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PURPOSE: The intent of this policy is to identify the ways New Chapter gathers, uses, discloses, and manages an applicants data.
Scope and Overview
This Employee Candidate Privacy Notice (“Notice”) describes how New Chapter, Inc. (“New Chapter,” “we,” or “us”) collects and uses, Personal Information during the employment application and recruitment process. This Notice applies to job applicants only and applies to all employment positions to which you apply. For purposes of this Notice, the term “Personal Information” refers to any information, or a combination of pieces of information, that allows you to be identified, and that is subject to, or otherwise afforded protection under, an applicable data protection law, statute, or regulation.
This Notice describes the categories of Personal Information we collect, how we use and retain that Personal Information, and when we may disclose your Personal Information to third parties. We will only use your Personal Information in accordance with this Notice, unless otherwise required by applicable law. We will take steps to ensure that the Personal Information we collect about you is adequate, relevant, not excessive, and used for limited purposes.
If you do not provide us the Personal Information that is necessary for us to consider your application (e.g., evidence of qualifications or work history), then we will not be able to process your employment application.
Collection of Personal Information
New Chapter may collect Personal Information from you (i.e., the candidate), our recruitment vendors, background and credit check providers, public agencies responsible for assisting in the employment eligibility and verification process, publicly available sources, and your identified references. We may collect and process the following categories of Personal Information about you:
- Contact information including name, title, residential or postal address, telephone number, and personal email address.
- The information in your curriculum vitae (“CV”), resume, cover letter, or similar documentation, or during the course of your interview or other engagement with us.
- Details regarding the type of employment sought, willingness to relocate, as well as job, compensation, and benefits preferences.
- Information related to your background, criminal record, credit history and similar data.
- Information provided by your references, or other third parties, related to your employment history, skills, or qualifications.
- Information related to previous applications to New Chapter, or previous employment history with New Chapter.
- Potentially sensitive information including information about your race, ethnicity, national origin, health, including, but not limited to, any medical condition, health, or sickness records, and data about your criminal convictions and offenses.
Collection of Other Information: For information regarding how we collect information on our website or other online services, including when if submit your application online, or during any other business or professional relationship with us, please visit our website privacy statement available at https://www.newchapter.com/privacy-policy/.
How We Use Personal Information
We use your Personal Information, as applicable law permits, or requires, to satisfy our employment application and recruitment process, or for our other legitimate business interests. For example, we may use your Personal Information for the following purposes:
- Identifying and evaluating job applicants, including assessing skills, qualifications, and interests.
- Verifying your information and completing employment, background and reference checks, which may be subject to your consent where required by applicable law.
- Communicating with you about the recruitment process and your application.
- Complying with our legal, judicial, regulatory, administrative, or other corporate requirements, including, but not limited to, requirements mandating that we conduct criminal record, or other background checks.
- Analyzing and improving our application and recruitment process.
- Accommodating individuals who may have specialized needs during the employment process.
- Protecting the rights, interests, and property of New Chapter, other job applicants, employees, or the public, as required, or permitted, by law.
We will only use your Personal Information in accordance with this Notice, and we do not sell your Personal Information for any business reason. If we need to use your Personal Information for an unrelated purpose, we will, to the extent practicable, provide notice to you and, if required by law, seek your consent. We may use your Personal Information without your consent, where permitted by applicable law or regulation.
New Chapter does not undertake any decision-making concerning its employment activities solely by automated means and without any human involvement.
We will disclose your Personal Information within New Chapter to appropriate officials who are involved in the employment application and recruitment process. We may also disclose your Personal Information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks. We will share your Personal Information with third-parties when required to do so by law, or by regulatory requirements to which you, or we, are subject. We may share Personal Information where it is necessary to administer our working relationship with you, or where we have another legitimate business interests in doing so, such as where it is necessary for the operation of our business or defend our business or legal interests.
We may also share your Personal Information with potential acquirers or investors of New Chapter, or the business area in which you work. We may share your Personal Information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some, or all, of New Chapter’s practice or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by New Chapter, in any form or format, is among the assets transferred.
We Do Not Sell Your Data
We do not sell or rent Personal Information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of Personal Information because we do not engage in those practices.
Data Location and Retention
New Chapter is headquartered in Vermont, United States, and has locations across the United States and in Canada. The information (including personal information) that New Chapter collects and processes is stored in the United States and Canada. If you are located outside of the United States or Canada, please be aware that information you provide to New Chapter will be transferred to the United States or Canada, and that the United States and Canada may not provide the same level of protections as the laws in your country. New Chapter does not participate in the Privacy Shield Frameworks. By continuing to provide us such information you hereby consent to your Personal Information being transferred to, and stored in, the United States or Canada. New Chapter retains employee records in accordance with industry standards. If you have any particular questions regarding our data retention practices, please contact us in accordance with the instructions below.
Data Protection Rights
Depending on the jurisdiction in which you reside, or where New Chapter conducts its data processing activities, you may be afforded additional rights or privileges under certain applicable data protection laws. Schedule 1 sets forth additional data protection rights or privileges that may apply to you.
With regard to any Personal Information that you provide New Chapter, regardless of whether that Personal Information relates to you or a third-party, you must ensure, on a continuing basis, that (i) such Personal Information is accurate, relevant, and complete, (ii) you have the lawful basis to provide New Chapter with such Personal Information, and (iii) you have provided this Notice to, and/or received, consent from, any third-party whose Personal Information you have provided New Chapter. If you choose not to provide us with the Personal Information identified herein, then New Chapter may not be able to satisfy our own contractual or legal obligations, and, in such circumstances, employment with New Chapter may not be permissible. You acknowledge and agree that New Chapter shall not be held liable for any consequence directly resulting from these circumstances.
If you have questions, concerns, or comments related to how New Chapter processes your Personal Information, including whether you would like to exercise the rights and privileges described herein, please use our website contact form located at https://www.newchapter.com/.
Amendment Date: This Notice was last amended on 1-1-20.
JURISDICTION SPECIFIC DATA PROTECTION RIGHTS
If your Personal Information is subject to, or afforded protection under, any of the following data protection laws, then you are entitled to receive notice of the following:
The California Consumer Privacy Act of 2018
The California Consumer Privacy Act of 2018, as amended, (“CCPA”) requires certain businesses that collect Personal Information on California consumers (as defined in the CCPA) to, at, or before the point of collection, inform consumers as to the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used. The types of Personal Information that New Chapter collects from its employment candidates, and the purposes for which such Personal Information is used, are set forth in this Notice. We do not sell or rent Personal Information that we have collected or retain about you to any other third-party.
Review Frequency: As needed.
Stewardship: New Chapter reserves the right to amend these policies when needed. All policies that have a material fiduciary impact on the firm are reviewed and approved by the New Chapter’s Head of Finance, Head of Human Resources and appropriate members of P&G leadership. All major policy creation and revisions are reviewed and approved by the Executive Leadership Team. Periodic revisions and updates to policies that do not represent a material change are reviewed and approved by the Head of Human Resources.
This contains only general information and is not intended to address all the possible policies, procedures, and work rules. This supersedes all past policies and/or standards, written or verbal, expressed or implied; it is not a contract of employment or written agreement of any kind. Managers and employees are encouraged to reference the most current version of our Employee Handbook policies by accessing them on-line at the New Chapter Employee Benefits Center site or by contacting their manager or Human Resources.
Where policies or employment practices differ in Canada, we will follow the Canadian Employment Standards Act. Canadian employees’ benefits are not identical to those for US employees, and we will follow the Canadian regulations where warranted.