Job Applicant Privacy Notice

Effective Date: August 27, 2024

1. Scope and Overview

This Privacy Notice describes how Safelite Group, Inc. (“Safelite,” “we,” or “us”) collects and uses personal information about you during the application and recruitment process. It also describes our expectations for those who collect and manage our job applicants’ personal information within our organization.   

California Residents. If you are a California resident, please review the Additional privacy information for California residents section below, for additional California-specific disclosures.

2. Collection of Personal Information

For purposes of this Privacy Notice, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include data where your identity has been removed so that we can no longer identify or associate it with you (“anonymous data”). We may use anonymous data for any purpose.  

• Personal contact details such as name, title, addresses (both current and former), telephone numbers, government issued identification numbers, and personal email addresses.

• Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application.

• Education information including degrees awarded, transcripts, certifications, professional licensure, and other information provided in support of the job application.
  

• Motor vehicle driving records.

• Information collected during phone screenings and interviews, both of which may be recorded.

• Information available publicly.

• Social media profile(s).

• Geolocation.

• Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.

• Reference information and information received from background checks, where applicable, including information provided by third parties.

• Drug test history and results.

• Criminal conviction history and related details

• Application system username, password, and other unique identifiers

• Information related to previous applications with us or previous employment history with us.

• Current personal or professional skills such as languages spoken, as well as skill sets determined through assessment tools and programs.

• Certain relevant health information such as COVID vaccination status. 

• Demographic information such as age, date of birth, gender, race, national origin.

We may collect personal information directly from you, as a job applicant. We may also collect information from third parties including, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. We may also collect information from our systems that you use. 

Failure to provide or allow us to use personal information required for our recruiting activities may affect our ability to accomplish the purposes stated in this Privacy Notice. 

3. Use of Personal Information

We may collect and use your personal information for recruiting and hiring purposes as well as onboarding you as a new employee if you are hired. Examples of how we may use such information include the following:

• Identifying and evaluating job applications, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
• Verifying your information and carrying out employment, background, and reference checks, subject to your consent where required by applicable law.
• Communicating with you about the recruitment process and your application.
• Verifying your eligibility for employment and, if applicable and required, supporting you with obtaining a work permit or visa.
• Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
• Onboarding you as a new employee, upon acceptance of an offer for employment and satisfaction of the background and drug test requirements.
• Analyzing and improving our recruitment, application, and onboarding practices.
• Creating and submitting reports as required by applicable laws or regulations.
• To comply with our legal, regulatory, or other corporate governance requirements.

In addition to using your personal information for the position for which you have applied, we may retain and use your personal information to inform you about and consider you for other positions that may be appropriate for you, with your consent. If you want to opt-out of us considering you for other positions, you may contact us as specified below under Contact Us

We may also use your personal information for our own legitimate business purposes, including, without limitation, for the following purposes:

• To prevent fraud.
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
• To ensure physical security of our personnel, offices, stores, and equipment.
• To evaluate or facilitate business transactions such as a merger, acquisition, or asset sale.

We may collect and process the following sensitive personal information when you voluntarily provide it, or we receive them from a third party with your consent, when relevant for a particular position to carry out our obligations under employment law, or as applicable law otherwise permits:

• Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.
• Race or ethnic origin to comply with statutory obligations.
• Previous criminal charges or convictions where relevant for the position.
• Citizenship or Immigration Status to determine eligibility to work and/or for sponsoring applicants or associates for work visas and/or citizenship.

Where we have a legitimate need to process sensitive personal information about you for purposes not identified above, we will only do so in compliance with applicable law.

4. Personal Information Disclosure

We disclose your personal information to third parties where required by law or to our employees, contractors, designated agents, or service providers who require such information to assist us with administering the recruitment process, including service providers who provide services to us or on our behalf. We may use service providers for various purposes, including, but not limited to, obtaining employment verification and background checks, drug testing and data storage or hosting. These service providers may be located outside of the country in which you live or the country where the position you have applied for is located.

We do not permit our service providers to process your personal information for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.

We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:

• To other members of our group of companies and also our clients, who are third party entities, (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
  
• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. 
  
• To protect our rights and property and the rights of property of our subsidiaries, affiliates, and parent company.
  
• During emergency situations or where necessary to protect the safety of persons.
  
• Where the personal information is publicly available.
  
• If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. 
  
• For additional purposes with your consent where such consent is required by law.

We do not sell personal information of job applicants to third parties.  However, we purchase personal information from other businesses, for example job boards, for purposes of viewing contact information of potential candidates who have opted into a program offered by such businesses to match candidates and potential employers, like Safelite.  Examples of the types of information Safelite would purchase access to include Identifiers such as name, email address, phone number, home address, as well as Customer Record Information such as employment and educational information, and anything put on a resume by a candidate.

5. Data Security

We use reasonable physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

6. Data Retention

We keep your personal information for as long as needed or permitted considering the purpose(s) for which it was obtained.  The current retention period for Recruiting Records, which includes documents such as Announcements, Background Check Results, Candidate Evaluations, Consent to Request Consumer Report Information Forms, Help Wanted Ads, Internal Postings, Interview Notes, Job Orders, Job Postings, Personnel Requisitions, Reference Checks, Rejected Employment Applications, Rejected Resumes, Release of Information Forms, Skills Assessment Test Results, Drug Screening Records is ten years from the end of the calendar year.  The current retention period for Personnel Files which includes records such as Address Changes, Employment Documentation, College Transcripts, Continuing Education Records, Employee Goals and Objectives, Employee Relocation Records, Employment Applications, Job Evaluation Documents, Employee Accidents and Injuries, Letters of Acceptance, Payroll Information, Performance Appraisals, References is eight years after termination of employment.  The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). 

If you are offered and accept employment with us, the personal information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal information policies. If you do not become an employee, or, once you are no longer an employee of us, we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations. 

7. Updating Your Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your during the application process. If you are concerned that we may have incorrect personal information about you or want a copy of the Background Check Policy available to associates in the People Guide, please contact us at peopledirect@safelite.com. Any such communication must be in writing. However, you are responsible for updating your personal information through systems made available to you, e.g. Workday or online job application portals.  

8. Additional Privacy Information for California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide the following notice to job applicants who are California residents. 

The information we collect from California residents is described in the Collection of Personal Information above for the purposes described in Use of Personal Information above. That information corresponds with the following categories of personal information under the CCPA.

We also collect “Sensitive Personal Information” as defined under California law, including: Social security, driver’s license, state identification card, or passport number 

9. Selling and Sharing Personal Information

We do not sell or share for cross-context behavioral advertising purposes the personal information we collect under this Privacy Notice including personal information of persons under 16 years of age. We also do not disclose personal information collected under this Privacy Notice to third parties who are not our service providers for our commercial purposes; however, we do share personal information with our third party clients who audit us as for compliance with contractual and legal obligations. 

10. Non-Discrimination

We will not discriminate, including by taking retaliatory measures, against any person who exercises privacy rights under applicable law or this Privacy Notice.

11. Applicant Tools

As of the Effective Date of this Privacy Notice, we use an applicant screening tool which may or may not qualify as an Automated Employee Decision Tool (AEDT), as defined in New York Law 144 (2021) If the link does not launch when clicked, then copy and paste the following into your address bar: https://rb.gy/zfkcz.  Due to a substantial lack of clarity in New York Law 144 and how businesses are expected to comply, we will not use the screening tool for applications submitted by job applicants in New York, New York.  An application for all other locations is not considered complete and ready for submission and review by us until the screening tool is completed.   

The screening tool does NOT collect any Personal Information about you as an applicant.  The purpose of this screening tool is to provide Safelite an additional data point in an overall analysis to determine if a job applicant for an auto glass installation technician role is a good fit for employment at Safelite in comparison to an ideal candidate profile. To be clear, an applicant will neither be automatically extended an offer nor rejected based solely on their score using the screening tool. 

Additionally, as of the Effective Date of this Privacy Notice, we use an interview summary tool that records the conversation between a Safelite interviewer and you.  The tool then transcribes the conversation, redacts certain pieces of sensitive personal information, summarizes your responses and displays the summary to the interviewer for editing and correction based on the interview.  The purpose of the tool is to allow the interviewer to be more engaged in the discussion instead of writing notes; therefore, the tool does not produce a score or recommendation with respect to your application or interview.  You have the option at the start of your interview to decline the use of this tool.  Safelite will rely on its existing legally compliant processes and procedures to evaluate candidates’ suitability for open positions.

12. Changes to This Privacy Notice 

Email: peopledirect@safelite.com

Mailing Address: