RECRUITING PRIVACY POLICY
 

PURPOSE 

BinkleyBarfield | DCCM, Baseline | DCCM and Shine | DCCM (the “Company”) is committed to protecting the privacy of applicants. In this Privacy Policy, we describe how we collect, use, disclose, and retain candidates’ personal information. We also outline our approach to sharing information with third parties with whom we coordinate to verify qualifications and facilitate the hiring process. Furthermore, the policy explains the legal basis under which we process this personal information, ensuring compliance with local laws and regulations that govern data protection and privacy.


 

POLICY

Personal Information We Collect

The Company collects your personal information in connection with the application and recruitment process in a variety of ways, including data contained in or gathered from applications, CVs or résumés, public social media sites, assessments, interviews, and third parties (ex: recruitment agencies). The information the Company collects from you and these sources include, but is not limited, to the following:
 

· Your full legal name, contact information (address, email, telephone number), and demographic data (data of birth, gender, and government identification data).

· Details in your CV or résumé (including your educational background, work history, and other qualifications)

· Employment objectives, skills and certifications, memberships, and community involvement

· Results of any assessment, survey, or questionnaire you complete and information you provide during an interview.

· Job performance, professional reputation, references, and financial details to coordinate and reimburse for travel.

· Details regarding any accommodation requests you make throughout the recruitment process.

· Details of your ability to work in certain areas (including citizenship, work permits, and right to work status)

· Educational, criminal, and financial background checks for certain roles were permissible by local law.

· Relevant social media profiles (e.g., LinkedIn)

· Any other personal information you choose to submit as part of your application.


 

Background Checks and MVR Reports

Background checks and MVRs may involve third parties contacting you to gather information. You are under no obligation to provide personal information to the Company during the recruitment process. It is important that you do not share sensitive personal information that is unnecessary for your application. 

If, however, you fail to provide information as requested, we may not be able to process your application further or continue the recruitment process. If you provide us with details about references or previous employers, please ensure that you have obtained their consent to process their data and for us to contact them.

How We Use Personal Information

The Company uses your personal information in the following ways:

· Manage the recruitment process and assess you for a position.

· Communicate with you about the recruitment process.

· Monitor and improve our recruiting and hiring processes.

· Comply with legal or regulatory requirements.

· In connection with regulatory inquiries, audits, legal claims, subpoenas, warrants, or other government/judicial processes or requests

Your personal information may be shared internally for recruitment purposes with Human Resources and recruitment teams, department managers, and the IT Department solely for pre-hiring and onboarding activities. This information will be stored within our applicant tracking system in Paylocity. 

We will protect such personal data through internal controls and policies, and reasonable security measures for protecting your personal data from being lost, accidentally destroyed, misused, or subject to unauthorized access.

Legal Basis for Processing

We collect and process your information solely to facilitate the necessary steps prior to entering into a potential employment contract with you.  We may also seek your consent to process your personal information in specific circumstances or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. 

If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.

Sensitive Personal Information

The Company can process sensitive personal information, such as demographic data, if you provide it and if collection is allowed in your jurisdiction. This data may be processed to ensure meaningful equal opportunity monitoring and reporting or to provide appropriate accommodations if needed during the recruiting process. 

Accessibility of Data Subjects with Disabilities

If you cannot access this privacy notice due to a disability, contact the HR Department for an alternative format. You may also have your authorized representative make the request.

Disclosure of Personal Information

We share personal information with our other operating companies under DCCM, our parent company, in connection with your application and in accordance with the conditions of this Privacy Policy. A list of such offices and affiliates is available upon request. We share personal information with third-party providers like auditors, and IT services solely for recruitment purposes. These services will access your personal information only to perform their necessary functions. They are not permitted to use the data for other purposes. We reserve the right to disclose personal information where we believe such disclosure is required by law or is appropriate in connection with any legal claims (actual or proposed litigation), subpoenas, warrants, or other government/regulatory/judicial processes or requests, as well as to protect visitors or the Company (people and property) and other rights or interests, or to comply with applicable law.

Security of Personal Information

The Company maintains what it considers to be reasonable and appropriate technical and organizational measures designed to protect personal information from accidental loss, misuse, and unauthorized or unlawful access or processing, disclosure, alteration, and destruction.

To the extent that we disclose personal information to clients or third-party service providers, we require that such third parties also maintain reasonable security and confidentiality measures and use the personal information in accordance with our instructions and applicable law. We have security measures in place designed to protect our user database, and access to this database is restricted internally.

Data Subject Rights

The Company wishes to maintain personal information that is accurate, current, and complete. If the personal information that you previously presented has changed, please submit your current information. In certain states, you may have rights under data protection law. This may include the right to request, access, delete, and/or update your information.

Your Personal Data Privacy Rights

In accordance with the applicable personal data protection law, you have rights as an applicant, including the following: 


 

· You have the right to request access to your personal data that we have file for you. You have the right to be informed about the collection and use by the Company, and request copies of your personal data. 

· You have the right to request us to cease processing your personal data. You have the right to request the restriction of our processing of your personal data, but this right may be subject to exemptions based on applicable laws. 

· You have the right to request us to delete your personal data from our applicant tracking system. You have the right to request that your personal data be deleted by us, but this right may be subject to exemptions based on applicable laws. 

· You have the right to request us to change any incorrect or incomplete personal data we have on file for you. You have the right to request inaccurate or outdated personal information of yours which we process be updated or corrected. 

· You have the right to request the transfer of your personal data to another party. You have the right to ask for your personal data to be transferred to another controller or provided to them in a machine-readable electronic format. 


 

The Company will not discriminate against you for exercising your data rights. If you have consented to the use of your personal data by the Company, you have the right to withdraw such consent. Note that by withdrawing your consent, it does not affect the right of the Company to process your personal data based on your consent prior to your withdrawal request. 

If you would like to exercise any of these rights, or have questions on the private privacy notice, please contact the HR Department at bbi.hr@dccm.com.


 

Data Retention

Your personal data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Privacy Statement or as otherwise required by applicable law. The Company may retain your data longer with your consent or for a legitimate business interest where we have assessed the business benefit and confirmed that this is not outweighed by your personal rights and freedoms.


 

Contact

If you have any questions about this Privacy Policy or how we manage your personal information, please contact our HR Department at bbi.hr@dccm.com. Alternatively, you may call our central office phone number, 713-869-3433 and ask to speak with a representative in the HR Department. 


 

Policy Updates

The Company may occasionally update this Recruitment Privacy Policy. When we do so, the revised date will be noted for applicants and candidates to reference the changes. We encourage you to check back periodically to stay informed of the latest version.


 

Effective Date: June 27th, 2025