Employee Applicant Privacy Notice in the E.U.
Data Privacy Notice for Prospective Employees in the European Union and the United Kingdom
This Notice describes Fordham University’s practices concerning the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation (GDPR) and GDPR U.K. to recruit and evaluate prospective employees and process employment applications. This Notice applies to Fordham and its affiliated legal entities and branches (collectively “Fordham,” “us,” or “our”) solely concerning prospective employees of Fordham’s sites in the European Union (the “Sites”). All such prospective employees (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.
“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
Additional notices at any data collection point may supplement this general Notice. If you have specific questions about any data processing activities described in this or any other Notice, please contact the Office of Legal Counsel.
The Information We Process About You
We process the information we collect from you directly, either during our communications with you about Fordham or as part of your application for employment at Fordham.
During the application process, we will indicate when certain information is required for Fordham to process your application. Failure to complete a required field may result in your application being denied or your offer of employment rescinded.
We use automated decision-making processes to screen applicants according to predetermined criteria. For example, we may use an automated process to review your resume for key terms associated with the job you have applied for. You can learn more about the logic we use in our automated decision-making processes by contacting Fordham University in London.
In addition, we collect the following kinds of information about you from third parties:
- Publicly available information we collect from third parties, your contact and demographic information. Any criminal convictions or offenses, information about your credit, and other information about your previous employment and education, which we collect as part of a background check process (where permitted by applicable law) from government records, credit reporting companies, your previous employers, and other academic institutions
- the purposes of the processing,
- the categories of Personal Information concerned,
- the recipients or categories of recipients to whom the Personal Information has been or will be disclosed,
- where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.
Purposes and Legal Basis for Processing Your Data
We process your Personal Information to recruit prospective employees, evaluate applications for employment at Fordham, evaluate your employment eligibility, communicate with you about Fordham and your application, and, if you are offered a position at Fordham, manage your acceptance of our offer of employment and begin the process of onboarding you as a new employee. We also use data to make strategic decisions about Fordham programs or course offerings, administer those programs, file required reports with applicable governmental authorities, and engage in financial planning. We also use your data for purposes required by law, including complying with applicable retention requirements and enforcing Fordham policies and applicable laws.
We combine the data that we collect to provide these functions.
We have the following legal basis for processing the information you provide in your application or that we collect about you during the application process.
We have a legitimate interest in recruiting and hiring qualified applicants, complying with laws and regulations that govern our conduct in the countries where we operate, and administering Fordham and its programs efficiently, ethically, and appropriately. We process all the information we collect from or about you to meet these purposes. You can obtain additional information about our legitimate interests in processing your data by contacting Fordham University in London.
Once you have accepted an offer of employment from us, we may also be required to process your Personal Information to complete a contract that you have entered with us, including a contract of employment or an agreement to receive certain other benefits. You can obtain additional information regarding the processing we do to enter into contracts with you by contacting Fordham University in London.
We may also be required to process your Personal Information to comply with laws applicable in the United Kingdom, European Union, or its member states. You can obtain additional information about our processing to comply with applicable laws by contacting the Office of Legal Counsel.
In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. For example, in certain jurisdictions, we are required to collect information about your disability status to comply with legal mandates to hire a certain number of disabled employees. You can obtain more information about these laws by contacting the Office of Legal Counsel.
When we process your Sensitive Personal Information based on your consent, you may withdraw that consent at any time by contacting the Office of Legal Counsel. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law. However, we will explain what processing activities will continue for legal compliance purposes when your consent is withdrawn.
Finally, we process your Personal Information for purposes compatible with those already described, including for conducting scientific, statistical, or historical research or for creating archives in the public interest. Where possible, we do not use identifiable information for these purposes, or we take steps, including using pseudonymous data, to limit the amount of Personal Information we use in our research or archives.
Recipients of Your Personal Information
Your Personal Information will be received and processed by Fordham employees and personnel, including third parties who provide services to Fordham in connection with the purposes of processing described above, including background-check providers, service providers that support our application software and other programs, and service providers that support our human resources and hiring functions. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. We provide Personal Information to printers and mailing houses, professional organizations, and third-party organizations who assist in verifying your credentials. You may contact Fordham University in London to learn more about the categories of service providers your data is disclosed.
We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.
Transfers to Third Countries
Fordham is a global university headquartered in the United States. We transfer your data to the United States and the countries where we operate. Fordham offers study abroad programs at international sites outside of the E.U. If you apply for employment at one of our E.U. or U.K. sites, your data will be accessed by our headquarters in the United States and the applicable E.U. or U.K. site as appropriate to evaluate your employment application.
You can find more information about how long we retain personal data by consulting our Records Retention and Disposal Policy. Certain E.U. sites may retain data for shorter or longer periods to meet local legal requirements or business practices. You can obtain additional information about these retention periods by contacting the Office of Legal Counsel.
You have the right to the following information regarding Fordham’s processing of your Personal Information:
You also have the following additional rights concerning your Personal Information:
- The right to request access to the Personal Information that Fordham has about you, as well as the right to request rectification of any inaccurate or incomplete data
- The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties or to request that Fordham directly transfer your Personal Information to one or more third parties
- The right to object to the processing of your Personal Information for marketing and other purposes
- The right to the erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible
- The right to lodge a complaint with the supervisory authority in the country where you live or work or where you believe that your rights have been violated
These rights may be exercised through the GDPR Data Request Process.
You can contact Fordham University’s Office of Legal Counsel with questions about this Notice, our data collection practices, or your rights.
Rose Hill Campus
441 East Fordham Road
Cunniffe House, Room 111
Bronx, New York 10458
+1 718 817 3110
Email: [email protected]
Fordham University in London’s local contact is:
Vanessa Beever, Senior Director
Fordham University in London
2 Eyre Street Hill
London EC1R 5ET
Phone: +44 20 3687 2950
Email: [email protected]