CANDIDATE PRIVACY STATEMENT

Effective Date: June 10, 2021

For all candidates residing in the State of California who wish to apply for a position with a VICE MEDIA GROUP owned and operated company.

The VICE Media Group together with its parents, affiliates, and/or subsidiaries (“VMG,” “we,” “our” or “us“) wants to make sure that the personal information we collect about you during any recruitment process is managed in accordance with the California Consumer Privacy Act (the “CCPA”).

This Candidate Privacy Statement aims to explain how we collect, use and share your personal information during any recruitment process, and applies to all prospective employees and freelancers. To be clear, this Candidate Privacy Policy does not apply to current VMG employees and freelancers.

LET’S START WITH A LEGAL BIT…

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). The purpose of this notice is to fully inform you about the ways in which we process your personal information.

We need you to read this notice (together with any amendments to this Candidate Privacy Statement in the future), so that you’re aware of what we’re doing with your personal information and why we’re doing it, when you’re involved in a recruitment process with VMG.

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 any time. The Candidate Privacy Statement was last updated and reviewed in June 2021.

SO YOU WANT TO KNOW WHAT VMG IS DOING WITH YOUR PERSONAL INFORMATION?

What type of personal information do we collect about you and process?

“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. Your personal information is collected by the VMG company that entered into an offer letter or employment contract, relationship, or a contract for services with you. Your personal information may need to be processed by other VMG companies, for their own independent purposes. We collect the following categories of personal information:

  • Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers
    • SOURCE(S): Directly from you
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
    • SOURCE(S): Directly from you, From third parties, such as tax authorities and benefits providers
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), breastfeeding, sexual orientation, veteran or military status, genetic information (including familial genetic information)
    • SOURCE(S): Directly from you, From third parties, such as medical reports from external professionals or benefits providers
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application or advertisement
    • SOURCE(S): Indirectly from you
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • Geolocation data, such as physical location or movements
    • SOURCE(S): Directly from you
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • Professional or employment- related information, such as current or past job history or performance evaluations
    • SOURCE(S): Directly from you, From third parties, such as previous employer(s), information from third parties acting on your behalf (e.g. recruitment/employment agencies), LinkedIn, or the results of a background check (where permitted by applicable law)
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • 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

    • SOURCE(S): Directly from you, From third parties, such as LinkedIn, or the results of a background check (where permitted by applicable law)
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • 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
    • SOURCE(S): Indirectly from you
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services
  • Sensory data, (such as audio, electronic, visual, thermal, olfactory or similar information)
    • SOURCE(S): Directly from you
    • HOW WE USE IT: For administrative employment purposes (see below)
    • HOW WE SHARE IT: Third party service providers who help us perform administrative employment services

How is your personal information collected?

We may collect personal information about candidates from the following sources:

  • You, the candidate either directly 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.

How do we use your personal information?

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the work or role;
  • Carry out background and reference checks, where applicable;
  • Communicate with you about the recruitment process;
  • Keep records related to our hiring processes; and
  • Comply with legal or regulatory requirements.

Having received 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 you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview (which may be conducted 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 the 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 personal information

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.

Who has access to your personal information?

When we share your personal information within VICE

We keep your personal information within VMG on our servers or third party applications like Workday. This means that your personal information may be shared with other VMG companies. Your personal information will be shared on a need-to- know basis with a people and teams within VMG:

  • Internal or external recruiters;
  • The applicable hiring manager;
  • 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 shared with or accessed by the human resources team, may not necessarily be shared with the hiring manager, etc.

When we share your personal information outside of VMG

We may need to grant organizations outside of VMG access to your personal information. To help you understand who these organizations are, here is a non- exhaustive list of the categories of organizations with whom we may share your personal information

  • Organizations (and their subcontractors) that provide technology solutions and/or support for the benefit of VMG. For example:
    • Organizations such as Google and Amazon Web Services who we instruct to provide systems and technologies which are used to support internal business operations and day-to-day communications only (for example the G-Suite products like Google hangouts and Gmail)
    • Organizations such as Workday who provide recruitment management services to VMG
    • Background check providers, where applicable
    • Third party recruitment providers
  • 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

When we share personal information with organizations outside of VMG, we require those organizations to treat the information in accordance with applicable law, including laws about data confidentiality and security. And, where we engage those organizations (such as our payroll providers) to process personal information on our behalf, we will require that information is treated consistently with this Candidate Privacy Statement.

For further details of the organizations outside of VMG that have access to your personal information please email employmentlegal@vice.com.

Is your personal information sent to other countries or territories?

As mentioned in the section entitled Who has access to your personal information,? your personal information may be shared with other VMG companies as well as organizations outside of VMG. These organizations may be located in various locations worldwide.

This means that your personal information may be transferred to a country or territory that is outside of the country in which you are applying or, if hired, where you later work.

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 VMG’s internal 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. This is so that VMG may approach you for future work opportunities. 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 employmentlegal@vice.com.

Your Rights

By law, you have a number of rights when it comes to your personal information. We’ve detailed these rights below. For further information regarding your rights, or to exercise any of your rights, please contact email employmentlegal@vice.com.

  • The right to be informed
    • You have the right to be informed as to the categories of personal information collected by us and the purposes for which the categories of personal information is used. This is why we’re providing you with the information in this Privacy Statement.
  • The right of access
    • You may ask to see the personal information we hold about you, but know there are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. Please note that a large amount of information we hold about you is accessible via Workday (or the applicable HRIS program), and you’re encouraged to access this information via the HRIS yourselves before requesting access from your HR Business Partner.
  • The right to rectification
    • You may request that any inaccuracies in your personal information are corrected. We aim to ensure that all personal information is correct and up-to-date. You also have a responsibility to notify us of any changes to your personal circumstances that may render your information inaccurate – for example, any change of address or bank account.
      You can update most of the personal information that we hold about you by logging into Workday. Certain information can only be amended with the help of your local HR Business Partner, so please contact them if necessary.

How will we handle a request to exercise your rights?

We’ll respond as soon as we can. Generally, this will be within 45 days from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

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.

Alternatively, the law may allow us to refuse to act on the request.

How do we keep your personal information safe and secure?

Taking into account state of the art measures and the cost of implementing them, VMG uses a variety of technical and organizational methods to secure your personal information in accordance with 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;
  • misuse;
  • damage; and/or
  • any other form of unauthorized processing

VMG implements the following precautions:

  • Servers: VMG uses servers that are up to date with both virus scanning and intrusion protection. VMG or trusted partners ensure that steps are taken to help keep the information saved on VMG servers safe and secure
  • Firewalls
  • File transmission: VMG employs multiple security layers in file delivery. All files are hashed and encrypted before delivery. They will only allow delivery to servers that have been certified by VMG
  • File Access: All files require credentials for access. Data is monitored, and file moves logged to ensure that data cannot be migrated without VMG’s knowledge

Unfortunately, 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.

SO, GOT QUESTIONS?

If you have any questions about the way in which we process your personal information or if you believe your data protection rights have been violated, please email employmentlegal@vice.com.