Privacy Policy for Recruiting at HA International LLC

Introduction

This Privacy Policy for Recruiting ("Policy") is adopted by HA International LLC ("Company", "we", "us", or "our") and applies to all individuals applying for positions within our organization ("Applicants", "you", or "your"). The purpose of this Policy is to inform you about how we collect, use, disclose, and protect the personal information of our Applicants during our recruitment process.


We are committed to ensuring that your privacy is protected and that your personal information is handled in a manner that complies with applicable data protection laws and regulations. By submitting your personal information to us, you acknowledge that you have read, understood, and agree to the practices described in this Policy.

What personal data we collect

In accordance with this Policy, the Company collects various types of personal data from Applicants during the recruitment process. This data is essential for assessing Applicants' suitability for positions within the Company and includes, but is not limited to, the following:

  • Contact details, including name, email address, phone number, and mailing address.
  • Resume/CV and cover letter.
  • Employment and education history.
  • References and background information, including feedback from previous employers.
  • Interview notes and assessments made during the recruitment process.
  • Documentation verifying work eligibility.

This data is collected directly from Applicants and, where necessary, from third parties such as previous employers or reference providers, with the Applicant's consent.

How we use your personal data

In accordance with this Policy, the Company processes personal data of Applicants for the following purposes:

  • To assess your suitability for employment within the Company;
  • To contact you regarding your application for employment;
  • To conduct interviews and evaluations as part of the recruitment process;
  • To carry out background or reference checks, as permitted by applicable law;
  • To comply with legal or regulatory requirements relevant to the recruitment process.

Data sharing and disclosure

In accordance with this Policy, the Company may share the personal information of Applicants with internal parties, including but not limited to, members of our Human Resources (HR) team, hiring managers, and interviewers involved in the recruitment process. Such sharing is limited to the extent necessary for the purposes of evaluating Applicants for employment.

Furthermore, the Company may disclose Applicants' personal information to third-party service providers, such as background check vendors or applicant tracking systems, strictly for recruitment purposes. These third parties are engaged by the Company to perform functions on its behalf related to the recruitment process and are obligated to handle personal information in accordance with the Company's directives and applicable laws.

Data retention

In accordance with this Policy, the Company will retain the personal data of Applicants for a period of up to 12 months following the conclusion of the recruitment process. This retention period is designed to allow the Company to consider Applicants for future employment opportunities and to fulfill any legal or regulatory obligations. Should an Applicant be successful and subsequently hired, their personal data will be transferred to their employee record and retained in accordance with the Company's employee data retention policies.

 

After the expiration of the 12-month period, unless a longer retention period is required or permitted by applicable law, the Company will take steps to securely delete or anonymize Applicant data. The Company may engage third-party service providers to assist in the deletion or anonymization process, ensuring that all such third parties adhere to confidentiality and data protection standards consistent with this Policy and applicable data protection laws.

Applicants may contact the Human Resources (HR) team at any time to request information about the retention of their personal data or to object to the retention of their data for specific purposes.

Your rights

Under the Policy, Applicants have specific rights regarding their personal data that the Company collects and processes. These rights include the ability to:

  • Request access to the personal data that the Company holds about you;
  • Correct or update any inaccurate or incomplete personal data;
  • Request the deletion of your personal data where it is no longer necessary for the Company to retain it, subject to applicable legal and regulatory requirements;
  • Object to the processing of your personal data in certain circumstances, including for marketing purposes;
  • Request the restriction of processing your personal data in certain circumstances, such as while the Company assesses a request for correction or as an alternative to deletion;
  • Request the portability of your personal data to another data controller, where technically feasible;
  • Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, or if you have any questions about your personal data under this Policy, please contact the Company's Human Resources (HR) team at hr.usa@ha-group.com. Please note that the Company may require you to verify your identity before proceeding with your request.

 

In certain jurisdictions, you may also have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates applicable data protection laws.

Data security

In accordance with our commitment to protect the privacy and security of personal data, HA International LLC ("the Company") implements comprehensive technical and organizational measures. These measures are designed to safeguard the personal data of Applicants from unauthorized access, loss, misuse, alteration, or destruction. Our security protocols include, but are not limited to, encryption, access control, secure data storage, and regular security assessments.


The Company ensures that all Human Resources (HR) team members who have access to personal data are trained on the importance of data security and are bound by confidentiality agreements. Additionally, we require our third-party service providers to adhere to similar standards of data protection and confidentiality.


In the event of a data breach, the Company will promptly take appropriate steps to mitigate any potential harm and will communicate with affected Applicants in accordance with applicable laws and regulations. The Data Subject Rights are respected and facilitated by the Company, ensuring Applicants can exercise their rights effectively.

International data transfers

The Company acknowledges that in the course of recruiting, it may be necessary to transfer personal data of Applicants to countries outside the European Economic Area (EEA) or other regions with comprehensive data protection laws. Such transfers will be carried out in compliance with applicable legal requirements to ensure the protection of the personal data of Applicants.

To safeguard Applicants' personal data during such transfers, the Company will:

  1. Assess the data protection measures of the      recipient country or territory to ensure they provide an adequate level of      protection for personal data, comparable to that which is provided within      the EEA or under relevant data protection laws.
  2. Utilize standard contractual clauses      approved by the European Commission or rely on other legal mechanisms      recognized as providing an adequate level of data protection.
  3. Implement appropriate security measures,      such as encryption and access control, to protect personal data during the      transfer process.
  4. Ensure that personal data is transferred      only to third-party service providers who have demonstrated compliance      with high data protection standards and who have agreed to contractual      obligations to protect the data.

In cases where the Company transfers personal data to a third-party service provider outside the EEA or other regions with comprehensive data protection laws, it will take all reasonable steps to ensure that the data is treated securely and in accordance with this Policy. Applicants have the right to obtain details of the transfer mechanism used by the Company by contacting the Human Resources (HR) team.

Updates to this policy

The Company reserves the right to update or modify this Policy at any time and from time to time without prior notice. Please review this Policy periodically, and especially before you provide any personal data. This Policy was last updated on the date indicated at the end of this document. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on the Company's website. However, the Company will use your personal data in a manner consistent with the Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.


We also encourage you to review our Policy regularly to stay informed about how we are protecting the personal data we collect. Your continued participation in our recruitment process or use of our services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy.

Contact information

If you have any questions or concerns regarding the processing of your personal data under this Policy, or if you wish to exercise any of your Data Subject Rights, please contact our Human Resources (HR) team directly. The HR team is responsible for overseeing and managing data protection queries and requests from Applicants and ensuring compliance with data protection laws and regulations.

To contact the HR team, you may use the following details:

  • Email: hr.usa@ha-group.com
  • Phone: +1 (630) 575-5766
  • Postal Address: HA International LLC, 630      Oakmont Lane, Westmont, IL 60559

In the event of a data breach or other urgent data protection issue, please use the provided contact details to report the incident immediately to the Company. The HR team, in collaboration with our third-party service providers, will take appropriate steps to address the issue, including notifying affected individuals and relevant authorities as required by law.