Barry-Wehmiller Group
Career Privacy Notice – 2 August 2021

1. Introduction

This Privacy Notice describes how Barry-Wehmiller Group, Inc., and its subsidiaries, affiliates and related companies (together “the Company”, “we” or “us”) processes Personal Data of applicants (“Candidates”) in recruitment. In addition to Candidates, this Privacy Notice also includes referrers who support the Candidate’s application. Separately, the Team Member Privacy Notice describes how we process Personal Data of Candidates who have become employees.

In this Privacy Notice, Personal Data refers to any information relating to an identified or identifiable person. The primary “data controller” is the legal entity that intends to employ the Candidate. This Privacy Notice covers all processing of Personal Data of Candidates, regardless of whether Personal Data is in paper or digital format.

We collect Personal Data directly from Candidates. We may also proactively conduct research about Candidate’s educational and professional background. Further, we may receive Personal Data from other sources, including for example recruitment agencies, Candidate’s referrers, previous employers, or other parties providing information related to background checks or assessments.

2. What Personal Data is Collected and How It Is Used

The following list describes the typical purposes that Personal Data is used for, and the typical categories of Personal Data that may be processed for those purposes. Other categories of Personal Data may also be processed if necessary for those purposes, and in compliance with applicable law.

The purposes and the categories of Personal Data that are processed vary depending on local practices and local law. In practice, in most countries only some of the categories listed below are processed. Both the purposes as well as the categories must be in compliance with applicable law.

2.1 Categories of Personal Data

Categories of Personal Data may typically include the following:

• Name and contact details;
• Cover letter, profile in LinkedIn or other corresponding platform, CV/resume;
• Information about education, skills, assessments, qualifications, professional certificates, experience and job history;
• Type of employment sought, desired salary and working hours, willingness to relocate or travel, and other possible job preferences;
• Depending on local practices, Candidates may also provide their date of birth, photo, marital status or other information related to Candidate or their family;
• Gender, nationality, eligibility to work, immigration status, work visas and related information;
• Information related to background checks, including, for example, reference checks, job history validation or verification of driver history (when required for the role);
• Careers site login and usage details;
• Referrer names and contact information. By providing these, the Candidate confirms that referrers are aware and consent to their Personal Data being provided to us;
• In compliance with applicable law, in some countries the following information may also be collected: ethnicity, disability, veteran status, drug tests results or criminal background checks.

2.2 How Personal Data is Used

Personal Data is used for Recruitment related activities, including the following:

• Assessing Candidate’s skills, qualifications and interests against our career opportunities;
• Verifying Candidate’s information, carrying out reference checks, and conducting background checks;
• Communicating with the Candidate about the recruitment process and the application, as well as informing the Candidate of other potential career opportunities with us;
• Creating and submitting reports as required under applicable law;
• Assisting the Candidate to obtain an immigration visa or work permit, where required;
• Analyzing and developing our recruitment process and practices as well as the Careers site;
• Fostering our diversity and inclusion programs and practices, in compliance with applicable law;
• Complying with applicable laws, regulations, legal obligations and enforceable governmental requests, and protecting our rights and property.

3. Sharing and Transfer

3.1 Internal Sharing within the Company

Personal Data may be shared within the Company when necessary. Personal Data may be accessed and processed, when necessary for the purposes described above, by our relevant team members. Typically these include the following:

• The Recruitment team and other relevant team members within Culture and People Development;
• Hiring leader and approver;
• Interviewers;
• IT administrators.

3.2 External Sharing

When necessary, Personal Data may also be shared with external parties or third-party service providers, including, for example, software and cloud providers, skill assessment vendors or drug test vendors, in order to process Personal Data on our behalf.

3.3 International Transfers

Personal Data may be stored, transferred to, and processed in any country where we have team members or facilities or in which we engage service providers, including in the United States of America. We implement appropriate safeguards (e.g., Standard Contractual Clauses) to protect Personal Data as required when transferred, including transfers outside the European Union (EU) and European Economic Area (EEA).

4. Legal Basis and Retention

Processing of Personal Data is mainly based on the following bases: in order to take steps prior to entering into an employment contract or agreement between the Candidate and the legal entity that will be the Candidate’s employer; for compliance with legal obligation; for legitimate interests of the Company (especially in relation to sharing within the Company); in order to protect the vital interests of the Candidate or another person; or, with consent.

Personal Data will be retained in accordance with the attached retention schedule, or as long as reasonably necessary for the purposes in accordance with applicable legislation.

5. Information Security

We implement and maintain industry standard technical and organizational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, access or unauthorized disclosure. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and the nature, scope, context and purposes of processing of Personal Data.

6. More Information

Candidates may contact us for more information on how their Personal Data is collected, used, and disclosed. Candidates may also request copies of, rectification of, or deletion of their Personal Data, when applicable. Depending on the applicable legislation, Candidates may also have other rights, as well as a right to lodge a complaint with an applicable supervisory authority regarding how their Personal Data is used. (In case the applicable supervisory authority is in Europe, the contact details can be found here: https://edpb.europa.eu/about-edpb/board/members_en and https://ico.org.uk/.)

If a Candidate has given their consent to retain Personal Data longer in the Candidate Pool, but wishes to withdraw their consent, that can be done at any time by logging onto the Careers site.

For recruitment related inquiries, Candidates should contact their recruiter.

For formal requests under applicable data protection legislation, Candidates may contact the Group Data Protection Officer in the following ways:

By email: dataprotection@barry-wehmiller.com

By post to: Group Data Protection OfficerLegal Team Barry-Wehmiller Group 8020 Forsyth Blvd St. Louis, MO 63105 United States of America

7. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. Any changes will be communicated in the Careers site.

California Addendum to Barry-Wehmiller Career Privacy Notice

Last updated: 20 February 2023
Version: 1.0

1. Introduction

This California Addendum to the Barry-Wehmiller Group, Inc. (the “Company”)Career Privacy Notice describes the Company’s practices regarding the collection, use, and disclosure of the Personal Information of applicants in recruitment who are California residents (“California Candidates”), describes the rights of California Candidates under the California Consumer Privacy Act (“CCPA”), and explains how California Candidates may contact the Company to exercise their rights, if applicable (the “Addendum”).  This Addendum supplements the Barry-Wehmiller Career Privacy Notice above.

Individuals who have a disability may be able to use a screen reader or other assistive device to review the contents of this Privacy Notice. If you require additional assistance, contact the recruiter responsible for your selection process, and advise of a request for disability assistance.

2.    Personal Information Collected under the CCPA

Within the last 12 months, we have collected the following categories of Personal Information from California Candidates:

• Identifiers: an individual’s name, contact details, IP address
• Customer records: contact details
• Protected classification characteristics: characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression). This information will be collected only if provided directly by California Candidates within the selection process.
• Internet or other similar network activity: login details, log data and information about the usage of systems and other devices, for example our career portal.
• Geolocation data: IP address
• Professional or employment-related information: current or past job history
• Inferences: information from assessment tests
• We do not use or disclose sensitive Personal Information to “infer” characteristics as defined under the CCPA, or for any purpose other than that which is necessary to assess your viability as a Candidate.

3.    Sales and Sharing of Personal Information

We do not sell your Personal Information, including within the preceding 12 months.

We do not share your Personal Information for purposes of cross-context, targeted behavioral advertising, including with the preceding 12 months. 

4.    Retention Periods

Personal Information will be retained in accordance with applicable records retention policies of the Company (please, consult Appendix 1 of this Career Privacy Notice), or as long as reasonably necessary for the purposes in accordance with applicable legislation, whichever is longer.  The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you are an employee) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

5.    Your Rights and Choices

The CCPA provides you, as California residents, with specific rights regarding your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

• Right to Know - In certain circumstances, you have the right to request the Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months.
• Right to Delete - You may have the right to request the Company delete your Personal Information that we collected from you and retained, subject to certain exceptions.
• Right to Correct – You may have the right to request the Company to correct any inaccurate Personal Information we may hold about you.  We will use commercially reasonable efforts to correct inaccurate Personal Information, taking into account the nature of the Personal Information and the purpose for our processing.
• Right to Non-Discrimination – We will not discriminate against your for exercising any of your rights.

6.    Exercising Your Rights

To exercise the rights described above, please submit a request to us by one of the following methods:

• Via email at: dataprotection@barry-wehmiller.com
• Via post at:
  Group Data Protection Officer
  Legal Team
  Barry-Wehmiller Group
  8020 Forsyth Blvd
  St. Louis, MO  63105
  United States of America

7.    Changes to this Addendum

We may update this Addendum from time to time.  Any substantive changes will be notified to you via the Careers site.

8.    Questions About This Notice

If you have any questions about this Addendum, the ways in which the Company collects and uses your information described in this addendum  and in the Barry-Wehmiller Career Privacy Notice above, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact via email at dataprotection@barry-wehmiller.com or via post as noted above.

APPENDIX 1

Retention schedule applicable to Personal Data collected on or after 2^nd August 2021.