Candidate Privacy Policy

TABLE OF CONTENTS

I. INFORMATION THAT WE COLLECT

A. Information You Provide to Us

II. SOURCES OF PERSONAL INFORMATION

III. CATEGORIES OF PERSONAL INFORMATION COLLECTED AND PURPOSE OF PROCESSING

IV. SHARING PERSONAL INFORMATION

V. YOUR PERSONAL INFORMATION RIGHTS

VI. COMMUNICATIONS

VII. SECURITY

VIII. RETENTION OF PERSONAL INFORMATION

IX. UPDATING CANDIDATE INFORMATION

X. REVIEW

XI. CONTACT INFORMATION

XII. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK

A. Identity and Contact Details of Controller and EU Representative

B. Special Categories of Information

C. Consent to Transfer

D. Data Protection Officer

 

This Privacy Notice describes, among other things, how Rich Products Corporation (“Rich’s”) collects, processes, and uses personal information (i.e., personal contact details such as name, job title, home addresses, telephone numbers, personal email addresses, birthdate, sex, recruitment information, employment records, identification information, and financial information) (“Personal Information”) about individuals seeking employment with Rich’s, including those seeking full-time employment, temporary employment, independent contractors, interns, or volunteers (collectively, “Candidates”) applying through the website, https://careers.rich.com/.  The Personal Information processed by Rich’s (which may be held on paper, in electronic format, or in any other format) may be subject to certain legal safeguards specified in applicable laws.  For Candidates based in the United Kingdom, European Union, or the European Economic Area, please also refer to the separate section below titled “Notice to Individuals in the European Economic Area and the UK.”

Rich’s needs to process your Personal Information in order to evaluate your candidacy.  There are also statutory requirements and other contractual requirements with which we must comply regarding your job application and any recruitment or hiring process.  If we are unable to carry

out the processing activities that we describe in this Notice, we may not be able to evaluate your candidacy or hire you.

This Notice does not guarantee that you will be hired and, if you are hired, this document does not create a contract of employment.  In the event you accept a position with Rich’s, your information will be handled in accordance with the Associate Privacy Notice.

I. INFORMATION THAT WE COLLECT

a) Information You Provide to Us

This Privacy Notice applies to all Personal Information you might voluntarily submit to us during the course of your application process with Rich’s.  We may collect and process the following Personal Information: 

  • Personal contact details such as name, job title, home addresses, telephone numbers, and personal email addresses; 
  • Date of birth;
  • Gender;
  • Recruitment information (including copies of right to work documentation; references, opinions and/or comments of any previous employers or coworkers; and other information included in a CV or cover letter or as part of the application process);  
  • Employment records (as included in a CV or cover letter or as part of the application process); 
  • Skills and job preferences;
  • Disability information;
  • Equal opportunities monitoring information, including information about your ethnic origin and health;
  • Information about your current compensation, including benefit entitlements (for UK/EEA Candidates only);
  • Information about your use of our information and communications systems (including email and phone numbers for receiving text messages);
  • Inferences from any of the Personal Information categories we collect;
  • Any additional demographic information that you voluntarily provide to us; and 
  • Any other information that you voluntarily provide to us as part of the application process. 

Background Checks

As part of Rich’s recruitment process, you may also be subject to a background check, where justified by the particular role you are applying to and subject to any applicable laws.  The content of background check information varies but may include Personal Information gathered from publicly available sources, your former employers or colleagues, schools you have attended, credit reporting agencies, and criminal records databases.  You will receive more information about the nature of such a background check before it begins and no such checks will be undertaken without your express prior consent, where this is required by applicable law.

II. SOURCES OF PERSONAL INFORMATION 

The above information is collected in the following methods listed below: 

  • Job applications (hard copy or electronic copy); 
  • Resume(s)/curriculum vitae(s); 
  • Information provided during job forums and recruitment events;
  • Information forwarded by recruitment agencies; 
  • Information provided directly from you;
  • Pre-employment screening services;
  • Online tests;
  • Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter, and Facebook);
  • Third parties as necessary for providing you with benefits and ancillary services;
  • Training and certifications.

Note, the above information is received by Rich’s in various forms including hard-copy and electronic form, delivered in-person or via email, text, fax, website, social media, etc.  

III. CATEGORIES OF PERSONAL INFORMATION COLLECTED AND PURPOSE OF PROCESSING

Personal Information collected by Rich’s may be processed for purposes and reasons set forth in the table below.  Please note that no automated decision-making takes part in our recruitment process.

OBJECTIVES OF THE PROCESSING TYPES OF PERSONAL INFORMATION BASIS FOR PROCESSING
Recruitment/Candidate Management

Managing the workforce: recruiting, managing work, developing and managing the company’s organizational structure, managing staff and team management, and talent management.

  • Identification data including s national identification number, and driver’s license 
  • Data related to the Candidate’s prospective position  
  • Salary data and related financial data 
  • Health data related to the Candidate’s prospective position
  • Information about committing or allegedly committing a criminal offense or a civil offense
  • For the proper assessment of a Candidate  
  • For administration of workforce training and development initiatives including via federal and state grant programs 
  • To fulfill the employment or other contract to which the Candidate is a party 
Legal Obligations 

The fulfillment of our legal obligations, including obligations arising from employment and immigration laws, tax laws, and regulations relating to health and safety at work.

  • Identification data including national identification number and driver’s license 
  • Candidate demographic information 
  • Data related to the Candidate’s prospective position  
  • Salary data and related financial data 
  • Information on insurance and indemnity 
  • Information on the social security system health data 
  • To comply with the legal obligations applicable to Rich’s
Protective Measures

Detection or prevention of any inappropriate behavior or violation of the Rich’s rules, including the protection of our intellectual property, confidential information, and other tangible and intangible property.

  • Identification data including social security number and driver’s license 
  • Data related to the Candidate’s prospective position 
  • Information on asset use and company systems 
  • For the legitimate interests of Rich’s, to protect the assets of the company
Legal Proceedings

For the purposes of any potential and/or ongoing litigation or inquiries concerning us or one of our Group companies, representatives of the company.

  • Identification data including national identification number and driver’s license 
  • Data related to the Candidate’s prospective position 
  • Information on asset use and company systems 
  • For Rich’s legitimate interests to claim Rich’s rights against third parties or to defend against third-party claims against Rich’s in a possible litigation or to defend and meet the requirements of an administrative inquiry
IT Security
  • Information on asset use and company systems 
  • Backing up
  • Providing Candidates with IT support
  • Detecting and protecting against security incidents and malicious, deceptive, fraudulent, or illegal activity

IV. SHARING PERSONAL INFORMATION

Personal Information collected during the course of your application process with Rich’s will be used only for employment and recruiting related purposes within Rich’s or its subsidiaries and affiliates.  Rich’s will not disclose any of your Personal Information to third parties, except as otherwise stated, without your express consent.  To the extent you accept a position with Rich’s, your Personal Information will be shared with certain third parties, as described in the Associate Privacy Notice.

Rich’s does not sell or otherwise disclose Candidate Personal Information for monetary or other consideration to any third parties.

V. YOUR PERSONAL INFORMATION RIGHTS

To the extent any data privacy law applies to the collection of your Personal Information, you may have certain rights in relation to your Personal Information.  These rights may include any of the following:

  • Right to Know and Right to Access.  You have the right to know and right to access what Personal Information is processed by Rich’s
  • Right to Correct Inaccurate Personal Information.  If you believe that Rich’s holds any incomplete or inaccurate data about you, you have the right to ask Rich’s to correct and/or complete the information.  
  • Rights to Erasure (Delete), Restrict, or Object.  You have the right to request erasure of your Personal Information or to restrict processing (where applicable) as well as to object to any processing of data or direct marketing from Rich’s.
  • Right to Opt Out of Sale or Sharing of Personal Information.  You have the right to opt out of the sale or sharing of your Personal Information.  However, Rich’s does not sell or otherwise disclose Candidate Personal Information for monetary or other consideration to any third parties. 
  • Right to Limit Use and Disclosure of Sensitive Personal Information.  You may have the right to direct Rich’s to limit its use of your sensitive Personal Information to that use which is necessary for the purposes stated above.
  • Right to Transfer and Data Portability.  You may have the right to request that we transfer your Personal Information to a third party or that we provide your information to you in a commonly used, structured format so that you may transfer your Personal Information to a third party.
  • Right to Revoke Consent.  You may have the right to revoke your consent to our processing of your Personal Information.
  • Right of No Retaliation Following Opt Out or Exercise of Privacy Rights.  Rich’s does not discriminate or retaliate against California residents who exercise their rights under the CCPA.
  • Right of Appeal.  Following Rich’s denial of any of the requests listed above, you may have the right to appeal that decision.

Data Subject Requests

In order to exercise your rights under this Privacy Notice and applicable data protection laws, you may send an email to [email protected].  You may also exercise your rights under this Privacy Notice by calling the following toll-free telephone number: 1-877-352-0077.  For certain rights listed above, you may be able to exercise those rights by logging in to your career profile page on the Rich’s Careers website at https://careers.rich.com/.

UK/EEA Candidates:  If you wish to exercise your rights under this Privacy Notice and applicable data protection laws, you can contact us in the following ways:

Email:  [email protected]

Call us: +44 03300605174

Write us: Rich Andover Realty Limited

Unit 5 Pioneer Road

Andover Business Park

Andover, GB SP11 8EZ

The requests will be considered and responded to in the time period stated by applicable law.  Note, certain Information may be exempt from such requests.  We may require additional information from you to confirm your identity in responding to such requests.  

You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly.  Please contact us at: 

Email:  [email protected]

Call us: +44 04400605174

Write us: Rich Andover Realty Limited

Unit 5 Pioneer Road

Andover Business Park

Andover, GB SP11 8EZ

If Rich’s receives a request from you to exercise any of the above rights, Rich’s may ask you basic questions to identify which Personal Information is associated with you before acting on the request; this is to confirm that your data is protected and kept secure.

VI. COMMUNICATIONS

We may use your contact information if you elect to receive job alerts or to notify you that we have received your information or that you are qualified for certain job opportunities.  We will not use your contact information to send you any other information or for any other purpose without your express consent.  If you do not wish to receive these alerts, please log in to your career account on the Rich’s Careers website and change your user preferences.

VII. SECURITY

Rich’s uses commercially reasonable security measures to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way.  We limit access to your Personal Information to a select group of authorized individuals who require access to it for the purpose of performing their job duties.  Those processing your Personal Information will do so only in an authorized manner and are subject to a duty of confidentiality.  Accordingly, we have put in place various physical, technical, and administrative data protection procedures, including industry standard security technology.  While we are committed to safeguarding your Personal Information, we cannot guarantee that the transmission and storage of your Personal Information is 100% secure.  We also have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

VIII. RETENTION OF PERSONAL INFORMATION

Rich’s will not maintain your Personal Information longer than is necessary for the purpose for which it was collected.  Rich’s will process Personal Information of the Candidate for the duration of the recruitment process and furthermore for a period of one (1) year from the conclusion of your most recent recruitment process with Rich’s, unless required to maintain the Personal Information for a longer period under any legal obligation.  This may include retaining your Personal Information in order to consider you for additional employment opportunities in the future.  If you do not wish us to retain your Personal Information for this purpose, please see the previous section titled “Your Personal Information Rights” regarding how to delete your Personal Information.  The Candidate’s Personal Information and documents may further be processed, if necessary, for the determination, exercise, or defense of Rich’s legal claims or for a period that is required by applicable law. 

If your application for employment is successful, Personal Information gathered during the recruitment process will be transferred to your personnel file and retained during your employment and for a period of time following the conclusion of your employment with us, as set forth in our Associate Privacy Notice.  If in the future we intend to process your personal data for a purpose other than that which it was collected we will provide you with information on that purpose and any other relevant information.

IX. UPDATING CANDIDATE INFORMATION

To edit your profile information, you must login to your career account.  After you enter your associated personal identification information, you will be able to edit or delete your profile.

X. REVIEW

Rich’s may revise the Privacy Notice from time to time and/or will update the Privacy Notice on an annual basis at our discretion.

XI. CONTACT INFORMATION

Rich’s has appointed/designated our Human Resources Director that is responsible for this Privacy Notice: 

Name: Erika Marabella  

Title: Vice President – Compliance, Deputy General Counsel

Email: [email protected] 

Phone: 1-877-352-0077

XII. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK

This section applies only to individuals applying to Rich’s from within the European Union (EU), the European Economic Area (EEA), and the UK, and only if we collect any Information from you that is considered “Personal Data,” as defined in the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.

a) Identity and Contact Details of Controller and EU Representative

Unless otherwise stated, we are the Data Controller for the Information we process.

Contact Details:

Email:  [email protected]

Call us: +44 03300605174

Write us: Rich Andover Realty Limited

Unit 5 Pioneer Road

Andover Business Park

Andover, GB SP11 8EZ

b) Special Categories of Information

In addition to the information specified in prior sections above, Rich’s may also process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, biometric data or sexual orientation, but will only do so with your explicit consent to those activities unless this is not required by law or the information is required to protect your health in an emergency.  Where we are processing data based on your consent, you have the right to withdraw that consent at any time.

For some roles, Rich’s is obliged to seek information about criminal convictions and offenses. Where Rich’s seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our contractual duties to you. 

We may transfer information about you to other group companies for purposes connected with your employment or the management of the company’s business.  This includes employment background checks and ability testing. 

We are operated in the United States, and we may use service providers based in the United States to operate our business and our relationship with you.  Please be aware that information that we collect may be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.  We maintain measures to address the transfer of your Personal Data between our group companies and between us and our third-party service providers in accordance with applicable data protection laws and regulations, including a data sharing agreement with standard contract clauses ensuring the security of your data.

d) Data Protection Officer

We have appointed a Data Protection Officer whose role is to inform and advise us about, and to confirm that we remain compliant with, data protection legislation.  The Data Protection Officer should be your first point of contact if you have any queries or concerns about your Personal Data. Our current Data Protection Officer is Maxine Brooks who can be contacted at [email protected] or 0330 5102 060. 

You can write to the Data Protection Officer at: 

Data Protection Officer 

Rich Products 

5 Pioneer Road 

Andover Business Park 

Andover Hampshire 

SP11 8EZ