CANDIDATE PRIVACY STATEMENT
Last Updated Date: July 7, 2023
This Candidate Privacy Statement applies to all candidates, applicants, and prospective applicants residing in the State of California who have applied or wish to apply for a position with a VICE MEDIA GROUP owned and operated company.
The purpose of this notice is to fully inform you about the ways in which we process your personal information.
This Candidate Privacy Statement is not an employment contract nor offer of employment, and nothing in this Candidate Privacy Statement should be construed as a promise of employment. This Candidate Privacy Statement may be updated by VMG at our discretion. We encourage you to revisit this Privacy Statement from time to time to stay apprised of any changes to our practices.
1. COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION
(A) What categories of personal information do we collect about you?
“Personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. “Personal information” as used in this Privacy Statement does not include information that is considered publicly available, aggregated, or deidentified under applicable law. In connection with your application to work with or for VMG, we collect the following categories of personal information:
- Identifiers and contact information, such as a name, alias, postal address, phone numbers, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, visa information, or other similar identifiers. We collect identifiers directly from you.
- Demographic information, such as your date of birth, gender, and pronouns. We collect demographic information directly from you.
- Sensitive Personal Information, including social security, driver’s license, state identification card, or passport number; financial account, debit card, or credit card number; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages. We collect sensitive personal information directly from you.
- Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application or advertisement. We collect internet or other similar network activity automatically.
- Geolocation data, such as physical location or movements. We collect geolocation data directly from you or in some cases automatically. We do not collect precise geolocation information.
- Professional or employment-related information, such as current or past job history or performance evaluations. We collect professional or employment-related information directly from you or from third parties such as previous employers.
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)), such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. We collect non-public education information directly from you, or from third parties such as LinkedIn or from background check providers where prohibited by law.
- Inferences drawn from other personal information, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions behavior, attitudes, intelligence, abilities, and aptitudes. We collect this information automatically, where we are permitted to do so by applicable law.
(B) What is the source of personal information we collect about you?
We collect personal information from you as described in this Privacy Statement or as may be notified to you by VMG from time to time. It may be mandatory for us to collect certain personal information about you. This will be the case where the law requires that your personal information is obtained. It will also be the case where collection of your personal information is necessary for the VMG company to enter into an offer or employment or contract with you. As described in Section 1(A), We may collect personal information about candidates from the following sources:
- Directly from you or via recruitment platforms such as Workday;
- Recruitment or talent agencies, who may pass us information about you in connection with your application;
- Background check providers, where applicable;
- LinkedIn and other industry professional platforms;
- Referrals (including personal, company and industry); and
- Personal or professional references.
(C) For what purposes do we collect your personal information?
We will use the personal information we collect about you for the following purposes:
- Assessment of your skills, qualifications, and suitability for the work or role;
- Carrying out background and reference checks, where applicable;
- Communicating with you about the recruitment process;
- Keeping records related to our hiring processes; and
- Complying with legal or regulatory requirements.
As further described above, when we receive your application (in whatever form it’s submitted to us) we will then process that information to decide whether you meet the basic requirements to be considered for the role. If we decide your application is strong enough to invite you for an interview, we may conduct an interview via phone, in person or electronic video conferencing. We will use the information you provide to us at the interview(s) (together with any other information submitted by you to VMG) to decide whether to offer you a position. If we decide to offer you the position, we will then contact your named references and conduct any other applicable background checks before making an offer to you.
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications, right to work or work history), we will not be able to process your application successfully. For example, if we require a background check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further in the recruitment process.
(D) How long do we keep your personal information?
If your application to work for VMG is successful, VMG will retain your personal information for the duration of your employment in accordance with our People Privacy Statement, a copy of which will be made available to you when you start with VMG.
If your application is unsuccessful or you decline an offer of work that is made to you by a VMG company, VMG may retain a limited amount of your personal information (including your name, contact details and VMG application history) for a period of up to two (2) years. We retain this information so that VMG may approach you for future work opportunities and to comply with our legal obligations. After this period ends, we will securely destroy your personal information in accordance with applicable laws and regulations. If you have any questions relating to our retention of your recruitment information, please email firstname.lastname@example.org.
(E) When, and to whom, do we disclose your personal information?
(i) Within VMG companies
Your personal information is collected by the VMG company that has engaged in the recruitment process with you (contact details for your appropriate VMG company are set out in Schedule 1 to this Candidate Privacy Statement).. Additionally, your personal information may be disclosed with other VMG companies by virtue of your personal information being hosted on our secure servers or third party applications like Workday. Your personal information may be shared on a need-to-know basis with a people and teams within VMG:
- Internal or external recruiters;
- The applicable hiring manager(s);
- The executive leadership team of the applicable VMG company; and
- Internal members of the finance, payroll, legal and human resources.
Certain of the above people and teams at VMG may be provided with only limited information about you. So, for example, certain information that may be disclosed with or accessed by the human resources team, may not necessarily be shared with the hiring manager, etc.
(ii) With third parties outside of VMG
We may need to disclose your personal information to organizations outside of VMG. We have disclosed candidate personal information with the following categories of third parties in the past twelve months:
- Service providers and other organizations that provide recruitment management services, background check services, technology solutions and/or support for the benefit of VMG.
- VMG’s professional advisers, as may be necessary from time to time. For example, insurers, bankers, investors and business partners, IT administrators, lawyers, auditors, consultants, and payroll providers.
- Authority, agency or other body with jurisdiction.
VMG may disclose personal information outside of VMG companies or its service providers: (1) if it is required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with the law or a legal process served on VMG; (2) to protect or defend the rights or property of VMG; (3) to protect the health, safety and well-being of VMG employees, contractors, applicants, former employees, visitors, or members of the public; and (4) in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.
For further details of the organizations outside of VMG that have access to your personal information please email email@example.com.
(F) We Do Not Sell Or Share Your Personal Information
We do not sell your personal information for valuable consideration or share your personal information with any third parties for purposes of targeted or behavioral advertising. For clarity, we have not sold or shared personal information as described above in the last 12 months.
We do not intentionally collect data about children that are under 16 years old. We do not sell or share the personal information of consumers under 16 years of age.
3. YOUR CALIFORNIA PRIVACY RIGHTS
By law, California residents have a number of rights with respect to their personal information. We’ve detailed these rights below.
The right to know and access
Subject to certain exceptions, and legal obligations, you have the right to request that we disclose certain information to you about our collection and use of your personal information, at least over the past 12 months, including whether we sell or share such information. You also have the right to request access to personal information collected about you and information regarding the categories of personal information; the categories of sources of that information; the business or commercial purposes for which we collect, sell, or share it; the third parties to whom we sell, share, or disclose it; and the specific pieces of personal information we have collected about you.
This information is disclosed in the “Information Collected” Section of this Privacy Notice. You may also submit a request for this information as described below. To protect your personal information, we are required to verify your identify before we can act on your request.
The right to portability
You have the right to request that we provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. Once we receive your request and confirm your identity, we will provide to you a copy of your data as required under the applicable data protection laws. We may provide this data to you via email to the email address you have provided with your request.
The right to delete
You have the right to request that we delete your personal information. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
The right to correct inaccurate information
Subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws, you have the right to request that any inaccuracies in the personal information we have collected about you are corrected. We aim to ensure that all personal information is correct and up-to-date. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the personal information and the purposes of the processing of the personal information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.
Non-discrimination or Retaliation
We will not discriminate or retaliate against you for exercising any of your data privacy rights.
(A) Submitting a request to exercise your privacy rights:
If you are a California resident and you have questions about our employee privacy practices or would like to exercise one or more of the rights listed above, please send your request to the following email address: firstname.lastname@example.org; call us at +1-888-269-1005; or write to us at the following mailing address:
Vice Media LLC
49 S. 2nd St.
Brooklyn, NY 11249
Attention: Legal Department
You must put the statement “Privacy Rights Request” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address.
We’ll respond within 10 days from when we receive your request.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- excessive/repeated requests, or
- further copies of the same information.
In order to process your request to exercise your rights, we must first verify it using information necessary to complete your request. We will not collect additional personal information from you for the sole purpose of your exercising your rights under applicable data protection laws.
(B) Authorized Agent
You may authorize another individual, called an authorized agent, to make requests on your behalf. We may ask the individual to submit documentation or proof supporting their authority to represent you, and we may ask you to either verify your own identity or confirm that you provided the authorized individual to act on your behalf.
(C) Right to Opt Out of the Sale or Sharing of Personal Information to Third Parties
You have the right to opt out of the sale or sharing of your personal information by VMG to third parties. Under California law, “sell” means to sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means your personal information to a third party for monetary or other valuable consideration. “Share” means sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. We do not sell or share your personal information, as those terms are defined under California law.
(D) Right to Limit Use and Disclosure of Sensitive Personal Information
California law considers the following pieces of personal information to be “sensitive” social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data. We collect this information to perform necessary functions such as administering benefits and payroll, performing other human resources functions, and complying with legal reporting obligations. You have the right to direct us to limit our use of your sensitive personal information to only those uses which are necessary for us to perform the services which are reasonably expected in this context or that are allowed by applicable laws.
We are committed to protecting the security of the personal information you share with us. In support of this commitment, we have implemented appropriate technical and organizational measures to help to protect your personal information against:
- unauthorized or accidental destruction, alteration and/or disclosure;
- theft and accidental loss, and/or unauthorized access;
- damage; and/or
- any other form of unauthorized processing
We cannot guarantee the security of your personal information as no security measures are perfect and there is always some risk of security incidents occurring. But we will use our best efforts to mitigate any damage caused as a result of a breach of these data security measures in accordance with all applicable data protection laws.
5. CONTACT US
If you have any questions about the way in which we process your personal information, please email email@example.com.
Your VMG company contact details
Vice Media LLC
49 S. 2nd Street, Brooklyn, NY, 11249
Vice Holding Inc.
49 S. 2nd Street, Brooklyn, NY, 11249
Golden Heart Films LLC
49 S. 2nd Street, Brooklyn, NY, 11249