CDW Job Applicant Privacy Notice
CDW provides this Privacy Notice ("Notice") to explain our practices regarding the collection, use, and other processing of Personal Data (defined below) about job applicants during the recruiting and hiring process.
1. What Personal Data do we collect?
CDW generally collects and uses the following types of personally identifiable information ("Personal Data") when recruiting:
- Contact information, like your address, phone number and email address;
- Personal identification information, like your name, date of birth, and gender (to extent permitted by law);
- Employment qualifications information, like your skills and experience, any degrees earned, languages spoken, work history including positions, dates, and salary expectations, references, your responses to screening questions and (to extent permitted by law) any related background checks (such as criminal record checks);
- Device information, like your IP address, device type, unique device identification numbers, browser type, broad geographic location, usage activity on our online recruitment site through cookies, Web beacons, and similar tracking technologies, and other technical information (see below for details); and
- Other identifying information, including information you may submit on the CDW recruitment site, including through chats or pre-recorded or live video interviews with our representatives.
Personal Data will be collected directly from you, including via the online application, profile form, via your resume, or during pre-recorded or live video interviews with you, as well as from authorized third parties (e.g., people you have named as your references, previous employers, background screening providers, schools, public authorities, or public resources), subject to the requirements of applicable law.
If you participate in a pre-recorded or live video interview, you will be required to provide us (and our service provider) with access to your device’s camera and microphone so that we can create an audio and video recording of your responses to screening questions or live interview. Access to these recordings will be limited to CDW recruiters on a need-to-know basis and will only be used and retained for the purposes set out below. Please ensure that you conduct the interview in a private location that will not capture the images of any other individuals.
There may be limited instances where we ask you to provide sensitive Personal Data, such as your race, ethnicity, and disability information in connection with your recruitment on a voluntary basis or as required to comply with our obligations under applicable law (Sensitive Personal Data).
CDW requires the Personal Data described in this Notice partly to meet legal requirements and partly to carry out the recruitment and hiring process, except when we indicate that certain information is voluntary. Not providing your Personal Data may prevent CDW from carrying out recruiting and hiring activities that impact your potential employment with us.
2. For what purposes and on what bases do we use and process Personal Data?
CDW will process Personal Data for the following purposes:
|Processing Purposes||Categories of Personal Data Involved|
|Recruiting activities, including assessing your suitability for employment, administering your recruitment, making a hiring decision (including assessing qualifications, tracking applicants during the application process, and carrying out in-person and/or video interviews), verification of credentials and prior employment history, performing background checks where permitted by applicable law, providing and customizing your site experience and communicating with you about your candidacy and about other job openings and events that may be of interests to you (including any job alerts that you requested).||Contact information, Personal identification information, Employment qualifications information, Device information, Other identifable information|
|Hiring Activities (if you are offered and accept a position with CDW) including establishing and administrating payroll, salary, and benefits and your employment relationship with CDW.||Contact information, Personal identification information, Employment qualifications information, Onboarding information, Other identifiable information|
|Complying with applicable laws and employment-related requirements along with the administration of those requirements, including record keeping and reporting for human rights, employment equity, and Foreign Corrupt Practices Act and similar screenings (where applicable).||Contact information, Personal identification information, Employment qualifications information, Sensitive Personal Data, Onboarding information|
|Managing corporate information technology, including protecting the security and effective functioning of the recruitment site and information technology systems.||Personal identification information, Device information|
3. Under what conditions is Personal Data transferred to other recipients?
You should expect that the Company will transfer your Personal Data to third parties as follows:
- Within the CDW Group of Companies. We share your Personal Data among the CDW group of companies as necessary to conduct recruiting and hiring activities, and respond to and comply with requests and legal demands.
- With certain acquiring or acquired entities. If the CDW business for which you submitted your Personal Data is sold or transferred in whole or in part, or if the CDW entity is acquiring and integrating another entity, your Personal Data may be transferred to the other entity prior to the transaction (e.g., during the diligence phase) or after the transaction, subject to any rights provided by applicable law, including the laws of the jurisdictions where the other entity is located; and
- With service providers. Some third-party service providers like IT support, background screening and video interviewing providers, or HR support providers will receive your Personal Data as necessary to support recruiting and hiring activities, comply with applicable laws and employment-related requirements, and other activities. These third parties will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard your Personal Data.
Some the recipients identified above may be located outside of your home country, including in the United States, which may have different rules for processing and securing Personal Data. We take appropriate measures to protect your Personal Data. Further, any access to your Personal Data is restricted to those individuals that have a need to know in order to fulfill their job responsibilities. CDW may also disclose your Personal Data as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.
4. For how long does CDW retain my Personal Data?
Your Personal Data is stored by CDW strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the data are collected, in accordance with applicable data protection laws. If you accept an offer from CDW, your Personal Data will be retained for the duration of your employment with CDW and as otherwise necessary in accordance with applicable law.
5. Cookies & Similar Tracking Technologies
When you visit our recruitment site, we also collect (directly or via third parties) information about your usage and activity on our site, including information about jobs you may be interested in through essential and non-essential cookies, Web beacons, and similar tracking technologies (collectively, “Cookies”). Cookies are small data files stored on your hard drive, our site or our emails, which we use to provide and improve our site and your experience, such as to see which areas and features are popular, count visits to our site, understand usage and effectiveness on our site, and/or tell if an email has been opened and acted upon.
Certain third-party services may also use information collected via Cookies, like your IP address, your ISP, and the browser and device you use to visit our site in order to better understand the usage and visitation of our site and the other websites tracked by these third parties. Many web browsers are set to accept Cookies by default, and only you have the ability to manage your browser settings. If you prefer, you can usually choose to set your browser to remove and reject certain Cookies.
For more about interest-based advertising on your desktop or mobile browser and to understand your options, including how you can opt-out of receiving behavioural advertising from participating third-party advertising companies, please visit the Digital Advertising Alliance-US, Network Advertising Initiative, and Digital Advertising Alliance-Canada.
To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again. Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics, and you will still see advertisements from us. However, our advertisements will not be tailored based on behavioural information about you and may therefore be less relevant to you and your interests.
If you delete your Cookies, use a different browser, or buy a new computer, you will need to renew your choices. Please visit the respective privacy policies and/or review the privacy settings of the social networking services you use, to make choices about online advertising on those services. While we and others give you choices described in this Notice, there are many ways Web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism. Although you may opt-out of receiving personalized ads from one network, you may still receive ads from other ad networks you did not opt out of or ads that are not personalized to your interests.
Some Internet browsers include the ability to transmit "Do Not Track" signals. Since uniform standards for "Do Not Track" signals have not been adopted, CDW does not process or respond to "Do Not Track" signals.
6. What are my rights?
As permitted by law, you may have certain rights to your Personal Data, including the right to access and correct your Personal Data by contacting us as detailed below, subject to limited expectations applicable by law. Please note that we need to retain certain Personal Data as required or permitted by applicable law. You can also opt-out of receiving recruitment communications about other opportunities by following the unsubscribe link in our emails, by responding "STOP," "Unsubscribe," or any similar response in our SMS messages to you, or by contacting us as detailed below.
7. Other Issues
Legal basis of processing
As required in some countries, we rely on the following legal bases to process your Personal Data: (i) the need to perform a transaction (administering a recruitment decision); (ii) as necessary to comply with a legal obligation (government reporting requirements); (iii) consent (for Cookies and certain communications); and (iv) as necessary for legitimate interests (in order to maintain our business generally, including maintaining the safety and security of the site).
What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Notice to use our site or to interact with us, but if you do not provide certain Personal Data, we may not be able to respond to administer your recruitment or make a hiring decision.
8. How do I reach the contact person for questions?
If you have any questions about this Notice or the manner in which we or our service providers treat your Personal Data, you should contact CDW’s Data Protection Officer at [email protected].
Last updated: FEBRUARY 27, 2020