Data controller: Southwestern Healthcare, Inc. and its Affiliates, hereinafter referred to as “Southwestern”, jobs@southwestern.org

As part of any recruitment process, Southwestern collects and processes personal data relating to job applicants. The organization is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Southwestern collect?

Southwestern collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience, employment history, and desired salary;
• whether or not you have a disability for which the organization needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in a particular country of employment; and
• on a voluntary basis, equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, and veteran status.

The organization collects this information in a variety of ways. For example, data might be provided in the application, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

Southwestern will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The organization will seek information from third parties only once a verbal job offer to you has been made and will inform you that it is doing so.

Why does Southwestern process personal data?

Southwestern needs to process data to take steps at your request prior to interviewing you. We also need to process your data to employ you.

In some cases, the organization needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work before employment starts.

The organization has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organization to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organization may also need to process data from job applicants to respond to and defend against legal claims.

Where the organization relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

The organization processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the organization processes other special categories of data, such as information about ethnic origin, sexual orientation, or veteran status, this is for equal opportunities monitoring purposes and purely on a voluntary basis.

For some roles, the organization is obliged under the law to conduct denied parties screening or seek information about criminal convictions and offenses. Where the organization seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

Who has access to data?

During the recruitment process, candidate information will be accessed internally only by those Southwestern employees who are involved in the recruitment process. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Southwestern and its corporate affiliates may use your personal information in connection with the position in which you have expressed an interest or to contact you in the future about other positions, within Southwestern, that may match your skills and experience.

The organization will not share your data with third parties, unless your application for employment is successful and it makes you a verbal offer of employment. The organization will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the necessary criminal records checks. In exceptional circumstances, candidate personal data may be processed and retained for the purpose of immigration requirements, including the sharing of that data with legal advisers and the Government Bodies, and the length of time data may be stored will be in accordance with laws relating to these requirements.

How does the organization protect data?

The organization takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, altered, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Southwestern’s information security processes provider for the classification of information and the assignment of protection requirement and information security controls based on the classification of information. The safeguards used to protect Personal Information should be commensurate with the type of Personal Information being processed and the risks involved.

Your rights

The Federal Fair Credit Reporting Act (FCRA) promotes the accuracy, fairness, and privacy of

information in the files of consumer reporting agencies. There are many types of consumer

reporting agencies, including credit bureaus and specialty agencies (such as agencies that sell

information about check writing histories, medical records, and rental history records). Here is a

summary of your major rights under the FCRA. For more information, including information

about additional rights, go to www.consumerfinance.gov/learnmore or write to: Consumer

Financial Protection Bureau, 1700 G Street N.W., Washington, DC 20552.

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require the organization to change incorrect or incomplete data;
• require the organization to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the organization is relying on its legitimate interests as the legal ground for processing; and
• ask the organization to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organization’s legitimate grounds for processing data.

If you would like to review, edit, or delete the personal information you have submitted, please email jobs@southwestern.org.

For how long does the organization keep data?

Unless you delete your personal information, we will retain it for a minimum of 12 months from your last update, unless otherwise required by law. If you are hired by Southwestern, we will retain the personal information you have submitted as part of your employment record for the term of your relationship with Southwestern and for any post-termination period permitted or required by law.

If you believe that the organization has not complied with your data protection rights, you can file a complaint with the Indiana Attorney General.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organization during the recruitment process. However, if you do not provide the information, the organization may not be able to process your application properly or at all.