Recruitment Privacy Notice North America

Notice at Collection to California Residents Under the California Consumer Privacy Act (CCPA) And California Privacy Rights Act (CPRA)

Hakluyt & Company Limited and its subsidiaries and/or affiliates (the “Company” or “we”) provide this notice to job applicants who reside in California (“you”) in accordance with the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”).

The Company will collect and retain certain personal information about you during the job application process. The purpose of this notice is to provide you with notice about the categories of personal information collected about you, the purposes for which your personal information is collected or used, and whether your personal information is sold or shared, so that you have a tool to exercise control over the Company’s use of your personal information.

The Company will collect the following categories of personal information and sensitive personal information from you: 

• Identifiers, such as your name, alias, postal address, email address, social security number, driver’s license number, state identification card number, passport number will not be sold or shared. If you are not hired, we will retain this information for up to six years. If you are hired, we will retain this information for the duration of your employment, plus 5 years.   

• Audio, electronic, and/or visual information, such as your photograph or image when recorded on Company surveillance cameras, or captured at Company events, your voice or image when captured on recorded meetings after being given prior notification will not be sold or shared. Surveillance camera footage is retained for 180 days; other data is retained for the duration of employment plus 5 years. 

• Pre-employment-related information, including information contained in your resume, application, background check, and interview notes will not be sold or shared. If you are not hired, we will retain this information for up to six years. If you are hired, we will retain this information for the duration of your employment, plus five years.   

• Education information, such as information regarding your degrees, field of study, prior educational institutions attended will not be sold or shared. If you are not hired, we will retain this information for up to six years. If you are hired, we will retain this information for the duration of your employment, plus five years.   

• Inferences, including Inferences drawn from any of the information collected about you to create a profile regarding your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes will not be sold or shared. If you are not hired, we will retain this information for up to six years. If you are hired, we will retain this information for the duration of your employment, plus five years.   

Of the above categories and examples, the following is considered sensitive personal information: 

1. Identifiers (social security, driver’s license, state identification card, or passport number) 

The following is NOT considered personal information under the CCPA/CPRA: 

1. Publicly available information, including information that is lawfully made available from federal, state, or local government records, information that is lawfully made available to the general public by a consumer or from widely distributed media, and information made available by a person to whom a consumer had disclosed the information if the consumer has not restricted the information to a specific audience.  
2. Lawfully obtained, truthful information that is a matter of public concern. 
3. Deidentified or aggregate consumer information. 

The Company collects and uses your personal and sensitive personal information for the following business purposes:

1. To fulfil the purpose for which you provided the information.
2. To comply with applicable laws, court orders, or government agencies/regulations.
3. To facilitate your application process with the Company, including for purposes related to facilitating the interview process and evaluating your application.
4. To verify and respond to consumer requests.To communicate with you regarding your application and prospective employment.

The Company does not sell or share your personal or sensitive personal information as defined under the CCPA/CPRA. 

The Company retains your personal information and sensitive personal information as reasonably necessary to achieve the business purposes for which it is collected as outlined above and as required by applicable laws and relevant statutes of limitation. The Company retains the information collected about you in accordance with the retention periods in the chart above.  

The Privacy Policy is posted on the Company’s website and may be accessed here.  

Should you have any questions about this Notice, please contact our HR Manager, Kaitlin Moore.