Candidate Privacy Policy

Last Updated 9/07/2023

Notice Regarding Privacy of Candidate Personal Information

Edmentum, Inc. and its wholly-owned subsidiaries (the “Company” or “we”) collect and use Personal Information for human resources, employment, health and safety, and business-related purposes and for its legal compliance purposes. Personal Information is information that identifies, relates, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This Privacy Notice explains how we may collect, use, and share Personal Information we collect from and about job applicants (“Candidate(s),” “you,” “your”).

Personal Information We Collect:

As part of the process for considering your candidacy for employment we may ask you to provide certain Personal Information, such as:

Basic identifiers, such as full name, date of birth, and signature.
Demographic data, such as gender, race, ethnic origin, marital status, disability, veteran or military status.
Contact information, such as home address, telephone numbers, email addresses, social media page URLs, and emergency contact information.
National identifiers, such as social security number, passport and visa information, and immigration status and documentation.
Educational background, academic qualifications, records, and references.
Past and Present Employment details, such as employer(s), job titles, job responsibilities, manager contact information, hire and separation dates, professional qualifications, employment references, and volunteering history.
Geolocation data, such as time and physical location related to use of an internet website accessed via a Company device or system, application, device, or physical access to a Company office location.
Profile or summary information about personal preferences, written and spoken languages, characteristics, attitudes, intelligence, abilities, and aptitudes.
Monitoring information such as recordings of audio or visual calls and videos of activity in our buildings gathered via our call monitoring and video surveillance systems.
Assessments drawn from that data as part of evaluation of your employment candidacy.

We may collect this Personal Information directly from you when you submit a job application, or from an employment agency, recruiting firm, or personal referral that provides us with your Personal Information on your behalf. We may also collect publicly available Personal Information about you from third parties, such as LinkedIn, which we leverage to assist us in our recruitment efforts.

Some of the Personal Information listed above – such as Personal Information revealing your race, ethnicity, trade union membership, and health data – is considered to be Sensitive Personal Information under applicable laws. Where required by law, we will request your consent prior to collecting Sensitive Personal Information.

How We May Use and Disclose Your Personal Information

We collect Personal Information to use or disclose for a variety of purposes related to a Candidate’s potential relationship with our Company, including our subsidiaries, and any successor to all or part of our business. These purposes may include, as appropriate, to:

Maintain, administer, and manage recruitment and vendor procurement;
Assess your fit for a current or future employment or contract role;
Communicate with you regarding your application;
Conduct background checks;
Maintain documentation required under applicable immigration law;
Manage Candidate information including maintaining Candidate records and evaluating potential qualifications;
Manage and maintain security systems and facilitate access to systems;
Comply with applicable laws and regulations;
Conduct internal audits;
Investigate and enforce compliance with and potential breaches of Company policies and procedures;
Perform workforce analytics, data analytics, and benchmarking
Administer and maintain the Company’s operations, including for safety and security purposes;
Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents, including in relation to known or suspected violation of our terms of use, fraud prevention, or other unlawful activities, including to share your Personal Information with entities assisting us in related investigations;
In connection with legal or regulatory obligations, including as may be necessary to protect our rights or the rights and safety of others, or as necessary in the event of a court order, regulatory inquiry, or other lawful request. Provided, however, that unless legally prohibited, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change, we may need to transfer your Personal Information to that re-organized entity, new owner, or assignee after the business change for them to use in accordance with this Privacy Policy.
Other human resources and vendor procurement purposes.

How You May Modify Your Information:

If you would like to review, correct, update or request that we delete Personal Information you have provided to us, please contact us at privacy@edmentum.com and specify what you would like to review, correct, update or have deleted.

Third Parties:

We may contract with third parties to support us throughout the hiring process, including data hosting providers, recruiters, background check and credit reference providers, professional advisors, such as accountants, auditors, and lawyers, facilities management, IT services, and others. These third parties may require a limited amount of information, including Personal Information, in order to deliver their services.

We may also retain, use and share aggregated user information that is not linked or linkable to Personal Information for legally permissible purposes.

Security:

We implement physical, administrative, and technical safeguards to help protect the confidentiality, integrity and availability of your Personal Information. We host Personal Information in cloud-based environments that use firewalls, encryption and other industry-standard technologies in an effort to prevent interference or access from outside intruders. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably within our control.

Data Retention:

We retain Personal Information for as long as is legally permissible, but for at least 2 years to consider your job application for the position for which you are applying, and for potential positions in the future. Where required by applicable law, we request your consent prior to retaining your Personal Information beyond the time necessary to consider your then-current job application.

Prior to deletion of your Personal Information, we will contact you to ask if you wish to consent to our retention for a longer time period for future employment consideration. If we do not receive permission within a reasonable time period, we will delete your Personal Information.

If you wish to request deletion of your Personal Information, please contact us at privacy@edmentum.com.

After deletion of Personal Information, we retain de-identified information for legally permissible purposes.

Opt-Out Policy:

We may send you emails with information about job listings or other information we believe may be of interest. You may opt out of receiving these email messages from us by clicking on the “unsubscribe” link found at the bottom of every email that we send or by contacting us at recruiting@edmentum.com.

We do not send email messages on behalf of third parties.

Notice For California and Other US Residents:

Certain US state laws, including the laws of California, provide their residents with certain rights related to their Personal Information, as described below. We provide these rights to all US residents.

Right to Know and Access Personal Information:

You may access Personal Information we maintain about you and request to receive it in a machine-readable copy that is readily available to you by using the methods provided below. If we grant your request, we will provide you with a copy of the Personal Information we maintain about you in the ordinary course of business. We may not fulfill some or all of your request to access as permitted by applicable law.

Right of Correction: You have the right to correct inaccuracies in the Personal Information we maintain about you.

Deletion of Personal Information:

You may ask us to delete the Personal Information we maintain about you by using the methods provided below.

Right to Opt Out of “Sale” or “Sharing” of Personal Information:

You may opt out of what California and other US state laws consider to be the “sale” or “sharing” of your Personal Information, which, for our purposes means transfer of your Personal Information to certain third parties for their targeted advertising purposes. You may opt out of this practice by clicking on the “Do Not Sell My Personal Information” link on the footer, or by clicking here and following the instructions.

Please note that before we are able to fulfill your requests regarding certain rights, we are required by law to verify your identity in order to help prevent unauthorized access to your data. In addition, please note that the rights listed above are subject to certain exemptions to safeguard the public interest (for example, to prevent or detect a crime) and our interests (for example, to maintain legal privilege). As a result, requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we are unable to fulfill your request and of any reasons why we are unable to honor your request.

Authorized Agent:

When authorized by your state law, you may be allowed to use an authorized agent to exercise any of these privacy rights on your behalf. If you are an authorized agent acting on behalf of a US resident as permitted under applicable state law to communicate with us or to exercise a privacy right, you must be able to demonstrate that you have the necessary authorization and access to act on behalf of the resident. If you are an authorized agent trying to exercise rights on behalf of a Edmentum user, please contact us at the contact information below with supporting verification information required under applicable state law.

To Exercise Your Rights

Please visit this page or contact us using the information below in order to exercise the rights described in this section. If you have any questions or concerns regarding your rights or this Privacy Policy, you may contact us at:

Edmentum
5600 W 83rd Street, Suite 300
8200 Tower
Bloomington, Minnesota, 55437
800.447.5286
privacy@edmentum.com

We will comply with your rights within the time frame required by applicable law.

Non-discrimination: We don’t discriminate or otherwise penalize anyone for exercising their rights under this Privacy Policy.

The chart below reflects our current practices and our practices that have been in place over the past 12 months.

Categories of Personal Information we Collect	Identifiers such as your first and last name, date of birth, address, telephone number, signature, email address, social media page URLs, emergency contact information, social security number, passport and visa information, immigration status and documentation, gender, race, ethnic origin, marital status, disability, veteran or military status, information about personal preferences, written and spoken languages, characteristics, attitudes, intelligence, abilities, and aptitudes. Internet or other electronic network activity information including your Internet Protocol address. Professional or employment-related information. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our website site, application, or advertisement. Geolocation data. Audio and video, such as recordings of audio or visual calls and videos of activity in our buildings gathered via our call monitoring and video surveillance systems. Assessments drawn from that data as relates to evaluation of your employment candidacy, provided however that such assessments do not include use of sensitive Personal Information. We collect sensitive Personal Information including social security number passport and visa information, immigration status and documentation, race, ethnic origin, disability, veteran or military status.
Categories of sources from which the Personal Information is collected	We collect the Personal Information directly from you and from third parties that assist us in providing the services, such as results of a background check from our third party service provider.
Business or commercial purpose for sharing or selling Personal Information	We collect your Personal Information to provide the recruitment services as described in this Privacy Policy and for the following purposes: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Debugging to identify and repair errors that impair existing intended functionality. Communicating with you about your application and candidacy. Maintaining the quality of our service and to improve, upgrade, or enhance our service.
Categories of third parties with whom we may "share" or "sell" Personal Information	We do not engage in what the laws define as “selling” or “sharing” your Personal Information, which for our purposes would mean transfer of your Personal Information to a third party for commercial purposes.
Specific pieces of Personal Information we have collected	Internet Protocol address, device ID. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our candidate portal. Basic identifiers, such as full name, date of birth, and signature. Demographic data, such as gender, race, ethnic origin, marital status, disability, veteran or military status. Contact information, such as home address, telephone numbers, email addresses, social media page URLs, and emergency contact information. National identifiers, such as social security number, passport and visa information, and immigration status and documentation. Educational background, academic qualifications, records, and references. Past and Present Employment details, such as employer(s), job titles, job responsibilities, manager contact information, hire and separation dates, professional qualifications, employment references, and volunteering history. Geolocation data, such as time and physical location related to use of an internet website accessed via a Company device or system, application, device, or physical access to a Company office location. Profile or summary information about personal preferences, written and spoken languages, characteristics, attitudes, intelligence, abilities, and aptitudes. Monitoring information, such as recordings of audio or visual calls and videos of activity in our buildings gathered via our call monitoring and video surveillance systems. Assessments drawn from that data as part of evaluation of your employment candidacy, provided, however, that such assessments do not include use of sensitive Personal Information.

Information for Residents of the European Economic Area (EEA), the United Kingdom (UK) and Switzerland:

When you apply for a job with the Company, we function as a “data controller” under the General Data Protection Regulation (“GDPR”). Our legal basis for processing your Personal Information are:

As necessary for our legitimate interests, including our interests in assessing candidates for current and future employment opportunities and managing and improving our recruitment and hiring process, unless those interests are overridden by your interests or fundamental rights and freedoms;
To comply with our legal obligations, including obligations to provide a safe working environment;
To prepare and execute an employment agreement with you;
Where it is necessary in the public interest, such as for review of our equal opportunity obligations;
Where required under applicable law, your explicit consent.

If you are located outside of the United States, please be aware that your Personal Information will be processed in the United States, inclusive of transfer and storage.

Wherever the Personal Information is, it will be treated in accordance with this Privacy Policy and applicable privacy laws of the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy.

We will comply with all applicable laws relating to the cross-border disclosure of your Personal Information. Where required, we will implement Standard Contractual Clauses with our third parties or rely on another appropriate transfer mechanism to ensure that the transfer of your Personal Information outside of your country is lawful. You may request details of the transfer mechanisms that we rely on to transfer personal information outside of your country by emailing us at privacy@edmentum.com.

Additional Rights:

The laws in your country may provide you with additional rights related to your Personal Information as described in this section, or they may limit these rights. In all cases, we will provide you with rights afforded to you in accordance with applicable laws.

For example, if you are based in the EEA, you may have the right to access, update or correct your Personal Information, to request deletion of your Personal Information, and to object to certain processing, to receive a machine-readable copy of the Personal Information about you that you provided to us, or in certain circumstances, to request that we transfer that Personal Information to a third party, and to lodge a complaint with a supervisory authority.

In addition, where you provided your consent to allow us to process your Personal Information, you may withdraw that consent by contacting us using the details provided in the “Contact” section. You may also restrict how we use your Personal Information while a complaint is being investigated.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (for example, to prevent or detect a crime) and our interests (for example, to maintain legal privilege). If you contact us to exercise any of these rights, we will verify your request and respond within the timeframe required by law

Changes to this Notice:

We review this Privacy Notice in accordance with legal requirements and the evolution of our business, and may change it in the future. When we do, we will provide you with notice as required by law, and the “last updated” notation indicates when it was last revised.

Contact:

If you have any questions about this Notice or need to access this Notice in an alternative format, please contact recruiting@edmentum.com and (800)-447-5286.

Our Data Protection Officer may be reached at privacy@edmentum.com.