Last updated 25th August 2023
This Candidate Privacy Notice provides job applicants with information about the processing of Candidate related information (“Candidate Information” or “data”) during the recruitment and selection process at Circana Inc, the Circana Group LP and our subsidiaries and affiliate companies which may include companies known as IRI, NPD or Circana (“the Circana Group”,”Circana” “we”, “our” or “us”) which may be located anywhere in the world. This Candidate Privacy Notice explains:
the information we collect when you apply for a position with us and how we use it
- the types of information we may share with others and under what circumstances
- how we protect your information
- how to correct information that personally identifies you
- additional disclosures for residents of the European Economic Area (“EEA”) and Switzerland.
When This Candidate Privacy Notice Applies
This Candidate Privacy Notice applies to information collected when individuals express interest in being employed at any company within Circana. This includes data collected when an individual visits a Circana, IRI or NPD website to review job postings, as well as information submitted by an individual during the application process.
In certain circumstances, you may submit your application for employment through a third party service that displays our job posting (such as LinkedIn). Circanadoes not control the privacy practices of these third party services. Please review their privacy notices carefully prior to submitting your application materials.
This statement does not form part of any contract of employment, nor does it cover the processing of other data that may occur in the context of employment, if we make and you accept an offer to join our team. We encourage you to read this notice carefully and understand its contents. If you have any questions, please see the “Contact Information” section below for how to get in touch with us.
Information We Collect And Why
The information we collect during the recruitment process and how we use that data may vary, depending on the jurisdiction where the position is based, and provision of all information may not be mandatory. To the extent any collection or use conflicts with a legal requirement or prohibition, then the Company will follow the applicable law. We refer to this type of information as “Candidate Information.” Candidate Information may be collected in multiple ways: you may provide it to us in connection with your application; we may make observations in the application process or collect information from public information sources; or you may authorize us to collect information from other sources, such as a former employer or reference. We also may collect information through cookies when you visit our website. Information we collect, and the uses for that information, may include:
Identifiers, including
- Contact information, such as your name, alias physical address, telephone numbers, and email addresses. We use this information to open and track your Candidate file and communicate with you.
- Identifiction and other Sensitive data such as your date of birth, country of birth or the country where you are a registered national or citizen, nationality/visa status, passport number, social security number, driver’s license number and signature,disability, gender identity, race, military/veteran status, medical conditions and sexual orientation (to the extent such information is collected or provided, for example, through voluntary self-identification). We use this information (at the time and manner and to the extent permitted or required by law) to address our legal obligations to you, to determine your eligibility to work, to verify your identity and fulfill our obligations to relevant government authorities, to make any adjustments required to assist you in the interview process, and to conduct meaningful equal opportunity and diversity monitoring and analyses, where permitted or required by law We do not use or disclose Candidate sensitive personal information for purposes except as described herein and as permitted by law
- Professional or other employment-related information, including:
- Job qualifications and related information, such as the position applied for, previous job roles, descriptions of your skills and experience, education, awards, qualifications, certificates, licenses, and any other information you choose to provide in your resumes and/or applications. We use this information to determine your qualification and selection for jobs, and potential conflicts of interest.
- Professional or other membership information, such as your membership in professional bodies and trade groups. We use this information to determine your qualification and selection for jobs.
- Travel related information, such as frequent flyer numbers, TSA known traveler numbers, itineraries, flight, train, rental car, car service, hotel or other similar information. If you are traveling during the application process, we use this information to facilitate your business travel, including to arrange or reimburse travel, to contact you during travel, as necessary with travel service providers, or in an emergency situation.
- Financial information, such as your bank account details. We use financial information to process any agreed expense claims and to comply with legal obligations.
- Results of background checks and screening, successful candidates may be subject to background checks, such as education verification, previous employment, criminal records and driver license checks (at the time and manner, and to the extent permitted or required by local law). We use this information to determine your suitability for employment including for certain job roles and to determine your eligibility for certain potential benefits. We may also collect background data from public third party sites and may not seek your specific consent where not required by law.
- References, such as opinions and comments of any previous employers. In connection with our evaluation of your application, we may request specific permission to seek information about you from third parties. This may include information regarding your work habits, performance in prior roles, and fitness for employment. We use reference information we receive to determine your suitability for certain job roles and to fulfill our obligations to regulators (including demonstrating the suitability of employees for their role to regulators and professional bodies).
- Salary and compensation information. We use salary and compensation information you provide to us and/or we obtain through the Candidate process (at the time and manner and to the extent permitted or required by law) to determine compensation offers and to benchmark our practices.
- Surveys, such as feedback and opinions as part of voluntary surveys. We use such information to understand what Circanais doing well and what it can improve upon within the Candidate journey. Your response to these surveys is optional and will have no bearing on the selection process for any vacancy at Circana. When you provide a response to a non-mandatory question, you are consenting to the collection and storage of that information by Circana.
- Internet or other electronic network activity information, and audio, electronic, visual or similar information, including:
- Website Interactions. When you interact with our website, certain information about your use of this Site is automatically collected. Much of this information is collected through cookies (excluding retargeting cookies), web beacons, and other tracking technologies, as well as through your web browser or device and includes:
- Details of your visits to our site and information generated in the course of the use our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site
- Details regarding the device you use to access our website or digital services, including where available your IP address, operating system and browser type
- Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our services or choosing to log in through a social media account), including your account ID or username and other information included in your posts
- Collection of this information may be performed on our behalf by service providers. Additionally, our websites use cookies. Our websites have separate privacy policies that explain the information collected, how it is used, and the choices you have.
- Other audio, electronic, visual or similar information to us, such as communications, documents or images that you create, provide or upload to our systems. CCTV footage, photographs, and call recordings and other audio recordings (e.g., recorded meetings)
- Inferences and Analytical Reports drawn from other personal information, such as analyses from Candidate Information used for improving our hiring processes.
Additional Uses Of Candidate Information
In addition to the uses set forth above, we may use and share the categories of Candidate Information:
- For consideration for other similar positions available within the CircanaGroup (if you provide your consent for us to do so)
- To comply with applicable legal and regulatory requests and obligations (including investigations).
- For health and safety purposes, such as contact tracing or conducting appropriate screenings of individuals prior to entering or accessing certain locations or premises
- For purposes of planning, due diligence and implementation of commercial transactions (e.g., mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions).
- To establish or defend legal claims and allegations.
- For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
- To seek advice from lawyers, auditors and other professional advisers.
Sources of Information
In general, we may collect Candidate Information from the following categories of sources:
- Directly from you
- Recruiters and recruiting platforms
- Employee referrals
- Publicly available information and sources
- Former employers
- Our service providers, representatives, and agents
- References you provide
When And With Whom We Share Information
We limit the information we share and disclose to others as described below:
- The Circana Group
We may share information about you with other companies within the Circana Group, especially the company that will ultimately be employing the successful candidate. They will also process your information in accordance with this Notice.
- Service Providers
In order to provide and support the evaluation process, we use carefully selected third party companies as service providers that work on our behalf to transmit, collect, process, or store information for us. We require these service providers adopt suitable technical and organizational measures to safeguard our information and to treat the information we share with them as confidential and to use it only for the purpose of providing the services for which they have been engaged. The categories of Service Providers with whom we work include:
– Vendors that assist with the application process, including assessing Applicant qualifications and providing the platform through which candidates submit their candidacy
– Auditing and accounting firms
– Professional services consultants, such as firms that perform analytics, assist with improving our programming, provide legal services, or supply project-based resources and assistance
– Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention
- Researchers
We may share Candidate Information with institutions where doing so would further an important research purpose. For example, some institutions are interested in exploring the relationship between certain academic degrees and backgrounds with the type of positions that such candidates seek at Circana. When we share information with researchers, Circana requires the researchers to agree to keep the personal information confidential. The researchers may publish papers or studies which include aggregated data aboutCircana’s candidates for employment, but may not publish any personal information that identifies a specific individual.
How We Protect Your Information
We have in place security measures to protect your Candidate Information from loss, misuse and unauthorised access, disclosure, alteration and destruction. The security measures are implemented and maintained in accordance with legal, organisational and technological developments.
Updating Candidate Information And Your Rights
Candidates retain control over most of their information that can be updated through Circana’s online candidate registration system and are able to (and expected to) self-serve amending, updating or deleting most information.
We observe the following rights for all Candidate Information and you will not to be subject to discriminatory treatment for exercising your rights:
- Right to Access – you have the right to request access to your personal information and additional information about the processing of your personal information (such as which parties it has been transferred to).
- Right to Correction- you are entitled to have any inadequate, incomplete or incorrect personal information corrected.
- Right to Object – you may object to our processing of your data. We only process Candidate Information where we believe have compelling reasons to process it, but we will always consider your objection and will stop processing it if we cannot demonstrate why we are processing it.
- Right to Withdraw Consent – you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. This means you would be withdrawing your application and could no longer be considered for employment for that role.
- Right to Deletion – in certain circumstances, you are entitled to have your information deleted. This applies where you have withdrawn your consent or where you object to our processing and we have no overriding legitimate reason to continue the processing.
- Right to Restriction – we will restrict the further processing of your data while the above situations are being investigated. We will only process restricted data with your consent or for the establishment, exercise or defense of legal claims.
Candidates of entities registered in the European Union and the UK may also be entitled to “Data Portability”, which means you may have the right to receive certain data which you have provided to us in a structured, commonly used and machine-readable format, and have it transmitted to another controller (where possible).
Candidates that reside in or are employed by a Circana entity in the European Union, the United Kingdom or Brazil also have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for the UK’s ICO, Brazil’s ANPD or European data protection authorities are available here. Prior to raising a complaint externally we encourage you to follow our complaints procedure below.
How To Exercise Your Rights
For any right that you are not able to exercise through candidate registration system please contact your Circana Group talent acquisition manager in the first instance. Your request will be processed promptly and (where required by law) within 28 days. We may have a reason why we do not have to respond to your request or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
If you are not contacting us through the email you originally supplied us with, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide sufficient information to allow us to verify that you are the Candidate about whom we have collected information and describe your request in sufficient detail to allow us to understand, evaluate, and respond to it. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify you. Authorized agents may initiate a request on your behalf through one of the above methods, but authorized agents will be required to provide proof of their authorization and we may also require you to personally verify your identity and the authority of the authorized agent.
Complaints And Further Queries
If you are not satisfied with how we have handled your request, or you have any questions, concerns or complaints regarding this Notice or the handling of your personal information (including any concerns about third parties we have shared your data with) please contact us using any of the details listed under “Contact Information”
Transfers To Third Countries
Candidate Information we collect will be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities, as described above. Candidate Information transferred between our third parties from the European Economic Area, Switzerland or the United Kingdom to a third country will be governed by Standard Contractual Clauses. If you require further information on this please get in touch using any of the details in the “Contact Information” section below
Data Retention
Data will be retained in accordance with any consent you have provided to us to retain your data, or if no such consent has been provided, for as long as it is required in order to to comply with our tax, accounting and recordkeeping obligations, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.
Profiling
We may use “profiling” e.g. automated processing of personal data to evaluate certain personal aspects (such as someone’s suitability for a role). Such profiling however will only be one element of a decision-making process and decisions will never be based solely on profiling results.
Additional Information For Individuals Located In The EEA And Switzerland
Legal Bases
We process Candidate Information on the following legal bases:
(1) with your consent: this ground is used to process information you are not obliged to provide as part of the recruitment process or if you wish us to retain your data for future opportunities at Circana. As stated above, where we process your data under consent you may withdraw that consent at any time
(2) as necessary for our legitimate interests in managing the recruitment process where those interests do not override your fundamental rights and freedom related to data privacy
(3) as necessary for the performance of the employment contract (precontractual requirement) related to the application of a specific post.
(4) in compliance with a legal obligation: for example where there is a requirement under employment and/or discrimination legislation to retain your information.
Contact Information
If you are not satisfied with how we have handled your request, or you have any questions, concerns or complaints regarding this Notice or the handling of your Candidate Information (including any concerns about third parties we have shared your data with) please contact the Chief Privacy Officer at privacy@circana.com.
You can also write to us at our Headquarters:Circana, Inc. , 203 N. LaSalle Street, Suite 1500, Chicago, IL 60601 and our International Headquarters is located at Maxis 1, Western Road, Bracknell Berkshire, RG12 1RT UK.
Our representative in the European Union is Circana Group Market Research Ltd 3rd Floor Kilmore House, Park Lane, Spencer Dock Dublin 1, Dublin 1, Dublin, Ireland
If Circana has appointed a data protection officer for the market in which you are applying, you may also contact them with any complaints or queries – please contact us for their email address.
Correctness Of Information
By applying for a role within the Circana Group, you confirm that all information you provide is complete and accurate. We expressly reserve the right to suspend, modify access to or remove your application if your profile violates any applicable Circana policy, is deemed offensive, violent and/or for any other reason as determined by Circana, in our sole discretion.
Updating This Privacy Notice
We strive for continuous improvement in our services, processes and protecting data subject rights. We will therefore update this privacy notice from time to time. Therefore, we advise you to check this notice each time you apply for a role. We are also happy to provide previous versions of this Notice on request.
Appendix
Applicable Legislation
| Country | Statute |
| Australia | Australian Privacy Principle 5.2, Privacy Act 1988 (Cth) |
| Brazil | Article 9, General Data Protection law (Law No. 13.709/2018) |
| Canada (Federal) | Section 6.1 and Principles 2, 3, and 8, Schedule 1, Personal Information Protection and Electronic Documents Act |
| China | Articles 17, 22, 23, and 39, Personal Information Protection Law (in Chinese) |
| EU Member States | Articles 13 and 14, General Data Protection Regulations 2016/679 |
| Hong Kong | Data protection principle 1(3) and Sections 35(C) and 35(F), Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) |
| India | Sections 4 and 5(3), Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 |
| Japan | Articles 15(1), 18(1) and (2), 23(2) and (5), and 27, Act on the Protection of Personal Information. Article 8, Cabinet Order to Enforce the Act on the Protection of Personal Information |
| Mexico | Articles 15,16, and 36 Federal Law on the Protection of Personal Data held by Private Parties (2010) Articles 14, 23, 30, 41 and 112, Regulations of the Federal Data Protection Law Chapter 5, Sections 1 and 26, Privacy Notice Guidelines (January 17, 2013) |
| New Zealand | Principle 3, Section 22, Privacy Act 2020 |
| South Africa | Article 18, Protection of Personal Information Act 2013 (No. 4 of 2013) |
| South Korea | Articles 20, 27, and 30, Personal Information Protection Act, as amended by Act No. 16930 Article 31, Enforcement Decree of PIPA (in Korean) |
| United Kingdom | EU Regulation (EU) 2016/679 General Data Protection Regulation, as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act |
| United States | California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended, and its implementing regulations |