Cognizant Careers Portal Privacy Policy ( Policy ) Date: 22 March 2017 Introduction This Careers Portal Privacy Policy ("Policy") applies to the Careers portal on the Cognizant website accessed via www.cognizant.com/careers ("Site"), which is owned and controlled by Cognizant Technology Solutions U.S. Corporation and its affiliates ("Cognizant", "we") and hosted by Taleo Corporation. For the purposes of this Policy, "Cognizant Affiliate" means any other company within the Cognizant global group of companies. The Cognizant Affiliate in your jurisdiction to whom you submit your application is the data controller. The Cognizant Global Associate Privacy Notice ( APN ) is also applicable to the use of this Site and its services. The APN provides general information about how Cognizant uses the personal information of prospective, current and past employees and contractors, whilst this Policy informs individuals specifically about the collection and use of their personal information via this Site. Please read the APN, as well as this Policy, before using the Site. You will find the link to the document at the following: https://www.cognizant.com/careers_resources/cognizant_associate_privacy_notice_english.pdf By clicking the "Accept" button during registration, you explicitly accept, without any qualification, the collection, processing, use and transfer of all Your Data (as defined below), in the manner described in this Policy. You should read this Policy carefully as it affects your legal rights and liabilities. If you do not wish to accept the terms of this Policy you must not use the Site. You also confirm that you are at least 18 years of age. If you are an agency submitting information on behalf of a candidate, you confirm that you have ensured that the candidate has been provided with and has read this Policy and the APN and has agreed to your continued use of this Site on their behalf. In such circumstances, references to "you" and "yours" in this statement are references to the candidate. Collection of Personal Data When you visit the Site we may collect the following general types of information about you: Personal Data When you apply for a job on this Site, this consists of information that can be used to identify you, or other individuals directly or indirectly, such as: - Name - Address and post code - Email address - Telephone number - Other contact information 1
- CVs (including but not limited to employment history, academic qualifications, professional qualifications). Your CV must not contain Sensitive Personal Data (see below) or any social security number or national identification number. If your CV does contain Sensitive Personal Data or any such number, then we will delete it and ask you to send us back your CV without such information. - Nationality - Personal Data submitted or generated as a result of assessments undertaken via the Site Should you be successful for a role, we would then ask you to provide the following information: - Information about third parties, such as references or contacts that you provide to us. You are responsible for ensuring that you have permission to submit any such information and that such individuals are aware that their information will be available to Cognizant or its clients for the purposes of taking up references. You may also be subject to fraud prevention database checks, where justified by the particular role you are applying to and subject to the applicable laws of the country you are located in. No such checks will be undertaken without your express prior consent. Should these checks identify fraud or the commission of any other criminal offence by you, subject to applicable law, we may record the details of this on the relevant fraud prevention databases in accordance with the applicable laws of the country you are located in. The information contained in fraud prevention databases may be accessed from other countries and used by law enforcement agencies and other organisations to prevent fraud. Please contact us at TAGSSEurope@cognizant.com if you want to receive details of the fraud prevention databases through which we share information. Sensitive Personal Data - This is Personal Data consisting of information as to racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs, membership of a trade union, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. We do not require you to provide any Sensitive Personal Data during the recruitment process. Nonetheless, should you be successful for a role, we may then ask you to provide some Sensitive Personal Data and/or identification numbers to enable us to comply with legal requirements at a national level (e.g. in relation to equal opportunities legislation). We will not collect and process your Sensitive Personal Data without your prior consent and, once obtained, you agree that we may disclose this information to prospective employers and clients in connection with the recruitment processes and for the purposes described below under the heading "Disclosure of Information" in accordance with applicable laws. Aggregated information - This is information that is aggregated and therefore not uniquely personal to you, but which refers to selected population or geographic characteristics, age, gender, occupation, preferences, and interests in accordance with applicable laws. Behavioural information - In order to prevent fraud, identify and deal with technical problems, and manage our services and resources we collect information regarding how you use our Site, which types of services you access and which areas of our Site you visit, information about your hardware and 2
software including your IP address, geolocation, browser and operating system type, domain names, and access times. For more information on our use of cookies and how we collect information on this Site, please read our Cookies Policy at https://www.cognizant.com/cookiepolicy. Purposes and legal basis for processing your Personal Data Where required, we will process your Personal Data with your prior consent. You may withdraw your consent at any time, which does not affect the lawfulness of the processing that has taken place before such withdrawal. Where consent is not legally required, we will process your Personal Data as required to comply with applicable laws or to pursue our legitimate interests. We will process your Personal Data (including, without limitation and where permitted, your Sensitive Personal Data) for the purpose of our recruitment processes and services, and associated administration, responding to your queries, or operating and improving the Site. We may access, retrieve, process and store your Personal Data and transmit or make it available online to prospective employers and clients. We may post information about vacancies and placements onto the Site and/or send it to applicants and candidates. We may collect and aggregate data from your Personal Data to enable us to monitor and improve our services. We may also share aggregated information with selected third parties, without disclosing individual names or personal identifying information. By registering with us, by managing your Personal Data or individual profile on the Site or specifically opting in where we request you to do so, you consent to us processing the Personal Data you have submitted at any time (including, without limitation and where permitted, your Sensitive Personal Data) in any of the ways and for any of the purposes described in this Policy (in each case in accordance with applicable laws). Should you be successful for a role, we will carry out certain background checks on you, where justified by the particular role you are applying to and where permitted by the laws of the country in which you are located, for example to verify your qualifications, education and employment history or for fraud prevention purposes. No such checks will be undertaken without your prior express consent. You consent to us informing prospective employers and clients about the status and completion of your background checks. We may also use your Personal Data (including without limitation and where permitted your Sensitive Personal Data), for any of the following purposes, subject to applicable law: - to allow you to set up and maintain an account or registration; - to create and maintain your online profile; - to enable you to contact us and enable us to respond and provide feedback; - to contact you about security and other updates to the Site, to provide you with services and other communications and information including newsletters and career information and advice; - to inform you of products or services available from Cognizant; - to conduct questionnaires/surveys, promotions and contests; 3
- to provide information about you and your potential interest in job vacancies to prospective employers and to provide products and services to employers in connection with the recruitment process; - to provide searchable CV databases and other products and services that enable users to network, post information on bulletin boards, view and compare profiles, and career background and experience; - to generate internal reports about the use of the Site. Disclosure of your Personal Data We may disclose your Personal Data, as required and in accordance with applicable laws, to the following parties: Third party service providers: We use a third party service provider (namely Taleo Corporation) who is located outside the European Economic Area to assist us in managing our Site and who may have access to your Personal Data. In addition, your Personal Data may be transmitted to a service provider to perform background checks (where permitted by applicable laws). The service provider may contact you to collect further information necessary to carry out the background checks. Your Personal Data may also be shared with other third party service providers who have been retained to provide services on behalf of Cognizant, such as for the storage of data or the maintenance of our Site. Cognizant affiliates: Your Personal Data may be shared with other affiliates of the Cognizant group of companies outside the European Economic Area and may be stored by Cognizant Technology Solutions Corporation, a US based company. Other third parties: If you post information in publicly accessible areas of the Site or in the searchable CV database, that information will be visible to and may be accessed, used, and stored by third parties who are not members of the Cognizant group of entities. We cannot control the use or privacy of CVs or other publicly accessible information that have been downloaded by third parties controllers (including without limitation any such information posted by you in chat rooms or online forums) who are accessing your Personal Data for their own use.recruiters: If you apply for a job via the Site, your CV will be available to the relevant employer, who may retain a copy of it. We cannot control their use and retention of your CV information. If needed, they will transmit your CV to clients for project-related purposes. Potential mergers or acquisitions: Following an acquisition of any or all of Cognizant s business operations, whether by way of acquisition of shares or stock, merger, consolidation or asset purchase and regardless of any possible new company name, we will continue to process and use your personal data in the same way. Insolvency proceedings: If Cognizant becomes the subject of insolvency proceedings, whether voluntary or involuntary, Cognizant or its liquidator, administrator, receiver or administrative receiver or similar officer may sell, license or otherwise dispose of your personal data in a transaction approved by the court of competent jurisdiction. We will notify you of any relevant sale of our business operations by a posting on the Site or via email. Public bodies and authorities: We will disclose all or any part of your Personal Data if required to do so by law, or at our discretion pursuant to a request from a governmental or regulatory entity/body or if we believe in good faith that such disclosure is necessary to (1) comply with legal or regulatory requirements or for the purposes of compliance with legal process; (2) prevent crime; (3) prevent any terrorist activity or threat to national security; (4) protect the personal safety or wellbeing of users of the Site or any other person. 4
Your rights We retain all the Personal Data we gather about you in accordance with applicable laws. Logging in to your account allows you to access or modify your profile or CV at any time. You may access and request a copy of your Personal Data or request the rectification or erasure of your Personal Data, or the restriction of processing of your Personal Data in accordance with and subject to applicable data protection laws ("Information Access Request"). If you wish to make an Information Access Request, please contact us at ChireSupportEurope2@cognizant.com. Before carrying out any such request, we reserve the right to verify and authenticate your identity and the information in respect of which you have requested access, rectification, erasure or restriction of processing. We will respond to Information Access Requests without undue delay and in any event within one month of receipt of the request (or earlier, if required by applicable law). If we require additional time to provide access to your information, we will acknowledge receipt of your request within 14 days (or earlier if required by applicable law) and promptly provide a supplementary response in accordance with the timescales required under applicable law. Access, rectification, erasure or restriction of processing of all or part of your Personal Data may be denied or limited by Cognizant if it would violate another person's rights and/or as otherwise permitted by applicable law. If you wish to delete or close your account or account profile information altogether, please contact us at ChireSupportEurope2@cognizant.com. We will confirm by email that your Personal Data has been deleted. We reserve the right to retain an archival copy of your Personal Data for a maximum period of 3 months after receiving your request for deletion or closure of your account. If any part of your Personal Data was accessed by third parties using the Site because you have posted it in the publicly accessible areas of the Site or in the searchable CV database, we shall take reasonable steps, taking account of available technology and the cost of implementation, including technical measures, to inform those third parties which are processing your Personal Data that you have requested the erasure of any links to, or copy or replication of, your Personal Data. If you are dissatisfied with the way we process your Personal Data, you have the right to lodge a complaint with the national data protection authority of the country in which you are located. Retention of Personal Data We will store your Personal Data for a period of 12 months from the date you submitted it. If you do not log into your account for a continuous period of 12 months or more, we reserve the right to close your account. We will send you a warning by email prior to closing your account. Deletion of closed account will include the deletion of all applicable account information, including contact details and CVs. Security of Information While Cognizant takes measures to safeguard your Personal Data from unauthorized access or misuse by third parties, Cognizant does not have control over these third parties and we are not responsible for their use of any of your Personal Data which is posted to or otherwise made available in public areas of the Site or the searchable CV database. You must ensure that you do not post any information which would be considered Sensitive Personal Data on the Site before being offered a role. 5
You are responsible for ensuring that your user name, password and other log-in credentials are kept confidential at all times. In accordance with applicable legislation, we have implemented technical and organisational measures designed to secure your Personal Data from accidental loss and from unauthorised access, use, alteration or disclosure. However, we cannot guarantee that unauthorised third parties will never be able to defeat those measures and access or use your Personal Data for improper purposes. International Transfers of Personal Data We may transfer your Personal Data to Cognizant Affiliates and third party services providers who may be based outside the European Economic Area (EEA). Where that is the case and where the data is being transferred to a country outside the EEA that is not deemed by the European Commission to have adequate protection, we will implement appropriate safeguards (such as the EU Standard Contractual Clauses) to protect your Personal Data when it is being transferred. For further information regarding the transfer of your Personal Data, please contact us at: ChireSupportEurope2@cognizant.com Changes to this Policy We reserve the right to make changes to this Policy at any time. Any changes to this Policy will be posted on this page thus make sure to read this Policy before submitting your Personal Data. Substantial changes will be highlighted on the Site or may be emailed to you. Contact Us If, at any time, you have questions or concerns about this Policy or believe that we have not adhered to this Policy, please feel free to email us at ChireSupportEurope2@cognizant.com or contact our Data Protection Officer at privacy@cognizant.com. 6