Sharethrough Employee Privacy Notice
Effective Date: May 4, 2021
Last Reviewed: March 18, 2022
Contents
1. Introduction
2. Data Controller, Data Protection Officer, and Representative
3. Information We Will Collect
4. Use of Personal Information
5. Data Sharing
6. Cross-Border Data Transfers
7. Data Security
8. Data Retention
9. Rights of Access, Correction, Erasure, and Objection
10. Changes to This Privacy Notice
11. Contact Us
1. Introduction
Sharethrough is committed to protecting the privacy and security of your personal information. This Employee Privacy Notice (the “Privacy Notice”) describes how Sharethrough and its subsidiaries, affiliates, and related entities (collectively, “Sharethrough,” “we,” or “us”) collect and process personal information about you during the application and recruitment process, and about you during and after your employment. This privacy notice applies to employees located in the United Kingdom (“UK”), Europe and the United States, including those in California in accordance with the California Consumer Privacy Act of 2018 (“CCPA”).
This Privacy Notice describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal information that we hold about you including how you can access, correct, and request erasure of your personal information.
We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
2. Data Controller, Data Protection Officer, and Representative
Sharethrough and its subsidiaries, affiliates, and related entities are joint controllers of the personal information we hold about you before, during or after your employment. Sharethrough has appointed a Data Protection Officer (DPO) and a representative in the European Union.
Sharethrough, its Data Protection Officer, and its representative may each be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Notice.
3. Information We Will Collect
Within the context of your role as an employee or prospective employee, we will collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
Personal information does not include certain information excluded from the applicable data privacy laws’ scope, such as:
- Publicly available information from government records.
- Deidentified or aggregated information.
- Personal information reflecting a written or verbal business-to-business communication, which may occur, for example, between you and our customers or suppliers.
To carry out our activities and obligations as an employer or potential employer, we may collect, store, and process the following categories of personal information which, unless otherwise noted below, we require for the purpose of administering the employment relationship with you and considering you for employment at Sharethrough:
| Category | Specific Pieces of Personal Information Collected |
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address (when you access our network resources), email address, username, Social Security number, or other similar identifiers. If provided by you as proof of eligibility to work or as part of your business travel profile, driver’s license number and passport number. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) or other similar state statutes | A name, signature, Social Security number, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, or health insurance information.If provided by you as proof of eligibility to work or as part of your business travel profile, passport number, driver’s license or state identification card number.NOTE: Some personal information included in this category may overlap with other categories. |
| C. Protected classification characteristics under state or federal law, including California | Required: Age (40 years or older), marital status. Note: We require your age to verify your identity, run background checks, and to provide you with health and retirement benefits. We require your marital status (along with dependent information) to administer benefits such as health insurance or retirement benefits. Optional: Race, color, ancestry, national origin, citizenship, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. NOTE: Providing this information is completely optional at your discretion, and we will collect this information only to the extent you choose to provide it in your resume, as part of the equal opportunity forms you fill out when you are hired, or as may be provided by a reference or other third party during reference and background checks. |
| F. Internet or other similar network activity | Browsing history, search history, information on your interaction with a website or application. Our collection of this type of information supplements our information security policy and other similar policies describing your use of our information systems. |
| H. Sensory data. | Visual information, such as your photograph for identification purposes, our company directory, and building security. |
| I. Professional or employment-related information | Current or past job history or performance evaluations. This may also include wage and benefit information, insurance enrollment information, start date and job title, location of employment, education and training, employment records (such as professional memberships, references, work history, and proof of work eligibility). |
In addition to the above, we may also receive information from background checks, phone screening, and interviews, including information from you or other third parties. This type of information may include the above categories or different categories as determined by the provider of such information.
4. Use of Personal Information
We only process your personal information where applicable law permits or requires it, including where the processing is necessary for the performance of our employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us as your employer, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent.
We may process your personal information for the following business or commercial purposes and for the purposes of performing the employment contract with you:
- recruiting;
- delivering or administering pay and benefits, including insurance benefits;
- managing our workforce and your career;
- delivering training programs, and measuring and recording the results of training;
- communicating with Sharethrough personnel;
- maintaining information about your work history, work performance, and disciplinary actions;
- to run and manage business operations, including to schedule work, manage the business organization, business assets, travel and expense reimbursement, managing corporate credit cards and card payment history, maintaining corporate contact directories and organizational charts, managing and storing records;
- processing IT infrastructure, including email, internet, social media systems, and file shares;
- maintaining the security and safety of our facilities, personnel, and other assets, including to authenticate personnel to access Sharethrough’s IT resources and facilities, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- to conduct screening and background and compliance checks before and during your employment at Sharethrough and maintaining records on such screening and checks;
- providing employment programs such as on-site health services, company cars, retirement schemes, stock options, and other similar benefits;
- to comply with legal requirements, including to report accidents, salary, and tax information to regulatory authorities;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sharethrough’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Sharethrough about our employees is among the assets transferred;
- in order to publish your name, picture, and contact information in our internal employee directory and, for leadership positions, to publish your online biography and for similar marketing efforts in accordance with Sharethrough’s policies; and]
- as described to you when collecting your personal information or as otherwise permitted under applicable law.
Sharethrough will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If we need to process your personal information for a different, unrelated, or incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal information without your knowledge or consent only where required by applicable law or regulation.
5. Data Sharing
We will only disclose your personal information to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the employment relationship with you, including third-party service providers who provide services to us or on our behalf.
Third-party service providers may include, but are not limited to, payroll processors, benefits administration providers, and data storage or hosting providers. These third-party service providers may be located outside of your home jurisdiction.
We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us as your employer. We do not permit our third-party service providers to process your personal information for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.
We maintain a list of third-party service providers to which your personal information could be transferred in the course of your employment. The list is available upon request.
We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you.
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.
- To protect the rights and property of Sharethrough.
- During emergency situations or where necessary to protect the safety of persons.
- Where the personal information is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
- For additional purposes with your consent where such consent is required by law.
6. Cross-Border Data Transfers
Where permitted by applicable law, we may transfer the personal information we collect about you to the United States, Canada and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our employment contract with you and for the purposes set out in this Privacy Notice.
We have implemented appropriate privacy protection mechanisms as required by law to secure the transfer of your personal information to the United States and other jurisdictions.
7. Data Security
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure.
In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
In case of a personal information breach, we will take all steps to fix it, including to report it as required by applicable laws and regulations, minimise any harmful effects on you, stop it from continuing, and prevent it from happening again.
8. Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider our statutory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means.
If you are hired, we generally keep your personal information as part of your employee file for the duration of your employment plus three (3) years, unless we are otherwise required to keep it longer by law.
If you are not hired, we generally keep your information for three (3) years after the decision has been made to provide you an opportunity to seek information about the recruitment process and in case similar role becomes vacant for which you will be a fitting candidate. We may also retain your information longer so we can show, in the case of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment process in a fair and transparent way.
Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer an employee of the company, we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations.
9. Rights of Access, Correction, Erasure, and Objection
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during the application process or your employment. You may request access to or correct the personal information that we hold about you. If you want to review, verify, or correct your personal information, please contact us at dataprotection@sharethrough.com. Any such communication must be in writing.
Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
10. Changes to This Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates.
If we would like to use your previously collected personal information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose. We may process your personal information without your knowledge or consent only where required by applicable law or regulation.
11. Contact Us
If you have any questions about our processing of your personal information or would like to make an access or other request, please contact us through your local human resources office (if you have one), or at the contact information below.
To Contact Sharethrough (Controller)
Sharethrough
5455 Gaspe Avenue, Suite 730
Montreal, Quebec,
Canada H2T 3B3
Attn: Legal & Compliance Team
Email: dataprotection@sharethrough.com
To Contact Our Data Protection Officer
Chantal Bernier
99 Bank Street
Suite 1420
Ottawa, Ontario K1P 1H4
Canada
+1 (613) 783-9600
Email: chantal.bernier@dentons.com
To Contact Our Local EU Representative
Dr. Christian Schefold
Sharethrough Inc.
Dentons GmbH
Markgrafenstraße 33
10117 Berlin, Germany
Email: representation.sharethrough.europe@dentons.com