Candidate Privacy Notice

OUTBRAIN CANDIDATE PRIVACY NOTICE

 

Last updated: 28 October 2022

 

Purpose and Scope

 

Outbrain Inc. is a data controller in relation to your personal data. This means that we are responsible for deciding how we hold and use personal data about you.

This privacy notice is applicable when you are applying to any vacancies at Outbrain Inc. or one of its group companies, whether as an employee, contractor or consultant. It makes you aware of how and why your personal data will be used, namely for the purposes of our recruitment, and how long it will be retained for.

It provides you with certain information required under relevant data protection laws, such as the EU General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018, the Israel Protection of Privacy Law 5741-1981, the Lei Geral de Proteção de Dados Pessoais 13709/2018 (LGDP), and the Japanese Act on the Protection of Personal Information (APPI), among others.

 

Data protection principles

 

We will comply with data protection laws and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

 

Categories of personal data we hold about you

 

In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:

  • The information you have provided to us in your CV and covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender
  • Your current employment status, your employment history, your qualifications and salary details.
  • Your right to work information (including passport and visa details).
  • Any information you provide to us during an interview or during the recruitment process.
  • Assessment content and results if you are given a task during the recruitment process.

Depending on the country, we may collect, store and use the following types of sensitive personal data during your application:

  • Information about your race or ethnicity, religious beliefs, sexual orientation or identity, veteran status.
  • Information about your health, including any disability or special arrangements you may request.

 

How your personal data is collected

 

We collect personal data about candidates from the following sources:

  • You, the candidate, when you submit your application.
  • A recruitment agency which submit an application on your behalf.
  • Your named referees, from whom we confirm you past employments and positions.
  • Data accessible from publicly available sources, such as social networks (e.g. LinkedIn).

 

How we will use your personal data and why

 

We will use the personal data we collect about you to:

  • Assess your skills, qualifications, and suitability for the role you applied to.
  • Communicate with you about your application and the recruitment process.
  • Keep records related to our hiring processes.
  • Carry out reference checks, where applicable.
  • Report on our equal opportunity monitoring.

We need to process your personal data to decide whether to enter into a contract of employment with you.

We also need to process your data to comply with our legal or regulatory requirements, such as assessing your right to work in the location you have applied to a role.

When you give your consent, we may also use your data to tell you about other opportunities or positions at Outbrain that you may be interested in.

In some countries, Outbrain may also request that you voluntary provide, with your explicit consent and solely in accordance with data protection laws, some sensitive personal data for diversity and inclusion purposes. This data will be anonymised and aggregated in order to report on our equal opportunity monitoring obligations where such processing is specifically authorised or required by law.

 

If you fail to provide personal data

 

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

 

How we use sensitive personal data

 

We will use your sensitive personal data in the following ways:

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
  • We will use information your race or ethnicity, religious beliefs, sexual orientation or identity, veteran status to ensure meaningful equal opportunity monitoring and reporting in our group of companies.

 

Information about criminal convictions

 

We generally do not carry out criminal background checks as part of our recruitment process, unless when required by local laws for specific roles. In such a case, we will inform you through a specific notice during the recruitment process.

 

Automated decision-making

 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

 

Data sharing

 

The personal data contained in your application is collected and processed by Outbrain Inc., which is the data controller, for the purposes of managing our recruitment and hiring processes.

We will share your personal data within our group of companies for the purposes of processing your application. Your data may also be shared with local tax authorities and any governmental or administrative body where Outbrain determines that it is necessary or desirable in order to comply with applicable laws, court orders, or government regulations. We may also share your personal data with a third party that is looking to acquire or does acquire all or part of the assets or stock of Outbrain, or that succeeds Outbrain in carrying on all or a part of the business of Outbrain whether by merger, acquisition, re-organisation or otherwise.

Your personal data is processed by Greenhouse Software Inc., which is our data processor.

All our processors, recipients and other entities in our group of companies are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal data may be transferred for the purposes listed above to other Outbrain entities or to other recipients as referred above located in countries outside of the European Economic Area, including the United States of America. Your personal data will only be transferred when the recipient is an country that provides an adequate level of data protection or subject to appropriate safeguards, such as the relevant module of the EU Standard Contractual Clauses as published on 4 June 2021.

 

Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know reason. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. You can find more details about these measures on Outbrain’s Security page.

We have put in place procedures to deal with any suspected personal data breach or security incident and will notify you and any applicable regulator of such where we are legally required to do so.

 

Data retention

 

We will retain your personal data for a period of 12 months after we have communicated to you our decision about whether to appoint you to the role you applied to. We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal data in accordance with our data retention policy and applicable laws and regulations.

When you give your consent, we may retain your personal data for a longer period of up to 24 months after your application on the basis that a further opportunity may arise in future and you wish to be considered for such a position.

 

Rights of access, correction, erasure, and restriction

 

Your rights in connection with your personal data

Under certain circumstances, you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below). This right is not absolute, and we may still be lawfully entitled to retain some of your personal data when we have a legitimate interest to do so, such as being able to respond to a legal claim.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Withdraw your consent when you apply for a role, you may give you consent to be contacted by Outbrain for other opportunities for up to 24 months. You have the right to withdraw your consent for processing for that purpose at any time.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, withdraw your consent or have any other request under data protection laws, please contact us via privacy@outbrain.com.

 

Data Protection Officer and Data Protection Authorities

 

We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact us via privacy@outbrain.com.

If you are not satisfied with how we handled your personal data, you may have the right to lodge a complaint with the data protection authority of your country of residence. If you live in the UK, you can make a complaint with the Information Commissioner’s Office (ICO) at this address. If you live in the EU, you can find the relevant data protection authority here.