable local law) and recruiting agencies.
From the Sitecore website	When applying for a job on Sitecore’s websites, be aware that our websites use online tracking tools such as cookies. For more information, please see the Sitecore Cookie Policy.

 

SECTION 3. HOW WE USE AND SHARE CANDIDATE INFORMATION

Sitecore will collect, use, store and otherwise process Candidate Information (including Personal Data and Personal Information) on the grounds of legitimate interest for the purposes of Sitecore job applications, recruiting and resourcing activities which include:

Communications	We may contact you to inform you of vacancies, discuss current or prospective roles and provide you with information regarding your application.
Managing recruitment and resourcing activities	This includes assessing your skills, qualifications and interests for alignment with Sitecore career opportunities, setting up and conducting interviews and assessments or other activities related to organization planning, preparing an employment agreement if you are offered a job at Sitecore, assisting you with obtaining an immigration visa or work permit, to the extent that these may be required. Information may also be used to conduct other similar uses pertaining to employment candidate applications and recruitment.
Verification of Candidate Information	We may use Candidate Information to verify your identity or to conduct pre-employment background or reference checks (to the extent these may be permitted by local labor or data privacy laws).
Development of services	We may use your Personal Data to develop and improve our recruitment processes, websites and other related services. Where feasible, we use aggregated anonymized information in context of the development activities.
Legal and regulatory compliance	We may obtain and disclose Personal Data as required by law (including laws outside of your country of residence), judicial process or to respond to public or government agencies, or for national security and/or law enforcement purposes.

 

If you are offered and accept employment with Sitecore, the information collected about you during the application and recruitment process will become a part of your employment record.

 

SECTION 4. USE OF AUTOMATED TOOLS

Sitecore’s recruitment team may perform searches against our applicant database using automated tools to target relevant job requirements and match them against an applicant's credentials. Employee candidates may be asked to successfully complete tests that are relevant to the role, and such testing may make use of automated tools. However, Sitecore does not make recruitment decisions based solely on automated processes.

 

SECTION 5. WHO MAY HAVE ACCESS TO CANDIDATE INFORMATION

Sitecore may share Candidate Information among the Sitecore group of companies and with authorized third parties that may be necessary for the purposes of recruiting, pre-employment background screenings, corporate governance, acquisitions and legal or regulatory requirements.

When we share Candidate Information within Sitecore or with authorized third parties, we will ensure that there is a genuine need to transfer Candidate Information and share only the information necessary for the performance of that specific purpose. Authorized third parties include, for example, recruitment agencies, auditors, professional advisors, external legal counsel, consumer credit reporting agencies, and recruiting systems providers. Sitecore contractually requires that its authorized third parties handling Personal Data or Personal Information are bound by confidentiality. We restrict those authorized third parties by contract and require them to process information only in connection with the specific purpose for which it was disclosed. We also require them to act consistently with this Policy and to use and maintain reasonable administrative, physical and technical controls designed to protect the confidentiality and security of the information that they receive from Sitecore or employee candidates.

 

SECTION 6. PRE-EMPLOYMENT BACKGROUND SCREENINGS

As a condition to employment at Sitecore, employment candidates will be subject to pre-employment screening (to the extent permitted by applicable law). The type of screening will depend on the role and the country of employment.

The objectives of the pre-employment screening are to verify

• References from previous employers.
• Education history.
• Past employment history (including dates of employment and positions held).
• Criminal background records (to the extent permitted).

Sitecore relies upon authorized third parties to conduct pre-employment background screenings and will release Candidate Information to them for this purpose only. Prior to the background screening commencing, you shall be supplied with information about the purpose and scope of the background screening and will be asked to provide consent to the check. Your consent to the screening may be withdrawn at any time but please note that if this may impact our ability to fully assess your candidacy for the role and may be unable to hire you.

Any offer of employment is conditional upon such pre-employment checks being performed and the results of those checks being satisfactory to Sitecore.

 

SECTION 7. CROSS BORDER TRANSFERS OF CANDIDATE INFORMATION

Sitecore is a global company with business processes, management structures and technical systems that cross national borders. This means that your Personal Data may be transferred internally to Sitecore affiliates and externally to third parties (including partners and service providers) across international borders for the purposes described in this Policy.

Sitecore ensures that it transfers data only in accordance with legally approved transfer mechanisms that are appropriate under applicable data protection laws, using appropriate contractual, technical and organizational measure. Sitecore has entered into and executed an agreement for the international transfer of Personal Data within the Sitecore group of companies ("Intra-Company Agreement") which governs the processing of your Personal Data by Sitecore entities. The Intra-Company Agreement also incorporates the European Union Model Clauses requirements for transfers of Personal Data.

Sitecore has selected Jobvite as our global online recruitment management system. Jobvite and its servers are located in the United States. For more information about Jobvite and its privacy practices, please go to: www.jobvite.com/privacy.

 

SECTION 8. HOW WE KEEP CANDIDATE INFORMATION SECURE

At Sitecore, we understand the importance of information, and the need to keep Candidate Information secure. We have implemented and maintain technical, administrative and physical security measures designed to protect Candidate Information from unauthorized access, disclosure, misuse, alteration, accidental loss or destruction and preserve the confidentiality, integrity, availability and resilience of all data both online and offline. This includes encryption, redaction, anonymization and pseudonymization where appropriate.

To demonstrate our commitment to protecting Candidate Information, Sitecore maintains a number of compliance programs and certifications in accordance with strict regulatory and industry standards. To learn more about current practices and policies regarding security and confidentiality of the Services, please visit our Trust Center.

We require that our third party service providers and partners agree to keep the information we share with them confidential and to use the information only to perform their obligations in the agreements we have in place with them. Sitecore has implemented internal policies to ensure that such parties are required under contract to maintain privacy and security protections which are at least as consistent with our own policies and practices.

However, please note that no website or internet transmission is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur and we cannot warrant the security of any information that you provide to us.

 

SECTION 9. RETENTION OF RECRUITING RECORDS

If you are successful in your job application, the information that we collect about you during the recruitment process will become part of your employment records and are kept in accordance with our policies for retention of employee data.

If your application is unsuccessful, Sitecore will retain your Personal Data on file to consider you for other job opportunities for a period of 3 years, unless a longer period is required to comply with our legal obligations and resolve any disputes relating to the recruitment process. At the end of the period, or earlier if you exercise your privacy rights, Candidate Information is deleted and securely destroyed.

Whenever necessary and to the extent permitted or required by law, Sitecore will delete and/or anonymize Personal Data that is no longer needed. Accordingly, you should retain your own copy of any information you submit to us.

 

SECTION 10. YOUR PRIVACY RIGHTS

You may access the Personal Data you have submitted through Jobvite by accessing your Jobvite account. You may be able to delete your Jobvite profile by contacting Jobvite. You may contact [email protected] to submit other requests to correct, amend or delete inaccurate information in a job application.

Additionally, depending on where you are located, you may have other rights, which may include the right of access, right to rectification, right to erasure, right to restrict processing, right to data portability and the right to object to Sitecore’s processing of your Personal Data on compelling legitimate grounds. You may exercise these rights by contacting us at [email protected] and we will review your request in accordance with applicable laws.

In the event you revoke your consent or object to certain processing activities or delete your profile completely, please note that Sitecore may be unable to continue the recruitment process with you.

 

SECTION 11. CONTACT US

We have recruiting teams in the United States, Denmark, Belgium, the United Kingdom, the Ukraine, Singapore and Malaysia. If you have any questions about a job application, please reach out to [email protected].

If you believe Candidate Information has been used in a way that is not consistent with this Policy or your specified preferences, or if you have further questions related to this Policy or Sitecore’s Privacy Policy or Privacy Shield certification, we encourage you to please contact our Privacy Team at the address below or by emailing: [email protected].

Written inquiries may be addressed to our Chief Legal Officer at:

Chief Legal Officer
Sitecore
101 California Street, Suite 1600
San Francisco, CA 94111
USA

 

Complaints and dispute resolution

While we hope that we can answer any questions that you may have, if you feel that you have not received a timely or satisfactory response from us to your question or concern, you have the right to submit a complaint to your local data protection authority or privacy regulator.

 

SECTION 12. UPDATES TO THIS POLICY

From time to time, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements or to reflect any changes in how we process information. Any changes to this Policy will be effective when we post the revised Policy on this website. The “Effective Date” section at the top of this Policy states when this Policy became applicable and serves as notice of the update.