Job Seeker Privacy Notice
Welcome!
At Edgewell, we believe that transparency and trust form the foundation of every great relationship - especially during important milestones like starting your career journey with us.
This Job Seeker Privacy Notice is designed with you in mind. It explains how we carefully handle your personal information throughout the hiring process, ensuring your privacy and rights are respected every step of the way.
Think of this as our way of saying: Your story matters, and we’re here to protect it.
We invite you to explore this document, which answers key questions and highlights the ways we’re committed to safeguarding your personal data. Should you have any questions, our Data Protection Officer is just an email away at privacy@edgewell.com.
Thank you for considering Edgewell—we’re thrilled to be a part of your Joyful Journey
What is the purpose and scope of this notice?
The collection, use, and disclosure of personal information is subject to numerous privacy requirements around the world.
This job seeker privacy notice (“notice”) explains how Edgewell (“we,” “our,” “us”) handles and protects personal information of any candidate or job seeker or prospective employee during the hiring process (“you,” “your”). In this notice, Edgewell means each subsidiary of the group.
This notice informs you about the various types of personal information processing carried out in the context of your job search, application or potential hiring process and reminds you of your rights.
This notice does not grant any more rights than those provided by the applicable legal rules in your country of employment.
The Edgewell Group Data Protection Officer (“DPO”) is responsible for overseeing this notice and, as applicable, developing related policies, processes, and guidelines. You can reach out to the DPO by using this form or sending an email to privacy@edgewell.com.
What is personal information?
Within the meaning of applicable legislation, personal data, or personally identifiable information (“personal information”) means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be directly or indirectly identified by reference to information such as name, email, identification number, online identifier or to one or more factors specific to the physical, psychological, genetic, or cultural identify of that person.
*We do not handle all the personal information, this list is for illustrative purposes only
What is our role?
When it comes to our qualification under the pertinent privacy legislation, we are considered as controller or business.
We decide the how and the why of the personal information handling. We determine what personal information will be processed, how the processing will take place, and the purpose for which it is processed.
Personal information sources
Your personal information will be collected directly from you, or indirectly from other from third parties outside of our organization, such as our trusted partners – recruitment agencies, background check providers, social media, or specialized websites or even from fellow colleagues.
Special case of subcontractors
In some circumstances, we might need to share your personal information with trusted partners helping us with our operations. They will be most frequently considered as data processors or service providers. They are a separate entity that processes the personal information on behalf of the controllers. They must specifically agree to follow any rules put forth by us and handle the personal information as specified by us as a condition of their engagement.
You will see during your job search, application, and potential hiring process such partners are mainly the ones listed under the next article.
Access to personal information
Your reliant personal information can be accessed by both internal and external recipients on only need to know basis.
Internal personal information recipients include the following:
- HR departments
- Hiring Manager(s)
- Interviewers
External personal information recipients include the following:
- Our website providers helping us operate the careers.edgewell.com platform and its features while searching for open positions
- Our providers helping us operate the career8.successfactors.com platform and the built-in features while applying for a job
- Our background check providers if applicable
With respect to sharing personal information with subcontractors, we will enter into a contract with each relevant subcontractor, share the personal information for limited and specified purposes, ensure the subcontractor protects the personal information with at least the same level of privacy protection as we do and follow any instructions from us.
Subject to applicable laws, we may also disclose your personal information in the context of sale or transfer involving all or portion of our business or assets. In this case, as with subcontractors, we would ensure that the potential acquirer agrees to provide the same level of privacy protection as we do.
What personal information do we handle?
Where permitted by applicable law, we will collect the following personal information about you:
Identification data: last name, first name.
Contact details: address, phone number, email address and name.
Prior employment-related information: your resume, professional qualifications, work eligibility, education, and employment history.
Personal details such as your salary expectations, language and other relevant skills, career ambitions.
Education and career: qualifications and diplomas, foreign languages spoken, curriculum vitae (detailing your prior work experience and, where applicable, continuing education), situation in terms of mobility and career plan management.
Connection data: login and password(s), cookies, IP address needed for your use of our hiring platform.
CCTV and access badge control data: CCTV systems at sites and access control devices (video recordings, information about access and time of collection).
Whistleblowing system: within the framework of our legal obligations, we have introduced a whistleblowing system enabling job seekers to report any unethical or inappropriate behavior and the conditions of processing are explained in the personal information notice of the system.
Your personal postal address might be used to send you professional equipment, gifts, samples, or similar content parcels, and/or other legitimate business-related correspondence (e.g., benefits information).
Special case of sensitive personal information
We may need to collect and process special categories of personal information. We process such personal information if and strictly insofar as such processing is with your freely given, express consent, in the context of legal claims or when we are required to do so in order to meet our statutory or regulatory obligations.
Other sensitive data may be collected on a voluntary basis and with your consent and in compliance with equal employment opportunity applicable regulations. (data about ethnic origins for surveys on diversity for example).
For what limited purposes do we handle personal information?
We can only process your personal information for valid and disclosed purposes. This is the case for the situations described hereafter.
HR management:
- Organizing recruitment and hiring
- Background checks and other pre-employment checks as required
- Retaining your contact details so that we may notify you of future job opportunities
- Assessing physical ability to work and ensuring that we have the appropriate facilities required for candidates with disabilities
Security:
- Managing access to premises (badge control)
- Securing premises by CCTV
- Securing access to hiring platform
- Judicial enquiry or proceedings
- Responding requests from authorities
- Making submissions in a case or before judicial or administrative authorities, an arbitration tribunal, or a mediator
Special case of automated decisions
Automated decision-making occurs when an electronic system uses personal information to make decisions without human intervention.
We do not plan that decisions which could have a significant impact on you will be solely made on the basis of automated decisions. You will be notified in writing in the event of a change in this approach.
Special case of AI usage
We are using artificial intelligence (“AI”) to assist job seekers who visit our career platforms in the application process. The AI can answer basic queries using the chatbot functionality to guide job seekers to available jobs based on stated preferences. AI can recommend jobs to job seekers based on their searches and use of our career platform. AI can collect basic information from job seekers applying to roles, including name, contact details to create a job seeker profile. AI captures job specific job seeker information from questions set by the recruiter for the purposes of manual screening and rating.
What authorizes us to handle personal information?
To be able to process personal information, we need a valid legal basis allowed by the pertinent privacy legislation.
During your application and potential hiring process, we mainly handle your personal information based on your freely given and explicit consent (e.g., sharing with us your curriculum vitae, disclosing information during interviews, etc.). Where we process your personal information based on your consent, you should be aware that you may withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of the processing carried out previously with your consent.
In addition, your personal information can be processed as follows:
- When we need your personal information for the fulfilment of our obligations and to exercise our rights in connection with your application and potential hiring process
- When we need to fulfil our statutory and regulatory obligations
- When your personal information is necessary to establish, exercise or defend our rights within the framework of judicial proceedings
- When we have a legitimate interest in processing your personal information
How do we store and transfer personal information?
Hosting and transfers
We are an international group of companies and there are cases in which the personal information of job seekers is stored outside their country or geographical area (e.g., United States or European Economic Area).
What are these cases?
- IT systems used by the departments to handle personal information might host the data in United States or other countries
- Hiring Managers can be located in different countries
- Other teammates participating in the application and potential hiring process can be located in different countries and access personal information
Specifically, in the case of transfers outside the European Economic Area, we ensure such transfers are secured in accordance with the rules defined by the General Data Protection Regulation.
With respect to transferring personal information to subcontractors outside of your country of residence, we will enter into contract with each relevant subcontractor, share the personal information for limited and specified purposes, ensure the subcontractor protects the personal information with at least the same level of privacy protection as we do and follow any instructions from us.
Retention periods
We will only store your personal information for the period necessary for the purposes set out in this notice, or in accordance with applicable legal provisions and depending on the context.
HR management: personal information is stored at least for the time of the application process and the pertinent retention periods.
Security: personal information stored for CCTV purposes (images) are stored for 3 months at the most after being recorded. Personal information on badges is stored for the time the job seeker needs to enter our premises.
For further details about retention periods, please contact our DPO at privacy@edgewell.com.
How do we ensure the security of personal information?
We take reasonable and appropriate measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into consideration the risks involved in the personal information handling and its nature.
All our subcontractors follow, as a minimum, our security requirements and are contractually bound to protect your personal information.
What is your role?
When pertinent, you are required to create your candidate profile on our recruitment platform and update it regularly during the full application and potential hiring process.
The fields include, depending on your location and without limitation, the following:
- Salutation
- First, middle, and last name
- Password
- Suffix
- Former Name
- Gender
- Marital status
- Nationality
- Race Ethnicity
- Disabled
- Protected Veteran
What are your privacy rights?
Subject to applicable legal provisions, you have the following rights:
Right of Access or to Know
In addition to this notice, you can request the confirmation we are holding your data.
Right to be Informed or to Know
You can obtain clear, transparent, and understandable information on how we process your data and, on your rights, as well as a copy of your personal information.
Right to withdraw Consent
You can withdraw your consent, at any time, for the purposes for which your consent has been obtained.
Right to Opt-out or Unsubscribe or to Object
You can object to the processing of your data when the processing is based on our legitimate interest or if we are using personal information for direct marketing purposes. You will be informed that you have a right to object at the time of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information.
Right to Rectification or Correction
You can request the rectification or correction of your data to obtain the modification of your personal information if obsolete, inaccurate, or incomplete. If we have disclosed your data to any third parties, we will take reasonable steps to inform those third parties of the request where possible. You can also directly update your data in your SuccessFactors account.
Right to Erasure/to be Forgotten
You can request the deletion of your data (or right to be forgotten). Before deleting your data, we will consider your request carefully in accordance with the requirements of any pertinent laws and will let you know if we are able to erase your data.
Right to Restriction or Limit of Processing
In certain specific circumstances you have the right to block the processing of your data. This right arises if you are disputing the accuracy of your data, if you have raised an objection to processing, if processing of data is unlawful and you oppose erasure and request restriction instead or if the data is no longer required by us but you require the personal information to be retained to establish, exercise or defend a legal claim.
In particular, you can ask us to limit the processing of your sensitive personal information such as social security number, religious beliefs etc. to a use and disclosure for specific business purposes only.
Right to Data Portability or to Transfer
In certain specific circumstances, you can ask to receive your data in a structured, commonly used, and machine-readable format and also can request its transmission to another controller where technically feasible. This right is subject to several conditions, the main being the processing is based on consent or on a contract.
Right to oppose Automated Decision Making
You have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you. As a reminder, we do not currently make any automated decisions about you.
Right to request Do Not Sell or Share
You can request us to be informed if your personal information is sold or shared and require us not to proceed with such operations.
Note that we are not selling your personal information and share it only as explained in this notice.
Right to Lodge a complaint
If needed, you may also lodge a complaint with your competent data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.
Before contacting local authorities, we invite you to raise your concern to the DPO at privacy@edgewell.com or use our whistleblowing channels.
Specific Local Rights
If needed, you can also exercise the specific rights your local legislation is giving you such as defining the guidelines regarding the use of your data in case of your death.
It is obvious that the names of the rights might vary depending on local legislation and definitions. The spirit remains the same.
Requests will be reviewed according to the applicable law and responses will be provided within one (1) month unless the request is complex and requires us to notify you about an extra month’s delay. If the local legislation foresees a shorter period of time, we will respect it.
You can exercise your rights by filling this this form or contact our DPO at privacy@edgewell.com.
Where to find the most updated version of this notice?
This notice is always available on our websites and Career opportunities platform.
We reserve the right to amend or update this notice and we ask you to read it regularly.