Applicant Privacy Notice
INTRODUCTION
This Privacy Notice for applicants and candidates (“Applicant Privacy Notice”) supplements and is expressly made part of the information contained in Validity’s Privacy Policy and applies solely to all applicants or candidates who have expressed their interest in joining Validity (“you”). A reference to “Validity,” “we,” or “us” is a reference to Validity, Inc.
This Applicant Privacy Notice applies to Validity’s processing of personal information that we collect online and offline for the purpose of recruiting you.
This Applicant Privacy Notice explains what information Validity collects during our application and recruitment process and how it is used. Furthermore, this notice includes information on privacy rights and how to exercise them.
INFORMATION WE COLLECT AND HOW WE USE IT
We may collect the personal information described below from you in connection with the Validity application and recruitment process. The information collected will depend on your stage in the process. The sensitive or special categories of personal data (as pointed out in the table below) that we may collect are only processed when applicable laws require or permit.
In cases where Validity is required to collect your personal data under applicable laws, the provision of such personal information is mandatory. Failure to provide such information to us may impact our ability to consider you for employment with us.
The table below demonstrates what personal information may be collected from you during the different stages of the recruitment process with Validity.
| Categories | Personal Data Elements | Purpose for Processing |
| Personal Identifiers |
a. name, home address (voluntary), phone number, email address; b. work authorization status. |
a. communicating with you for the purpose of recruitment/application processing; reimbursements for any agreed expenses incurred by you during the recruitment process with Validity; secure access to our systems and offices. b. complying with legal and regulatory obligations (including verifying that you are legally permitted to work in the country to where you are applying); conducting background checks (where applicable, and in accordance with the applicable law). |
| Protected Classifications (under applicable law) | c. race, gender, ethnic origin, veteran and military service, and disability status (all provided on a voluntary basis), COVID immunization status. | c. complying with our legal and regulatory obligations under applicable law; submitting hiring statistics and practices to relevant regulatory authorities (where required and in accordance with applicable law, for example in compliance with equal opportunity employment or health and safety laws). |
| Professional- or Employment-Related Information | d. resume/curriculum vitae (CV), employment history, education history, qualifications and skills, willingness to relocate, desired salary, and background screening information (as applicable) | d. evaluating your submission for a relevant job opening; reviewing your qualifications and references and making hiring decisions; preparing on-boarding materials and relocation (as applicable); conducting background checks (as applicable and in accordance with applicable law). |
| Education Information | e. education history, qualifications and skills, level of education and degrees obtained. | e. evaluating your submission for a relevant job opening; reviewing your qualifications and references and making hiring decisions. |
| Other personal information | g. professional social media account page (for example, LinkedIn) if available | g. evaluating your submission for a relevant job opening; reviewing your qualifications and references and making hiring decisions. |
In addition to the purposes mentioned in the table above, we may process your personal information for our legitimate interests such as: (i) resolving disputes and/or as a part of a legal action, (ii) keeping records related to Validity’s hiring practices for analytics and to improve our future recruitment activities; (iii) responding to a warrant, subpoena, or other valid legal process; and (iv) administrating IT security and secure access to our systems and office locations.
HOW WE COLLECT YOUR INFORMATION
The personal information mentioned above is generally collected through our application and recruitment process and may come from employment agencies and references but, in most cases, comes directly from you. When shared with us, we may also collect additional information from our service providers, such as background verification agencies or screening services, or from your previous employers and your professional social media accounts (for example, LinkedIn). In any instance, such collection will be performed pursuant to applicable laws and regulations (which may differ based on the relevant jurisdiction).
HOW WE MAY DISCLOSE PERSONAL INFORMATION
The security and privacy of your information are important to us, and we take this responsibility very seriously. Access to your personal information is allowed only to Validity’s employees and authorized contractors who need to know the specific information in question to carry out their responsibilities regarding Validity recruitment and hiring or compliance with applicable law. For example, our HR team will need to see the details above to administer the recruiting process, or a hiring manager will review your resume.
In some instances, as permitted or required by applicable law, you will be asked to submit your information to companies providing services under contract to Validity as part of the recruitment process, such as background checks.
Your personal information may also be shared with government authorities and law enforcement officials if such disclosure is mandated by law or if required to protect Validity’s legitimate interests in compliance with applicable laws.
In some cases, Validity may buy or sell assets or businesses. In these types of transactions, your information may be one of the transferred business assets. Validity may disclose personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets.
WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION (NO SALE/SHARE)
Validity does not “sell” (as defined by applicable laws, including by California laws) the personal information covered by this Applicant Privacy Notice. We also do not “share” your personal information covered by this Applicant Privacy Notice for the purposes of cross-context behavioral advertising, as defined under applicable laws. Furthermore, Validity doesn’t use or disclose your sensitive personal information for any purposes other than those that are specified in section 7027, subsection (m) of the CPRA.
DATA RETENTION
We will retain the personal information we collect where Validity has an ongoing legitimate business reason to do so (for example, considering for future open roles or to comply with applicable employment laws). When we have no ongoing legitimate business need to process your personal information, we will delete or de-identify it. In instances where you become an employee of Validity, the personal information you provided during the application process with us may be added to your employee file to administer the employment relationship with you. You will be referred to internal policies for further information in those cases. Please refer to YOUR PRIVACY RIGHTS AND CHOICES section of this Applicant Privacy Notice.
HOW WE SECURE PERSONAL INFORMATION
Validity has implemented appropriate organizational, technical, and administrative measures to protect personal information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your personal data from loss, misuse, interference, unauthorized access, modification, and disclosure, you should be aware that no security procedures or protocols are ever guaranteed to be 100% secure from intrusion or hacking, and there is therefore always some risk assumed by sharing personal information online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your application account has been compromised), please notify us immediately at [email protected].
INTERNATIONAL TRANSFERS
Your personal information may be stored and processed in any country (including the United States) where we have facilities or in which we engage service providers, and, by disclosing information to us, you consent to the transfer of information to countries outside of your country of residence (which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information). Validity will take steps to ensure that your personal information is subject to appropriate safeguards, including, where required, by implementing appropriate transfer mechanisms such as the European Commission’s adequacy decisions or standard contractual clauses (as amended and approved) for the transfer of personal information to third countries, supported by appropriate technical and organizational measures. For additional information regarding the mechanism under which your personal information is transferred internationally, you may contact us at [email protected].
YOUR PRIVACY RIGHTS AND CHOICES
Your privacy rights may differ based on the relevant jurisdiction’s applicable privacy and employment laws. Below is the general list of privacy rights that are common for current regulations and laws, where enacted. As mentioned above, those may differ; however, Validity will comply with submitted requests per corresponding regulatory frameworks, including regulations specific to the European Economic Area, the United Kingdom, and California.
In summary, you may have the right to request that Validity:
- provide you with information regarding whether we process your data, including any details related to such processing;
- correct any inaccurate data we may have about you;
- complete any incomplete information that we may have about you;
- under certain circumstances, erase your personal information;
- under certain circumstances, cease or be restricted from processing your data;
- under certain circumstances, furnish you with the personal data which you provide us within a structured, commonly used, and machine-readable format;
You may also:
- object to how your personal data is used in automated decision-making, if applicable;
- lodge a complaint with a supervisory authority (regulatory agency);
- direct us to stop selling or sharing your personal information with third parties (please see above section NO SALE/SHARE);
- under certain circumstances, limit how your sensitive personal information is used and disclosed (please see above section NO SALE/SHARE);
- receive non-discriminatory treatment by Validity in the event you exercise your privacy rights.
EXERCISING YOUR PRIVACY RIGHTS
We will respond to your requests to exercise your privacy rights following the requirements of applicable data protection laws, including the timing for the responses. Please note that we take the security and privacy of your data very seriously, and, in order to fulfill your request, we may need you to provide certain personal data to verify your identity. When submitting your request, please specify your full name, email address, country, and the details of your engagement with Validity (for example, if you are a past applicant). Your request must include sufficient details that allow us to verify your identity, understand, evaluate, and respond to it properly and safely.
We may use the following methods to verify your identity: email validation, mobile number validation, fact-based questions, or in-person or remote document identity verification.
Based on applicable data protection and privacy laws, individuals may also designate an authorized agent to exercise these rights on their behalf. In those instances, we may ask you directly to confirm the designation of the authorized agent with us.
Please note that only you, or an authorized agent (where permitted by law), may make a privacy rights request related to your personal information.
To exercise the privacy rights that apply to you, please submit your request to us by sending an email to [email protected] or by phone: (800) 961-8205 (US toll-free).
APPLICANT PRIVACY NOTICE UPDATES
Validity reserves the right to amend this Applicant Privacy Notice at our discretion and at any time. When we make changes to this notice, we will post it on our website and update the notice’s last updated date.
CONTACTING US
We welcome any questions, comments, or concerns you may have regarding this Applicant Privacy Notice. Please do not hesitate to contact us as follows:
email: [email protected]
phone: 1-800-961-8205 (US toll-free)
mail: Attn: Privacy
Validity, Inc.
100 Summer Street, Suite 2900
Boston, Massachusetts 02110
United States
Effective Date: March 2024