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Global Data Privacy Notice for Employees and Job Applicants

Last updated: March 20, 2024

Rocket Software, Inc. and its affiliates (“Rocket Software,” “we,” “us,” or “our”) have issued this Global Data Protection and Privacy Notice for Applicants (“Privacy Notice”) to help you understand our practices surrounding the collection, use, and disclosure of your personal data as an applicant via our careers site (the “Site”). The Site serves as the centralized career application portal for Rocket Software. Because we gather certain types of information about applicants during the recruitment process, we want to help you understand our practices surrounding the collection, use and disclosure of your personal data.

We respect the privacy of individuals and are committed to handling personal data responsibly and in accordance with applicable law. This Privacy Notice sets out the types of personal data that we collect and process about you, the purposes of the processing and the rights that you may have in connection with our processing, depending on your location.

Alternative methods of applying for employment are available to individuals unable to submit an application through this Site because of a disability. Contact [email protected] to discuss modifications.

This Privacy Notice addresses the following topics:

 

If you are located in the European Union, United Kingdom or Switzerland, you should also refer to “Jurisdiction Specific Information,” below, for a description of additional information and rights that you may have. In all other jurisdictions, this Privacy Notice is provided on an informational basis only, and your rights may vary according to applicable local data privacy laws.

This Privacy Notice applies only to information collected for recruitment purposes through the Site and from other sources. The other sources might include information that you provide other than through the online application page as well as information obtained, for example, from prior employers, other references, pre-employment screening providers, and educational institutions.

This Privacy Notice does not form part of any contract of employment or other contract to provide services. It is important that you read and retain this notice, together with any other privacy notice that we provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

 

Equal Employment Opportunity Statement 

Rocket Software is an equal employment opportunity employer. Rocket Software does not discriminate against any applicant or employee on the basis of race, color, sex, sexual orientation, gender identity, religion, national origin, age, disability, veteran status, or any other consideration made unlawful by applicable federal, state, or local laws. Rocket Software also prohibits harassment of applicants and employees based on any of these protected categories.

For U.S. Applicants: It is also Rocket Software’s policy to comply with all applicable laws respecting consideration of unemployment status in making hiring decisions. Rocket Software complies with the Americans with Disabilities Act, the ADA Amendments Act of 2008, Section 503 of the Rehabilitation Act of 1973 and applicable state law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job.

 

Your Consent

To submit your job application, you will be required first to create an account with us. After providing the required account information, you will need to click on “Rocket’s Global Applicant Privacy Notice,” review this Privacy Notice and then click “Create Account.” By clicking “Create Account,” you consent to the collection, use, disclosure, transfer across borders and other processing of your personal data as described herein. Once you agree, your consent will continue to apply to our collection, use, disclosure, cross-border transfer and other processing of your personal data unless you revoke your consent by contacting us as instructed under “How to Exercise your California Rights” or “How to Exercise Your Rights.”

If you click "Decline," you will not be able to use the online application page to apply for global career opportunities within the Rocket Software corporate group and Rocket Software may not be able to consider you for the position for which you are applying.

You can access, update, correct or delete your account information and any information in your profile by visiting the online application page and clicking on the “Edit Account Information” or “Edit Profile.” If you would like to access the information that you have submitted through the online application page; wish to request that we update, modify, or delete your information; please follow the process described below under “How to Exercise your Rights.”

 

Categories of Personal Data We Collect About You

A. Categories of Personal Data

If you choose to apply for a position with us, the categories of personal data that we may collect about you are listed below. Please remember that you are responsible for providing information that is accurate, complete and up to date when you disclose information to us during the employment process.

  1. Basic identifiers and contact information, such as first name, last name, preferred name, job title, employer, contact information, including email address, work address and telephone number, languages spoken, and preferences and interests, Internet Protocol (IP) address, and signature.
  2. Professional or employment-related information, such as your resume and information about your employment history (e.g., dates of employment and last position held), educational history ((e.g. degrees earned, certifications obtained), professional licenses and/or certifications, and any information you disclose through your LinkedIn profile or any other professional membership platform profile).
  3. Internet or other similar network activity, such as information regarding your interaction with the Site, including through the use of cookies. Please review our Cookies Notice to learn about the information we collect automatically using cookies notice when you visit the Site. If you visit our offices during the recruitment process and use our guest WiFi, we may collect information about that use, such as type of device used and start/stop time. We also may collect information from your publicly available social media content (other than LinkedIn, which is covered in the bullet immediately above).
  4. Medical information, such as if you request an accommodation in connection with the hiring process, we may collect medical information about you.
  5. Other identifying information that you voluntarily choose to provide, such as (a) any personal data submitted as part of your response to our question asking why you chose to apply for a position with Rocket Software, including any photographs or other personal data you choose to submit; (b) your eligibility to work in the country where you reside; (c) your salary expectations or (d) that you provide via our complaints or whistle-blower hotline.

Information About Protected Classification

When you apply for a position in the United States, or indicate the U.S. as a preferred work location when registering your profile, you will be invited to provide information about your, gender, race/ethnic origin, disability and/or veteran status as required by federal and state civil rights laws. The provision of this information is entirely voluntary. If you decline to provide this information, your application(s) will not be affected in any way. If you do choose to provide this information, you consent to our using it for equal employment opportunity monitoring purposes. This information will be kept confidential and separate from your application and will not be used to evaluate your application for employment.

Except as described above, we will not request or otherwise collect information about your health, race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or sexual orientation or your genetic information or biometric information through the on-line application or during the application process unless the law, as an exception, requires us to do so. We, or a third-party background check company under our direction, may check criminal history records for information about convictions, but only if and to the extent permitted by applicable law. Please note, that you might choose to voluntarily make available to us such sensitive personal information when reporting an issue to support your concern if you file a whistle-blower complaint.

B. How We Collect Your Personal Data

We may collect the categories of personal data listed above from the following sources:

  • You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
  • Vendors and service providers, for example, recruiters and background check providers.
  • Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
  • Public internet sources, for example, social media, job boards, public profiles, and other public online sources
  • Public records, for example, court records, and credentialing and licensing organizations.
  • Automated technologies on our electronic resources, for example, to track logins and activity on our careers page.
  • Surveillance/recording technologies installed by Rocket Software, for example, video surveillance in common areas of Rocket Software facilities, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law
  • Government or administrative agencies, for example, law enforcement or public health authorities.
  • Acquired company, if we acquired your employer, we might collect personal data from that employer.

C. Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve our websites, products or services and promote our business, provided that we will not share such data in a manner that could identify you.

D. Personal Data of Children

We do not knowingly collect or solicit personal data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use our websites, products or services or send us any personal data. If we learn we have collected personal data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided personal data to us, please contact us at the email address at the end of this Privacy Notice, including in the subject line “Use of Child’s Personal Information.”

 

How We May Use Your Personal Data 

A. Purposes

To the extent that you provide us with any personal data, or we otherwise collect your personal data (e.g., through or in connection with our websites) we may use your personal data for the following purposes (which shall be considered “business purposes” for purposes of the California Consumer Privacy Act of 2018 (as amended, along with any implementing regulations, the “CCPA”)):

Recruiting

  • To evaluate your qualifications or suitability for employment with Rocket Software
  • To communicate with you
  • To check your references
  • To conduct a pre-employment or criminal history background check
  • For identification purposes
  • For recordkeeping purposes
  • To demonstrate your agreement to, or acceptance of, documents presented to you, e.g., acknowledgment of employment application, offer letter, or contract of employment
  • To evaluate and improve the recruiting process
  • For security and IT network purposes
  • To comply with our legal obligations and to defend against administrative charges or legal claims

If you visit our facilities

  • To make travel arrangements
  • To reimburse travel expenses
  • To manage access to the facility
  • To issue a security badge
  • To maintain security during the visit.
  • To monitor your use of the corporate Internet access if you connect to our guest WiFi during a visit to our offices

We will use the information that we collect about your race, ethnicity, sex, disability, or veteran status only where permitted by applicable law and

  • To identify whether you may be able to benefit from our federal affirmative action programs for individuals with disabilities or veterans
  • To monitor the effectiveness of our outreach and recruitment efforts
  • To provide reports to federal, state, or local agencies as required by law
  • For other purposes related to diversity and inclusion as permitted by applicable law

You may also choose to receive automated emails about positions within Rocket Software at the e-mail address you provided informing you of positions that may fit your profile. To stop receiving these emails at any time, you can click the "unsubscribe" link at the bottom of these emails. You may also choose to stop receiving these emails (or to begin receiving them if you had previously elected not to) by signing into the online application and updating your account options.

If you are not hired for the position for which you initially apply, we may also use the information that we collect about you through the recruiting process to identify other job openings in which you might be interested in applying and to contact you to let you know about the opportunity to apply for those job openings.

Our employees involved in the evaluation of your application and, if you are hired, in the administration of your employment relationship with us will have access to your personal data on a need–to-know basis.

No solely automated decision-making, including profiling, is used when processing your personal data.

B. Legal Basis For Processing

Where applicable, personal data protection law requires a lawful basis for collecting, using and otherwise processing your personal data, we rely on your consent to do so. The processing of your personal data also is necessary for us to determine whether to enter into an employment agreement with you. If you do not provide requested information, we may not be able to consider you for employment. In addition, the processing of your personal data is necessary for us to pursue our legitimate interests in recruiting and hiring suitable personnel and related activities.

 

How We May Disclose Your Personal Data

Your personal data may be shared with and processed by our affiliates and certain service providers and business partners as necessary to fulfil the purposes set out in this Privacy Notice. We use a number of service providers that provide a wide range of services, including legal and financial professional advisors, IT and data security providers, data hosting providers and website managers and other IT service providers, meetings and conference vendors, auditors, marketing agencies, HR firms, and data software providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

We may also disclose your data to a third party when we believe it is necessary to protect your health or safety, such as disclosure to emergency medical personnel if you experience a medical emergency in the workplace.

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a corporate transaction, including any divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors (including as part of any preliminary diligence process).

 

Retention Of Your Personal Data

If we hire you, the information that you submitted through the online application and the information that we collect during the application process will become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes. We will retain this information for the entire duration of your employment relationship with us and thereafter in accordance with applicable law, legal process or administrative needs.

We will retain the information of applicants who are not hired for one year after the hiring decision has been made unless (a) the applicant indicates that we may maintain the information on file until the applicant asks to delete the information, or (b) a shorter or longer retention period is legally required. These records will be retained for our internal recordkeeping and reporting purposes. During that time, we may use your personal data to consider you for positions in addition to the position(s) for which you initially applied. If you wish to withdraw your application from consideration at any time during this retention period, you can do so by contacting us at [email protected], including in the subject line “Withdrawal from Consideration.”

 

Security of Your Personal Data 

We have put in place appropriate technical, physical and administrative procedures and means to safeguard and secure the information we may collect or might receive from you in order to prevent unauthorized access or disclosure. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and required to keep your personal data secure.

 

International Transfers of Your Personal Data

As we operate at a global level, we may need to transfer personal data to countries other than the ones in which the information was originally collected. When we export your personal data to a different country, we will take steps to ensure that such data exports comply with applicable data privacy laws.

If you are located in the European Union (“EU”), Switzerland, or the United Kingdom (“UK”), we have taken steps to ensure an adequate level of protection for your transferred personal data through Standard Contractual Clauses to which Rocket Software, Inc., its U.S. subsidiaries and its subsidiaries in the EU, India, Switzerland, the UK and other geographies are parties. If you are located in another country with restrictions on cross-border data transfers, such as Brazil, we may rely on your consent for the transfer of your personal data outside your country of residence.

 

Jurisdiction-Specific Information 

The following jurisdiction-specific information may apply to you based on where you reside or are located:

A. California

This section applies only to individuals who reside in the state of California in the United States (“California residents”). In addition, this section applies to personal information collected through the Site and in any other way, such as when California residents visit our offices.

California Notice at Collection

We collect the categories of personal information identified in the “Personal Data We Collect About You” section, above, for the purposes identified in the “How We May Use Your Personal Data” section, above, and retains personal information for the period described in the “Retention of Your Personal Data” section, above. We do not, and will not, sell your personal information or disclose it to third parties for cross-context behavioral advertising. We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Additional Information Regarding Disclosures of Personal Information

The California Privacy Rights Act (“CPRA”) requires that we provide you with the following information about disclosures of your personal data to third parties for “business purposes”, as that term is defined in the CPRA:

  • Service providers: We may disclose to service providers any of the categories of personal data they collects for the business purpose of performing services on our behalf and, in particular, for the specific purposes described in the “How We May Use Your Personal Data” section, above.
  • Auditors, lawyers, consultants, and accountants engaged by Rocket Software: We may disclose the categories of personal data listed in the “Catagories of Personal Data We Collect About You” section, above, to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on our behalf.
  • Affiliated companies:  Rocket Software may disclose any of the categories of personal information listed in the “Categories of Personal Data We Collect About You” section, above, to other companies within the Rocket Software family of companies for the business purposes set forth herein, including (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a product or service.

No Sales or Sharing

We do not sell or “share” (disclose for cross-context behavioral advertising) your personal information.

Your California Privacy Rights

Subject to applicable exceptions, California residents have the following rights under the CPRA:

  • Right to Know: You have the right to submit a verifiable request for specific pieces of your personal data and for information about our collection, use, and disclosure of categories of your personal data.
  • Right to Delete: You have the right to submit a verifiable request to delete personal data that we have collected from or about you.
  • Right to Correct: You have the right to submit a verifiable request to correct inaccurate personal data about you maintained by us, taking into account the nature of the personal data and the purposes of processing the personal data.

Non-Discrimination

We will not unlawfully discriminate against you for exercising your privacy rights under the CPRA.

How to Exercise Your California Privacy Rights

We will respond to a request to know, delete, and correct in accordance with applicable law if we can verify the identity of the requestor. You can exercise these rights in the following ways:

  • Call 1-800-890-4254
  • Complete the request form available under “How to Exercise Your Rights,” below

B. European Union, United Kingdom, and Switzerland

This section applies only if our collection, or your provision, or personal data under this Privacy Notice is subject to the European Union (EU), United Kingdom (UK) or Swiss data privacy laws, such as the EU GDPR or the UK or Swiss equivalent.

Rocket Software is a controller of any personal data collected or processed by us when you interact with us in the ways described above (e.g., when you visit our Site, etc.). The types of personal data we collect, and our legal bases for doing so, is set out above.

Your Rights

You may have the right to access the personal data we hold about you and control the way in which and what personal data we store and process about you, as set out below. To exercise these rights and controls, please see “How to Exercise Your Rights,” below.

  • Access: You have the right to ask for a copy of the personal data that we hold and process about you free of charge, however we may charge a ‘reasonable fee,’ if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
  • Correction: You may notify us of changes to your personal data if the information we hold and process about you is inaccurate or it needs to be updated.
  • Deletion: If you think that we should not be holding or processing your personal data any more, you may request that we delete it. Please note that the right to deletion is not absolute and it may not always be possible to delete personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, deletion of personal data may result in the inability for us to fulfil the purposes described in the Privacy Notice.
  • Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
  • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer the personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdrawal of consent: If you previously gave us, and we rely on, your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose not specified in this Privacy Notice, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

More on the Right to Lodge a Complaint: If individuals located in the EU, Switzerland and/ or UK believe that their personal data has been processed in violation of applicable data privacy laws, they may follow the “How to Exercise Your Rights” process below but they also have the right to lodge a complaint with the competent supervisory authority in the country where they reside, where they work, or where the alleged violation occurred.

C. All other locations

To the extent provided by applicable law and subject to any relevant exceptions, you may be able to exercise the following rights and any other rights afforded under applicable law:

  • Access: The right to request access to your personal data maintained by Rocket Software.
  • Rectification: The right to request that Rocket Software update or correct your personal data that is outdated or inaccurate.
  • Deletion: The right to request that Rocket Software to delete/erase your personal data.
  • Restrict Processing: The right to request restriction of processing of your personal data in certain situations, such as while a dispute concerning the accuracy of personal data is being resolved.
  • Withdraw Consent: The right to withdraw your consent to the processing of your personal data, at any time, where you previously consented to the processing of your personal data.
    • More on the right to withdraw consent: Any withdrawal shall not affect the lawfulness of processing based on your consent before its withdrawal, and Rocket Software will continue to retain the personal data that you provided us before you withdrew your consent for as long as allowed or required by applicable law.

If you believe that your personal data has been processed in violation of applicable data privacy laws, you may also have the right to lodge a complaint with the data protection authority where you live, where you work, or where you believe the violation occurred. Individuals in India may make a complaint to Rocket Software by the complaint procedure provided by the Data Protection Board of India.

D. How To Exercise Your Rights

To exercise the rights described above, you or your validly-appointed authorized agent (“Authorized Agent”) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the timeframe provided by the laws applicable to your location. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a Valid Request by completing this Form, or, in the case of California residents, by calling 1-800-890-4254. The more risk entailed by the request (e.g., a request for specific pieces of personal data), the more items of personal data we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

You may also authorize an agent to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. You can obtain an “Authorized Agent Designation” form by contacting us at the email address at the end of this Privacy Notice, including in the subject line “Authorized Agent Request.”

We will respond to requests to exercise individual data rights in accordance with applicable law. We will recognize any additional rights you may have under applicable law, but we may not grant you more rights than applicable law provides.

 

Changes to this Privacy Notice

We may change this Privacy Notice from time to time in our sole discretion. If we decide to change our Privacy Notice, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Please check periodically for changes to this Privacy Notice, and especially before you provide any personal data to us.

 

Inquiries and Concerns

Please direct any questions or concerns you may have about this Privacy Notice to [email protected], including in the subject line “Privacy Notice Inquiry.”