SYNEOS HEALTH GLOBAL APPLICANT PRIVACY NOTICE
CORPORATE AND CLINICAL EMPLOYEE POSITIONS
(Last Updated: 28 October 2019)
Syneos Health ("we," “us,” or “Syneos Health”), operating through its affiliates/subsidiaries located throughout the world (collectively, the “Company”) is committed to protecting your privacy and has implemented the measures below to protect the personal data we process about you. In this notice, when we use the term "Personal Data", we mean all information that relates directly or indirectly you. Personal Data does not include information that cannot be used to identify you or a natural person, including aggregated or anonymized information. Our use of information that cannot identify a natural person is not limited in any way by this notice.
Scope
This notice applies to all Personal Data gathered by, for, and on behalf of Syneos Health through its applicant portal, and during the application, recruitment, selection, and onboarding process.
Effect of Other Notices
Syneos Health has additional privacy notices or terms that are tailored for the different ways your Personal Data is collected by different Syneos Health lines of business or functions. For example, Syneos Health provides a website privacy notice that describes the Personal Data we may collect in connection with your use of Syneos Health sites that link to it. If you receive a privacy notice provided to you for a specific purpose, the terms of the more specific notice or contract will control your interaction with Syneos Health with respect to that purpose.
Identification of Data Controller
The Syneos Health legal entity that is the data controller of your Personal Data is the company entity located in your jurisdiction and with which you interacted to provide your Personal Data and/or another Syneos Health legal entity with which you interacted to provide your Personal Data (if you did not interact with a local legal entity). A current list of all Syneos Health entities globally can be found at here. You can contact the Syneos Health entity acting as a data controller through our Privacy Office, using the contact information provided in this notice.
The Categories of Personal Data We Collect
During the application, recruitment, selection, and onboarding process, Syneos Health may collect or obtain Personal Data about you. Various regulators define what constitutes Personal Data, but in general, it may include information such as your name, physical address, telephone number, e-mail address, company affiliation, employment and educational history, browsing history, and associated interests. The categories of Personal Data we collect or obtain about you may include:
• Personal Identifiers such as your name, username; unique personal identifier, IP address, date of birth, work related photographs, postal or street address, social security number or other national identification number, and similar identifiers;
• Contact details including your email address, telephone number, and emergency contact details;
• Professional or employment-related information such as level of service and work history, which may include details of your qualifications, skills, work location, experience, work record and employment history, information about your compensation and benefit entitlements;
• Educational and training history, including schools or institutions attended, course work or training completed, and degrees or certifications earned educational awards, certificates and licenses, vocational records and in-house training attendance;
• Recruitment and performance-related data, such as professional and personal reference contacts, objectives, ratings, comments, feedback results, career history, eligibility for re-hire, work equipment, career and succession planning, skills and competencies and other work-related qualifications.
• Inferences about characteristics, such as your abilities and aptitudes.
• In some jurisdictions, we may also collect information about you such as your gender, racial or ethnic origin, or veteran’s status; whether or not you have a disability for which we need to make reasonable adjustments; whether you are entitled to work in the country in which the position is located and your residence status; and other information included by you in your resume or curriculum vitae or disclosed to us during the application, recruitment, hiring and onboarding process.
From time to time we may combine Personal Data with other information, such as combining a location with your name. If we combine Personal Data with other information, we will treat the combined information as Personal Data. When we combine information we may do so to improve the completeness and accuracy of your Personal Data and to perform the other activities described in this Privacy Notice or another notice we may provide to you.
How we Collect or Obtain Information About You
We collect or obtain information about you in several ways.
• Direct Interactions: We collect Personal Data directly from you when you choose to provide us with your Personal Data, for example, when you complete a form, upload a document, or communicate with us through other means, such as via telephone or email.
• Open Source Data: We may also collect Personal Data from other sources, for example from information you may have made publicly available, such as social media posts.
• Interactions with Technology: We may collect Personal Data resulting from the use of technologies such as cookies and other tracking technologies. For example, we may log certain information that your browser sends us when you use a Source, such as your IP address.
• Service Providers and Other Third Parties: We may collect information from service providers who conduct background checks. The content of these checks may vary by jurisdiction, but can include verification of employment and educational history, criminal offences, compliance screening against publically available watch and sanctions lists, and information gathered from social media platforms, and other publicly available sources. We may also obtain information about you from recruitment vendors, relocation vendors, personal or professional references, and former employers and industry contacts.
In addition, collecting Personal Data, we may also collect statistical or aggregated information through your interaction with and use of our applicant portal that does not reveal your specific identity nor directly relate to you. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country or city. This other information may include, but is not limited to, non-identifying browser and device information, data collected through automated electronic interactions such as referring page, application usage data, demographic information, geographic location, statistical and aggregated information. To learn more about how we do this, please see the “Cookies and Other Tracking Technologies” portion of this Privacy Notice.
Sensitive Personal Data
We do not generally seek to collect Sensitive Personal Data (which is also known in certain jurisdictions as special categories of Personal Data) unless it is required as part of the application, recruitment, selection, and onboarding process. The term "Sensitive Personal Data" refers to categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories generally include racial or ethnic origin, political opinions, financial background, religious or similar beliefs, sexual life, trade union membership or affiliations, individual medical records and history, physical, mental or physiological health condition or genetic or biometric information, ideological views or activities, information on social security measures, or administrative or criminal proceedings and sanctions which are treated outside pending proceedings.
If we seek to collect Sensitive Personal Data, we will do so in accordance with applicable law.
How We Use Personal Data
We use Personal Data for many purposes, including:
• to allow you to utilize the Syneos Health applicant portal;
• to respond to your questions or other requests or to provide you with information;
• to contact you regarding your application for a particular job or for other potential employment for which your skills may be a fit, or regarding material changes to this Privacy Notice or related policies;
• to improve the applicant portal and for internal business purposes;
• to tailor your experience with the applicant portal and/or otherwise customize what you see when you visit our websites;
• to provide you with information about Syneos Health that may be of interest to you;
• to contact you for responses to surveys or questionnaires;
• to maintain, operate and administer the applicant portal and manage our candidate pool;
• to collect information, we are required to obtain from regulators during the application, recruitment, selection, and onboarding process;
• as applicable, to conduct interviews, assess your suitability for a position; facilitate the hiring and onboarding process;
• to conduct ongoing screening against publically available watch and sanctions list; and
• for other purposes reasonably related to your application for employment or as otherwise disclosed at the time you provide the Personal Data to us.
The above processing may be performed both electronically and on paper.
Disclosure to Third Parties
We may share Personal Data within the Syneos Health Group companies and with third parties, as described below.
• Companies and people who work for us: We contract with other companies and individuals to help us manage our application, recruitment, selection, and onboarding process. For example, we may host some of our applications on another company's computers, hire technical consultants to maintain our sites, work with companies who provide customer service, recruitment support, background checks, relocation services, and other services related to the application, recruitment, selection, and onboarding process. In addition, we may validate your identity and other information against available databases. In order to perform their services, these other companies may have limited access to some of the Personal Data we maintain about you. Other companies may collect information on our behalf through their websites or applications. We require that such companies not use your information for any purpose other than fulfilling their responsibilities to us. We also require that such companies keep your Personal Data confidential and comply with applicable laws. Syneos Health’s practice is to (i) conduct reasonable and appropriate due diligence on our service providers; and (ii) obtain written commitments regarding the processing of Personal Data, including that the service provider will only handle Personal Data in accordance with our instructions; adopt adequate technical and organizational measures to protect your personal data; and not retain Personal Data when it is no longer required for completion of its services. Details of service providers and the countries in which they are based are available from the Syneos Health by contacting its Global Privacy and Data Protection Officer. You are responsible for any additional permissions you choose to grant to service providers for other services. We are not responsible for the practices of recruiting firms you have engaged directly and from whom we have received your information.
• Business transfers: If we transfer a business unit or an asset (such a Syneos Health website) to another company, we may transfer the Personal Data we have collected to the relevant third party.
• Legal requirements: Syneos Health reserves may provide Personal Data to law enforcement or other government officials to comply with applicable legal requirements. We may disclose activities or information about you as we, at our sole discretion, determine necessary or appropriate, in connection with an investigation of fraud, for the administration of justice, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.
• For the Protection of Health and Safety of Persons: We may release information if, in our judgment the release may be necessary to prevent the death or serious injury of an individual.
Legal Basis for Processing Personal Data
In certain jurisdictions, such as the Member States of the European Union, we are required to identify the legal bases for processing Personal Data. We process Personal Data:
• To perform contracts with you or to take steps at your request prior to entering into such contract;
• To comply with a legal obligation, such as to consider reasonable adjustments to your work environment necessitated by a disability, or to comply with equal employment regulations;
• For our legitimate business interests, such as assessing and managing our workforce, which will be assessed in connection with the specific use of Personal Data;
• With your consent (or, where required to process Sensitive Personal Data, with your explicit consent), which will be requested and given via the Sources or otherwise.
Withdrawal of Consent
If we process Personal Data based on your consent or your explicit consent, you have the right to withdraw your consent in whole or in part at any time. Once we have received notification that you have withdrawn your consent, we will no longer Process your Personal Data for the purpose(s) to which you originally consented unless there are compelling legitimate grounds that override your interests, rights and freedoms (for example, to comply with a legal obligation), or for the establishment, exercise, or defense of legal claims. If we processed Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such purposes. The withdrawal of your consent does not affect the lawfulness of such processing that occurred before its withdrawal. Should you withdraw consent to future processing of your Personal Data, we may not be able to contact or interact with you as originally planned when you first provided your consent.
Cross-Border Transfers
Syneos Health operates on a global basis, and your Personal Data may be transferred, accessed and stored globally as necessary for the uses stated in this Privacy Notice, or in another notice or agreement provided to you. We have taken measures to protect the confidentiality, integrity, availability, and security of Personal Data when it is transferred. By using the applicant portal (and if required by law), you consent to the transfer of information to countries outside of your country of residence.
For applicants based in the European Union, Switzerland and the United Kingdom:
Certain Syneos Health entities (Syneos Health Clinical, Inc., Syneos Health, LLC, InVentiv Clinical, LLC, InVentiv Health Clinical Research Services, LLC, and InVentiv Health Clinical, LLC) comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union, United Kingdom, and/or Switzerland, as applicable, to the United States in reliance on Privacy Shield. These entities have certified to the Department of Commerce that they adhere to the Privacy Shield Principles with respect to such information. To learn more, please see our Privacy Shield Statement.
To the extent that your Personal Data is shared with service providers or other third parties processing Personal Data on our behalf which are located outside your country of residence, it is our practice to enter into appropriate contracts that require such third parties to comply with applicable data protection laws.
Retention and Deletion
When you create an account, Syneos Health will retain your Personal Data in our applicant tracking system. While your information is active, you may still be considered for other positions at Syneos Health. If you do not wish to be considered for future positions, you may deactivate your account at any time by using the tools provided in the applicant portal. This action will result in a “soft delete,” which will remove your Personal Data from the applicant tracking system. Even if you delete your account, however, Personal Data associated with jobs to which you have applied will be retained for compliance and record keeping purposes, and will be subsequently permanently deleted in accordance with the Company’s retention practices. If you are hired by Syneos Health, your information will be retained as part of the information we process about you in connection with your employment.
Protection of Information
The security of your Personal Data is important to Syneos Health. We use commercially reasonable physical, electronic, and administrative safeguards that are designed to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, regardless of our efforts and the device you use to access the applicant portal or other online resources, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission.
Cookies and Other Tracking Technologies
The applicant portal and/or third parties may use “cookies,” “web beacons,” scripts, tags, Local Shared Objects (Flash cookies), Local Storage (HTML5) beacons, and other similar tracking technologies (collectively, “Tracking Technologies”) to collect information from you automatically as you use the Sources, browse Syneos Health websites, and the web. These Tracking Technologies help us tailor our content, gather statistics about and understand website and internet usage, improve or customize the content, offerings, or advertisements through the Sources, personalize your experience with respect to the Sources (for example, to recognize you by name when you return to a Syneos Health website), save your password in password-protected areas, save your online video player settings, help us offer you programs or services that may be of interest to you, deliver relevant advertising, maintain and administer the Sources, and for other purposes described in the "Uses of Information" section of this Privacy Notice.
These Tracking Technologies collect “click stream” data and other information regarding your use of the applicant portal, such as your visits, use of our features and preferences, and may also collect your IP address or some other identifier unique to the device you use to access the Sources (“Identifier”). Your Identifier may be automatically assigned to the device you use to access the applicant portal. By using the applicant portal, whether as a registered user or otherwise, you acknowledge, understand, and hereby agree that you are giving us your consent to track your browsing activities and your use of the applicant portal through these technologies.
Cookies
"Cookies" are text files that a website can send to your device through your browser, which is then used to identify your device by the website. Cookies can be both “session level” (stored only for until you close your web browser), which help you efficiently navigate our Sources during a visit, and “persistent” (stored for a longer period, even after you close your browser), which remember relevant information such as your language preference. The Syneos Health applicant portal may use both session level and persistent cookies.
Cookies may also be “first-party cookies,” which are cookies that are placed by the website owner on a website, or “third-party cookies,” which are cookies belonging to one party that are placed on another party’s website. We may use both first- and third- party cookies on the applicant portal. Some of the third-party cookies we use relate to Tracking Technologies we have licensed from third parties, including Adobe Experience Cloud and Google Analytics. These companies use programming code to collect information about your interaction with our sites, such as the pages you visit, the links you click on, and how long you are on our sites.
If you would like more information about cookies, including how to manage them, please see All About Cookies.
Other Tracking Technologies
We also use other technologies to collect information about how the applicant portal is used, tailor our content, gather statistics about and understand website and internet usage, improve or customize the content, offerings or advertisements through the applicant portal, personalize your experience with respect to the applicant portal (for example, to recognize you by name when you return to the portal), save your password in password-protected areas, save your online video player settings, help us offer you programs or services that may be of interest to you, maintain and administer the applicant portal and for other purposes described in the "Uses of Information." Some examples of these Tracking Technologies include:
• "Web beacons" (also known as image tags, gifs or web bugs), including conversion pixels, are small pieces of code used to collect advertising data. They may count page views or help us understand, for example, whether e-mails we send out have been opened or whether certain links have been clicked. As noted above, web beacons often act in conjunction with cookies. If you do not want your cookie information to be associated with your visits, you can turn off cookies in your browser. Your visit will then be detected, but it will not be associated with information stored in cookies.
• Local Shared Objects (e.g., Flash cookies), and Local Storage (e.g., HTML5) may be used to store content information and preferences. You may manage Flash cookies by clicking here. Your browser may offer settings to turn off HTML5.
The applicant portal does not recognize automated “do not track” instructions. You can, however, adjust your web browser’s privacy preferences regarding the use of most cookies. For example, you can remove existing cookies and block future cookies from being placed on your device through your browser’s privacy settings. Unless you choose to block cookies, the applicant portal may issue cookies when you visit our site or click on an e-mail link that we send to you, even if you have previously deleted our cookies. If you choose to delete or block cookies, you may impact your user experience on the applicant portal, as some features may no longer work. In addition to deleting or blocking cookies, you may be able to manage cookie preferences with the cookie manufacturer. For example, you can opt out of Google Analytics by clicking here. You can opt out of Adobe Experience Cloud by clicking here.
Your Rights as a Data Subject
In some jurisdictions (for example, the Member States of the European Union) you may be entitled to certain rights in and to your Personal Data, subject to certain conditions and exceptions contained in applicable law. These rights may include the following:
• Request us to confirm whether your Personal Data is processed by us, and if we do, to obtain access to your personal data and certain information about it.
• Require the correction of your Personal Data if it is inaccurate or incomplete.
• Direct us to stop processing your Personal Data under certain circumstances.
• Erase or delete your Personal Data, for example, where the data is no longer needed to achieve the purpose for which it was collected.
• Restrict the further Processing of Personal Data.
• Request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (we currently do not engage in such processing and will notify you prior to doing so).
• Request to receive your Personal Data for transmission to, or to directly transmit to, another data controller in a structured, commonly-used and machine-readable format.
To protect your privacy and the security of your Personal Data, we will take reasonable steps to verify your identity before complying with such rights requests. Please note that you may also utilize the tools provided in the applicant portal to update your account information and remove your information from consideration in our candidate pool.
Exercising Your Rights or Raising Concerns
Should you have questions about the Personal Data that we process, or if you have a question, concern, or would like to exercise your legal rights in and to your Personal Data, please contact the Syneos Health Global Privacy and Data Protection Officer as follows:
Attn: Privacy Office Attn: Privacy Office
Syneos Health Syneos Health
1030 Sync Street Farnborough Business Park, 1 Pinehurst Road,
Morrisville, NC 27560 Farnborough, Hants, GU14 7BF
United States of America United Kingdom
We may also be reached via e-mail at data.privacy@syneoshealth.com.
How Your Dispute or Complaint May Be Resolved
Any questions, concerns, or complaints regarding the use of your Personal Data should be directed to Syneos Health Global Privacy and Data Protection Officer using the contact information presented above.
If you are located in certain jurisdictions, such as the European Union, you also have the right to raise a complaint about the collection or use of your Personal Data to your local regulator. In the European Union, you may contact the United Kingdom’s Information Commissioner’s Office, which we have designated as our Lead Supervisory Authority. You may also contact the Supervisory Authority for the Member State in which you reside.
Changes to This Privacy Notice
We may periodically update this notice. When we post changes to this notice, we will also revise the “Last Updated” date appearing at the top of the notice. If there are material changes to this notice, we will notify you by e-mail. We encourage you to review this notice periodically to be informed of how we are using your information and to be aware of any changes to it. Your continued use of the Syneos Health applicant portal after the posting of any amended notice shall constitute your agreement to be bound by any such changes. Any changes to this notice are effective immediately after we post it.
By selecting the “I Accept” button you acknowledge and confirm that you have received and understand this notice. Further, where your consent is required by law, you consent to the use of your personal data as explained in this Privacy Notice and the transfer of your Personal Data to the Syneos Health companies located in countries other than your own, including to the United States.