University Physicians’ Association, Inc. (UPA)

Notice of Privacy Practices for Job Applicants & Onboarding Process

We use the term "Personal Information" (also called "personal data" or "personally identifiable information" in the laws of some jurisdictions) to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been de–identified, anonymized, or aggregated, or that otherwise cannot reasonably be related back to a specific person is not considered Personal Information. The precise definition of Personal Information may vary depending on your state of residence, but we take the same approach to protecting your privacy.


   This Notice of Privacy Practices (“Applicant Notice”) explains our privacy practices and how we handle Personal Information related to you as a job applicant and during the onboarding process. Our privacy practices related to our employees (including successful job applications) are governed by our employee privacy policies and not this Notice. We respect the privacy rights of individuals and are committed to handling Personal Data responsibly and in accordance with applicable law. This Notice sets out the Personal Data that we collect and process about you, and the purposes of the processing.

Information We Collect

When applying for a job and during the onboarding process, we may collect certain information from and about you in order to evaluate and process the application.
 

The types of Personal Information we may process include, but are not limited to:

· Identification data – such as your name and last name.

· Contact details – such as address, telephone, and email addresses.

· Employment details – such as job title/position, office location, employment contract (if applicable).

· Background information – such as academic/professional qualifications, education, CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law).

· Government identifiers – such as government issued ID/passport.

· Financial information such as current salary.

· IT information – information required to provide access to company systems and networks (and information collected by / through those systems) such as IP addresses, log files and login information.
 

We may also process sensitive Personal Information relating to you. This may include but are not limited to government identifiers (i.e. dates of birth, social security, driver's license, state identification card, or passport number), citizenship or immigration status, emergency contact information, and precise geolocation data. Information that reveals your racial or ethnic origin, sexual orientation, criminal convictions and offenses, biometric data for the purposes of unique identification, and information about your health. As a general rule, we try not to collect or process any sensitive Personal Information about you, unless the information is needed for the purpose of onboarding or authorized by law or where necessary to comply with applicable laws or to provide benefits. We do not sell sensitive Personal Information collected under this Notice.
 

How We Use Information

The information submitted during a job application and onboarding process may be used for personnel recruitment, management, and planning purposes including the following:

· Analyzing your qualifications for the job you applied for or future jobs that may match your profile;

· Communicating with you regarding your job application, your inquiries and requests, other job openings, or important notices;

· Conducting criminal history, background, and employment checks, if we offer you a position;

· Supporting our efforts to maintain a diverse workforce; and

· Complying with or monitoring our compliance with any applicable law or regulation.

We may use and share information in an aggregated or de-identified manner at our discretion, including for analysis, marketing, and/or the improvement of our processes.
 

Accuracy of Information You Provide

You are responsible for the information you provide to UPA, ensuring that it is honest, truthful, accurate, and not misleading in any way.

 

How We Share Your Information

Vendors and Service Providers. We may share your information with vendors and service providers that we believe need the information to perform a technology, business, or other professional function for us, including providing products or services to you or our clients on our behalf, creating or maintaining databases, preparing and distributing communications, or responding to inquiries.


Affiliates. We may share your information with companies that we own or control, that are owned or controlled by us, or that are under common ownership or control for legitimate business purposes.

Business Transition. If UPA, or any portion of our assets, are acquired by, merged with, transferred to, or invested in by another company, we may share your personal information with that company or other third parties involved in the business transition. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this notice.

Legal. We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law, and without your consent when it is necessary to protect our clients, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.

Retention and Disposal

We retain information as long as necessary to fulfill the purposes for which we collected it, for legitimate business reasons, or as required by law. Generally this means your Personal Information will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries, comply with regulatory obligations, or to deal with any legal matters, document the proper deductions during and on termination of your employment or work relationship (e.g. to tax authorities), or to provide you certain benefits. When we dispose of information, we use secure means, such as either physically or electronically erasing information or making it anonymous in a non-recoverable manner.


Security

We implement the appropriate organizational, technical, and physical security measures and controls to protect the confidentiality, integrity, and availability of the personal information entrusted to us. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, for example you feel that the security of any account you might have with us has been compromised, please immediately notify us of the problem by contacting us at upahumanresources@utmck.edu.

Changes to Job Applicant Notice

We reserve the right to modify, alter, or update the terms and conditions of this notice from time to time without prior notice. We will post these changes in addition to changing the “Last Updated” date at the bottom of this notice. Modifications shall become effective immediately upon being posted.

Contact Us

If you have any questions about this notice or our information handling practices, please contact us at upahumanresources@utmck.edu.