Candidate Privacy Policy
Effective: December 21, 2023
Table of Contents
This Candidate Privacy Policy (this“Policy”) explains what information we collect about you during the application or recruitment process for employment with us, as well as the purposes for which we collect and use that information. This policy does not apply to the use of Transcarent services, which are covered under our Transcarent Privacy Policy.
We consider you to be a “Candidate” from the period starting when you apply or are recruited through completion of on boarding if hired. In this Policy, if we mention “Personal Information” we are talking about any information we collect about you during the application or recruitment process that could, alone or together with other information, personally identify you or that could be reasonably linked to you.
What Categories of Personal Information May We Collect?
Transcarent may collect the following categories of Personal Information about you. The examples here are not a comprehensive list.
Categories of Information | Examples of information from these categories |
Identifiers | Name Email address Phone number Address Driver’s license number Passport number |
Characteristics of Protected Classifications Under California or Federal Law | Gender Race Disability Military or veteran status |
Professional or employment-related information | Your resume or CV Cover letter Information about any previous employment at Transcarent Referrals and references Desired salary Interview details Professional or employment-related information |
Professional or employment-related information | Information received from background checks (where applicable) |
Sensitive Personal Information | Driver’s license number Passport number Social security number Racial or ethnic origin Medical or health information |
How May We Use Candidate Personal Information?
To provide you with context for how we may use your personal information, we offer the following examples. This is not a comprehensive list.
Communicate with you about your application and the recruitment process, including informing you of other potential employment opportunities with us.
If you are offered a position, to prepare your offer letter.
Assess your skills, qualifications, and interests for employment opportunities with us.
Manage and improve our application and recruitment process (such as making the application process more efficient and improving our diversity practices).
Comply with local laws, regulations, legal processes, or enforceable government requests.
Vetting for recruitment and team allocation including, where relevant and appropriate, right to work verification, identity fraud checks, relevant employment history, relevant regulatory status and professional qualifications
If you are offered a position, to provide any necessary accommodations, if requested by you.
If you are offered a position, to conduct a background check (to the extent permitted by applicable law and with your consent) including verifying the information provided by you or others and checking your references.
Why Might We Share Your Personal Information?
We won’t sell or share your personal information for targeted advertising purposes. We will share your personal information with those who have a legitimate business need for it. The following are examples and not a comprehensive list.
To carry out the uses described above.
For a third party to provide products or services to us or on our behalf. For example, to facilitate the application process or conduct background checks.
To comply with our legal obligations, regulations, or contracts, or to respond to a court order, administrative or judicial process (such as subpoena, government audit or search warrant). Or in response to lawful requests by public authorities (such as national security or law enforcement).
As necessary to establish, exercise, or defend against potential or pending litigation.
Where necessary to protect Transcarent, your vital interests (such as safety and security), or those of another person.
With your consent (such as to contact your references). Please note: you are responsible for obtaining consent from references before providing their personal information to us.
We may share your personal information with the following categories of recipients.
Categories of recipients | Reasons for sharing | Categories of Information Shared |
Vendors and Service Providers | We may share any information we receive with vendors and service providers retained in connection with your candidacy. Information is shared to the extent necessary to perform the vendors’ or service providers’ respective functions. | Identifiers Protected classification characteristics under California or federal law (such as gender or race) Professional or employment-related information Sensitive Personal Information |
Corporate Affiliates. | To support us in providing, integrating, promoting, and improving the Services, we may share Candidate Personal Informationwithin our corporate family of companies that are related by common ownership or control. | Identifiers Protected classification characteristics under California or federal law (such as gender or race) Professional or employment-related information Sensitive Personal Information |
In addition, we may share information we have about you that is described in any of the categories listed above in “Categories of Information We Collect” in the following situations:
As required by law and similar disclosures: we may access, preserve, and disclose your information if we believe doing so is required to: (a) comply with applicable laws or law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.
Merger, sale, or other asset transfers: we may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets.
With your consent: we may disclose your information with your permission.
Retention of Information
We will retain your information for the period necessary to fulfill the purposes outlined in this Policy, to consider you for any future job opportunities, or as instructed by you, unless a longer retention period is required or permitted by law.
If you are hired for a position at Transcarent, we will retain the information provided during the application and recruitment process as part of your employee record.
Security
We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, no electronic transmission or storage of information can be entirely secure; no one can guarantee the absolute security or privacy of your information.
Your Privacy Rights
Transcarent has candidates from throughout the United States. Regardless of where you are located, we respect your ability to know, delete, correct, and export your information.
Right to Know and Access Personal Information: For your convenience, we already included the following information in this Candidate Privacy Policy.
The categories of information we collect or disclose about you.
The categories of sources of such information.
The business or commercial purpose for collecting your information.
The categories of third parties with whom we share or disclose your information
You also have the right to request the specific pieces of personal information we have collected about you.
Right to Correct Inaccurate Personal Information: we want the information we have about you to be correct. Please let us know if you think that the personal information about you is incorrect, incomplete, or outdated. We may ask that you provide documentation to support your request. We will correct your information unless we determine that the persona information is more than likely correct.
Right to Request Deletion of your Personal Information: you have the right to ask us to delete personal information collected from you, subject to certain exceptions where we need your personal information to:
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities,
Comply with legal obligation, or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Please note: if you submitted your personal information to a third-party provider yourself, you need to contact that third-party directly to request such deletion.
Right to Opt Out of Sale or Sharing of Candidate Personal Information
You can opt-out of any sale of your Personal Information or sharing of personal information for cross-contextual behavioral advertising as such terms are defined under the CCPA. We do not sell or share candidate Personal Information in the manner restricted by the CCPA and have not done so in the preceding 12 months.
Right to Opt Out of Automated Decision-Making
As of the date of this policy, we do not use automated decision-making on Candidate Personal Information.
Right to Opt Out of Processing of Candidate Personal Information for Profiling or Targeted Advertising
We do not process Candidate Personal Information for profiling or targeted advertising purposes.
Right to Limit Processing of Sensitive Personal Information: you may request that we limit the use and disclosure of your sensitive personal information to that which is necessary to perform the services reasonably expected by an average consumer who requests these services, with some exceptions. For example, we are allowed to use your sensitive personal information (even if you opt-out):
if it is not used to infer characteristics about you;
to detect security incidents;
to resist malicious, fraudulent, deceptive, or illegal actions directed at Transcarent;
to ensure the physical safety of you and others;
for short-term and transient use.
Exercising Your Privacy Rights
To request to exercise your privacy rights described above, please submit your request to Privacy@Transcarent.com with the subject line “Candidate Privacy Rights Request”.
Only you or an authorized agent may make a request related to your Candidate Personal Information. We may ask additional questions to verify that a request is coming from you or an authorized agent; we do this to protect your data privacy. To do that, we need you to:
provide information that allows us to reasonably verify that you are the person about whom we collected Candidate Personal Information or an authorized representative. For example, by letting us know your name and zip code; and
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We can only respond to your request or provide you with personal information if we verify your identity or authority to make the request and confirm the personal information relates to you. If we follow-up with you to ask for more identifying details, please know this is to protect your data privacy. We will use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.
You may also make a privacy request by calling our toll-free number(888) 388-9151.
Right to Appeal Decisions Made by Transcarent: you may appeal a decision made by us by emailing Privacy@Transcarent.com with subject line “Privacy Request Appeal.” Please include in your appeal why you think we should revisit our decision.
Non-Discrimination Rights:we won't discriminate against you if your exercise any of the privacy rights described in this privacy statement.
Changes to Our Candidate Privacy Policy
We may change this Policy at any time. If we do, we will update the date at the top of this document. We will also note major changes in the table below with the effective date of each prior version noted in the left column. This table is intentionally blank now as this is the first version of this Policy.
Previous Notice | Major changes made to the Notice |
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@transcarent.com.