Recruitment Privacy Policy
1. INTRODUCTION
This Recruiting Privacy Policy (Privacy Policy) describes the privacy and security practices that SunTracker Technologies Ltd., its subsidiaries and affiliates (SunTracker, we or us) employ when collecting, using and handling (processing) personal information about you in connection with our online and offline recruitment activities. It also explains the choices you have in relation to these processing activities.
“Recruiting Personal Information” means all information that relates to an identified individual or to an identifiable individual. For example, your name, address, email address, educational and employment background, CV or resume, and job qualifications.
This Privacy Policy applies to SunTracker’s processing of Recruiting Personal Information of job applicants and SunTracker’s recruiting activities more generally, conducted both offline, online and via third party websites.
SunTracker Technologies Ltd. and its affiliates are responsible for the processing of your Recruiting Personal Information as described in this Privacy Policy.
We process Recruiting Personal Information used to further SunTracker’s recruiting activities such as your name, address, email address, educational and employment background, CV or resume, and job qualifications.
We process Recruiting Personal Information that you provide directly such as when you submit a job application, or information you provide during an interview. We also receive Recruiting Personal Information from other sources, such as during references, background, or employment checks, and from third party recruitment sources.
We process Recruiting Personal Information that you provide directly to us, such as when you submit a job application on the sites or at a recruiting event, or when we conduct a phone or in-person interview. We may also receive Recruiting Personal Information about you from other sources, such as from persons you indicate as a reference, persons who referred you for a position, in connection with background or employment checks, and from third party recruitment sources, including third party sites.
SunTracker may process the following categories of Recruiting Personal Information for our recruitment activities as further described in Section 2 of this Privacy Policy:
~~ name and contact details;
~~ educational background;
~~ employment background;
~~ job qualifications and work eligibility, including your nationality, country of residence, and visa and immigration status;
~~ jobs in which you have expressed an interest or for which you would like to submit an application;
~~ CV, resume, or transcripts, and any supporting documentation attached to your CV or resume such as copies of certificates and diplomas;
~~ employment references;
~~ compensation information, such as your current salary;
~~ background check information, such as a verification of your educational and professional background, and other relevant information subject to SunTracker policies and applicable laws; and
~~ certain types of sensitive Recruiting Personal Information as described in Section 9 below.
2. WHY AND HOW DO WE USE YOUR RECRUITING PERSONAL INFORMATION?
We use Recruiting Personal Information for the following purposes:
(a) to communicate with you and respond to your requests or application
(b) for recruitment, evaluation and hiring purposes
(c) to analyse, develop and improve our recruiting activities and SunTracker products and services
(d) to maintain the security of the SunTracker Recruiting Cloud and our sites, systems and networks
(e) to comply with applicable laws and regulations and to operate our business.
These purposes are described below in further detail.
(a) To communicate with you and respond to your requests or application.
If you get in touch with us (for example, through SunTracker contact forms on the sites, contact with our recruiters or at events or social media platforms) we process information about you to communicate with you about your application or job interests. For example, we may update you on the status of your application, inform you about new vacancies or invite you for recruitment activities such as a phone screening or in-person interview.
(b) For recruitment, evaluation and hiring purposes.
We process information about you to connect the right job applicant with the right job at SunTracker and evaluate whether you are the right applicant for a position. We may therefore include information about you in our recruitment database to manage SunTracker’s candidate selection and recruiting processes. If you are selected for a position at SunTracker, information about you will also be used to facilitate the hiring process. Please be aware that, prior to hiring you and in order for SunTracker to be able to extend an offer to you, you may be requested to complete a background check.
(c) To analyze, develop and improve our recruiting activities and SunTracker products and services.
In order to analyze, develop and improve our recruiting activities and SunTracker products and services, SunTracker may process information about you, for example if you encountered any problems in using a site contact form or if it is not functioning as expected. We may also process information about you to develop and test new products or system versions, patches and updates.
(d) To maintain security.
We may use Recruiting Personal Information about you as necessary to maintain the security of the SunTracker sites, systems and networks. For example, we may process information about you when investigating suspicious activity on our sites, systems and networks.
(e) To comply with applicable laws and regulations and to operate our business.
In some cases, we may process information about you to comply with applicable laws and regulations, such as legally mandated reporting or other legal process requests. We may also process information about you in the performance and organization of our business and internal management, for example to conduct audits and investigations, for mergers and acquisitions, finance and accounting, archiving and insurance purposes and in the context of dispute resolution.
3. FOR EUROPEAN UNION (EU) RESIDENTS, WHAT IS OUR BASIS FOR PROCESSING?
For information about you collected from the EU/EEA, our basis for processing is the following:
~~ In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
~~ Your use of the SunTracker Recruiting Cloud and the processing of information about you for recruiting purposes is based on your consent. Please note that you can always close your account and withdraw your consent, although this may affect our ability to consider you for employment at SunTracker.
~~ Any processing of your sensitive Recruiting Personal Information in connection with your job application is based on your explicit consent. Please note that you can always close your application and withdraw your consent, although this may affect our ability to consider you for employment at SunTracker.
~~ The processing of information about you as part of our offline and online recruitment activities is based on our legitimate interest in finding the best person for a specific job.
~~ In case you were not selected for the position but we would like to contact you about future job opportunities that may be of interest to you, we may process the relevant contact and related information provided by you as part of your initial application, based on our legitimate interest to find the best possible candidate for the position.
~~ Our processing of information about you to analyze, develop and improve the SunTracker Recruiting Cloud, our sites and SunTracker products and services is based on our legitimate interest in enhancing the effectiveness, user experience and functioning of the SunTracker Recruiting Cloud, our sites and our products and services.
~~ Our processing of information about you for security purposes is based on our legitimate interest in protecting SunTracker systems and networks.
~~ Our processing of information about you for legal and regulatory purposes is based on a legal obligation or on SunTracker’s legitimate interest in complying with applicable laws and regulations.
~~ Our processing of information about you for business operations purposes is based on our legitimate interest in operating our business in an efficient and appropriate manner.
4. FOR HOW LONG DO WE RETAIN RECRUITING PERSONAL INFORMATION?
SunTracker will retain your Recruiting Personal Information related to your application for a position (such as your CV or resume or the position to which you applied) for up to seven (7) years from the date you applied (unless a longer or shorter period is required by applicable law).
To the extent permitted or required by law, SunTracker may delete your Recruiting Personal Information at any time. As a result, you should retain your own copy of any information you submit to us.
5. WHEN AND HOW CAN WE SHARE YOUR RECRUITING PERSONAL INFORMATION?
(a) Sharing within SunTracker
SunTracker employees are authorized to access Recruiting Personal Information only to the extent necessary to serve the applicable purpose and to perform their jobs.
(b) Sharing with third parties
Where necessary, we share Recruiting Personal Information with the third parties described below:
~ Third-party service providers (for example, website management, information technology and related infrastructure provision, background or employment check service providers, auditing, and other similar services) in order for those service providers to perform business functions on behalf of SunTracker.
~ Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
~ As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
~ When third parties are given access to your Recruiting Personal Information, we require them to abide by contractual, technical and organizational measures designed to ensure that your Recruiting Personal Information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.
6. HOW IS RECRUITING PERSONAL INFORMATION HANDLED GLOBALLY?
Recruiting Personal Information is transferred globally, with Recruiting Personal Information processed in Canada from global sources. Personal Information transferred to SunTracker is subject to the Personal Information Protection and Electronic Documents ActS.C. 2000, c. 5 (“PIPEDA”) and the Personal Information Protection ActSBC 2003 Ch. 63 (“PIPA”). Where PIPEDA and PIPA do not provide an adequate level of protection for Recruiting Personal Information, SunTracker will take reasonable measures to adequately protect Recruiting Personal Information.
7. HOW IS YOUR RECRUITING PERSONAL INFORMATION SECURED?
SunTracker has implemented appropriate technical, physical and organisational measures designed to protect your Recruiting Personal Information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.
8. WHAT ARE YOUR CHOICES?
For information about you collected in the EU/EEA or as otherwise required by law, you may request to exercise some or all of the following choices regarding how we process your Recruiting Personal Information.
~ Withdraw consent – You may request to withdraw the consent you have previously provided for the processing of your Recruiting Personal Information by contacting us at info@suntrackertech.com.
~ Change or correct Recruiting Personal Information – You can edit some of your Recruiting Personal Information in the SunTracker Recruiting Cloud. If you have any questions about this process, you may contact us at info@suntrackertech.com.
~ Object to, or limit or restrict use of Recruiting Personal Information – You can ask us to stop using all or some of your Recruiting Personal Information by contacting us at info@suntrackertech.com.
Right to access and/or take your data – To request access to all of your Recruiting Personal Information covered under this Privacy Policy, please contact info@suntrackertech.com.
9. DOES SUNTRACKER COLLECT SENSITIVE RECRUITING PERSONAL INFORMATION?
SunTracker does not request or require and asks that you do not send us any sensitive Recruiting Personal Information concerning racial or ethnic origin, religion or philosophical beliefs, health, sexual orientation, or political affiliation in connection with your job application and our recruiting efforts. To the extent information you do provide to us contains sensitive information, for example details of your racial or ethnic origin, political opinions or beliefs, religious beliefs, membership in a trade union or political party, physical or mental health or condition, sexual orientation, commission or alleged commission of an offense or related proceedings, job evaluations or educational records, you explicitly authorize SunTracker to process this Recruiting Personal Information as described in this Privacy Policy.
Additionally, if you have a disability and would like SunTracker to consider any accommodation, you may provide that information during the recruiting process. In accordance with applicable law, we may explicitly ask for information such as race or ethnicity for the purpose of monitoring equal opportunity. However, we do not require applicants to provide this information in connection with their job application and our recruiting efforts, and if you choose to provide this information as part of an equal opportunity program, it will not be viewable or otherwise used in the hiring or selection process.
10. WHAT ARE YOUR RESPONSIBILITIES?
You are responsible for the Recruiting Personal Information that you provide or make available to SunTracker, and you must ensure it is relevant, 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. Further, if you provide any Recruiting Personal Information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for SunTracker to collect and use that information as described in this Privacy Policy.
11. PRIVACY OFFICER
SunTracker has appointed a Privacy Officer. If you believe your Recruiting Personal Information has been used in a way that is not consistent with this Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please contact the Privacy Officer.
Written inquiries to the Privacy Officer may be addressed to:
SunTracker Technologies Ltd.
Privacy Officer
#501 – 747 Fort Street
Victoria, BC V8W 3E9
Canada
Email: privacy@suntrackertech.com
12. DISPUTE RESOLUTION OR FILING A COMPLAINT
If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with this Privacy Policy and in accordance with applicable law.
If you have an unresolved privacy or data use concern that you believe we have not addressed satisfactorily, you have the right to file a complaint with a competent data protection authority.
13. SUNTRACKER CORPORATE HEADQUARTERS
SunTracker’s corporate headquarters are located at:
#501 – Fort Street
Victoria, BC V8W 3E9
Canada
Tel: +1.778.433.7868