Last Updated: November 2020
ILLUMINATE USA is strongly committed to protecting the privacy of your personal information. This notice explains how ILLUMINATE USA handles the personal information you submit and we collect and process for recruitment and hiring purposes. The term “personal information” also refers to “personal data”. ILLUMINATE USA is the data controller for the information you provide through this website.
“ILLUMINATE USA”, “we”, and “us” refers to ILLUMINATE USA LLC and our affiliates that have posted a position for which you are applying. Each affiliate is a separate legal entity.
This Privacy Notice applies to personal data provided to us, either by you or by others (such as your present or past employers). When collecting and using personal data our policy is to only collect what we need and to be transparent about why and how we process personal data. We may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection. How we process your personal data may vary by jurisdiction based on applicable law.
1. Collecting Your Information
ILLUMINATE USA may seek additional data and/or verify your personal information by contacting your references, referrer and other third parties.
ILLUMINATE USA may also collect information about you from publicly available information sources. As permitted under applicable law, ILLUMINATE USA may also conduct background checks, criminal record checks and assessments and use and store such information during the recruitment process.
The information you provide to ILLUMINATE USA via Workday, both now and in the future, will be held and processed by or on behalf of ILLUMINATE USA for purposes related to current or future employment with ILLUMINATE USA.
2. Sensitive Personal Information / Special Categories of Personal Data
As part of your application to ILLUMINATE USA, you may provide sensitive personal information, often also referred to as special categories of personal data, to us (by responding to questions or as part of your application, resume/CV or otherwise). If you do provide sensitive personal information, you do so voluntarily and agree that such information may be used by ILLUMINATE USA as described in this Privacy Notice and as permitted under applicable laws. (Sensitive personal information may include, for example, information relating to your race or ethnic origin, political opinions, religious beliefs, trade union membership, criminal records, physical or mental health, biometric information, or sexual orientation.) ILLUMINATE USA will not require you to provide sensitive personal information about yourself through Workday, except to the extent, the collection of such information is required under applicable law.
By uploading and/or submitting such sensitive personal data to ILLUMINATE USA, you express your consent to data processing by ILLUMINATE USA for the purpose of carrying out the specific mandate relationship and thereby give your consent under applicable data protection law(s).
3. Updating and Accessing Your Information
It is your responsibility to keep your personal information accurate and up to date and to inform us of any changes. You can access your Workday profile at any time to review or update your personal information.
4. Using Your Information
ILLUMINATE USA and other ILLUMINATE USA affiliates with which your personal information is shared may, as permitted by applicable law, use your personal information for any or all of the following purposes:
- Managing your application(s) for employment, evaluating you for open positions throughout the ILLUMINATE USA network, and managing your candidate profile
- Evaluating your suitability for employment (including for example, providing your personal information to third parties to conduct background checks)
- Sending you email notifications and other announcements, requesting additional information or otherwise contacting you about your candidacy
- Conducting statistical analyses and reports including for example regarding usage of Workday, demographic analyses of candidates, reports on ILLUMINATE USA recruitment activities, and analyses of candidate sourcing channels, where permitted by law
- Administering and managing Workday and communicating with you about it
- Relating to any other purposes for which you provided the information to ILLUMINATE USA
Should you become an employee of ILLUMINATE USA or another ILLUMINATE USA associated company, any personal information you submit through Workday may be used in connection with your employment as permitted by applicable laws.
The processing activities described in this Privacy Notice are necessary in connection with your application for employment as well as ILLUMINATE USA’s legitimate interests in running a business and being a member of the ILLUMINATE USA network.
5. Data Retention
We will retain your personal data for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation). If your application is unsuccessful, ILLUMINATE USA may retain and use the information you provided to ILLUMINATE USA via Workday for a reasonable period of time to deal with any matter which may arise in connection with your application, for purposes of contacting you regarding other employment opportunities, and for ILLUMINATE USA’s legitimate business purposes. We may keep your personal data for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
6. When and How We Share Personal Data and Locations of Processing
We will only share your personal data if we are legally permitted to do so. When we transfer or share personal data, we put contractual arrangements and security mechanisms in place that comply with our data protection, confidentiality and security standards and applicable laws and regulations.
ILLUMINATE USA is part of a global network with companies around the world. Your personal information may be transferred and disclosed to other ILLUMINATE USA affiliates in connection with your application for employment and other legitimate business purposes. As a result, your personal information may be transferred and stored outside the country where you are located. This includes countries and regions outside the European Economic Area (EEA) and countries or regions that do not have laws that provide specific protection for personal information.
Where we collect your personal information from within the EEA, transfer outside the EEA will be only:
To a recipient in a jurisdiction approved by the European Commission as offering an adequate level of protection for personal data
Under an agreement which covers the EU requirements for the transfer of personal data to data processors or data controllers outside the EEA
We may transfer your personal data to:
Other ILLUMINATE USA affiliates
We may share your personal data with other ILLUMINATE USA affiliates for the purposes set out above (under “Using Your Information”).
Third party organizations that provide applications/functionality, data processing or IT services to us
We use third parties to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting, and management, data analysis, data back-up, security and storage services.
The third party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by ILLUMINATE USA, and to flow those same obligations down to their sub-processors.
We may also disclose personal information to other third parties for regulatory compliance purposes and/or as otherwise set out in this Privacy Statement.
We may also disclose your personal information to law enforcement, regulatory and other government agencies, and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation. This includes disclosures outside the country or region where you are located. ILLUMINATE USA may also review and use your personal information to determine whether disclosure is required or permitted.
7. European Privacy Rights
If you are a recruit in the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to enter into a contract with you (i.e. enter into an employment or work relationship with us), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Under the General Data Protection Regulation (GDPR) you have a number of rights with regard to your personal data. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability.
If you have provided consent for the processing of your personal data you have the right to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
If you are a European ILLUMINATE USA Recruit, you also have the right to lodge a complaint to the competent data protection supervisory authority if you believe that we have not complied with the requirements of the GDPR with regard to your personal data.
If you apply to a position in the U.S., ILLUMINATE USA Inc. will be the controller of your personal data. If you reside in, the United Kingdom, the European Union or European Economic Area or apply to a position in the United Kingdom or in one of the member states of the European Union or European Economic Area, the appropriate ILLUMINATE USA affiliate will be the controller of your personal data.
To exercise any of your rights, please contact us at firstname.lastname@example.org. We will process any requests in accordance with applicable law and within a reasonable period of time. We recommend you include documents that prove your identity and a clear and precise description of your request.
To find out more about the California Consumer Privacy Act, see the Illuminate USA CCPA Applicant Notice.
You are under no statutory or contractual obligation to provide personal information to ILLUMINATE USA during the recruitment process and you may choose to not to provide some of the personal information for the purposes set out in this Privacy Notice. Depending on the information you may choose not to provide, we may not be able to process your application, request or onboard for employment related purposes.
To request that your personal information be deleted, please contact us at email@example.com.
If you would like further details of ILLUMINATE USA’s data processing activities relating to Workday or have any other questions, please email ILLUMINATE USA at firstname.lastname@example.org.
11. Tracking Technologies
When you visit ILLUMINATE USA’s recruiting web pages or the recruiting portions of our site, ILLUMINATE USA may observe your activities, interactions, preferences, transactional information, and other computer and connection information (such as IP address) relating to your use of our websites and our services.
ILLUMINATE USA has implemented generally accepted standards of technology and operational security in order to protect your personal information from loss, misuse or destruction.
In particular, ILLUMINATE USA has put in place appropriate technical and organizational security measures to prevent any unauthorized or unlawful disclosure or processing of personal information and the accidental loss or destruction of or damage to personal information.
13. Changes to This Privacy Statement
We may update this privacy statement at any time by publishing an updated version here. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to review this privacy statement periodically to be informed about how we are protecting your information.