Employment Privacy Policy

This Employment Privacy Policy describes the handling of personal data of GoodLeap, LLC, (“GoodLeap” or “We”) employees and job applicants through third party agencies and recruiters on behalf of candidates. It also describes the handling of personal data of any prospective candidates or leads, such as those individuals who expressed an interest in receiving news and details about future GoodLeap opportunities or other related communications. Personal data is defined herein as information, or a combination of pieces of information, that could reasonably allow you to be identified.

Personal Data GoodLeap Uses

We will collect your personal data from you directly and potentially from other sources. Listed below are the categories of personal information that GoodLeap may process about Employees:

Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social security number, driver’s license number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an Employees, or a device that is linked to an Employees, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.
Professional or Employees-related Information, including job related data, maintained as part of the Employees relationship that is present in source including but not limited to a job application or resume; an employee’s contract; a contractor agreement; a performance review; a disciplinary record.
Education information, including information about an Employee’s educational background, such as education records, report cards, and transcripts that is not publicly available.
Publicly available information from websites or social media, including information that you choose to voluntarily submit to GoodLeap in connection with your application (e.g. when applying through LinkedIn).
Other data you may choose to share with us, such as hobbies, social preferences, or survey data.

How GoodLeap Uses Your Personal Data and the Basis on Which GoodLeap Use It

We limit our use of your personal data. GoodLeap only collects and uses your personal data for specific, necessary reasons related to Employees and based on GoodLeap’s legitimate interest. GoodLeap may use information for the following purposes:

Create and manage the recruitment system, job applications and a database of interested individuals and leads.
Assess and evaluate your skills, qualifications and interests against the position applied for and/or other positions with GoodLeap communicate with you in relation to your expressed interest in GoodLeap, job opportunities/ leads, application or the recruitment process.
Verify your information, including through reference checks and, where applicable, background checks.
Send you information about the new hire and Employees experience at GoodLeap prior to your first day.
With your consent, send you information about positions with GoodLeap which may be of interest to you.
Operate, evaluate and improve the recruitment system, our application tracking and recruitment activities (this includes analyzing our job applicant base, our hiring practices or trends, identifying qualifications or skills shortages, and using information to match candidates and potential opportunities).
Detect, prevent and respond to fraud or potentially illegal activities (such as intellectual property infringement), misuse of the recruitment system or other applicable policies.
Perform audits, assessments, maintenance and testing or troubleshooting activities related to the recruitment system and our recruitment processes.
Comply with legal obligations to which GoodLeap is subject to and cooperate with regulators and law enforcement bodies.
GoodLeap must have a legal basis to process your personal data. In most cases the legal basis will be one or more of the following:
- to comply with our contractual obligations to you or to take steps to enter into a contract with you
- to comply with our legal obligations
- with your consent
- to meet our legitimate interests, for example to conduct our recruitment processes efficiently and fairly or to manage applicants effectively. When GoodLeap process personal data to meet our legitimate interests, GoodLeap put in place robust safeguards to ensure that your privacy or other fundamentals rights and freedoms are not overridden by our legitimate interest to comply with our legal obligations, for example obtaining proof of your right to work status to enable GoodLeap to meet relevant obligations.

For purposes of administering an employee contract between you and GoodLeap, GoodLeap may use your information for the following purposes:

Determining eligibility for hiring, including the verification of references, qualifications, and criminal records checks data (for certain vetting purposes, where permissible and in accordance with applicable law);
Administering payroll and benefits, processing Employees work-related claims (e.g., worker compensation, insurance claims, etc.), and processing leave of absence requests;
Establishing training and/or development requirements;
Reviewing work performance and determining performance requirements;
Enforcing disciplinary actions or termination;
Establishing emergency contacts and responding to emergencies;
Complying with applicable laws (e.g., labor and Employees, health and safety, tax, and anti-discrimination laws), judicial requests from courts of competent jurisdiction, or exercising or defending legal rights;
Compiling internal directories, such as Employees directories;
Preventing and detecting fraud or other types of wrongdoing;
Implementing and administering IT systems and information security, including authentication and authorization to access GoodLeap’s IT systems and networks;
Fulfilling the purpose for which you provide it;
For other lawful or legitimate purposes, which may be reasonably required for day-to-day operations, such as accounting, financial reporting, and business planning;
Validating business transactions;
Protecting confidential information, intellectual property, and other business interests;
Investigating breaches of GoodLeap’s policies and procedures, or other unlawful or improper acts;
Complying with legal obligations; or
Any other legitimate purpose permitted by applicable law.

GoodLeap may physically and electronically monitor its offices, information technology systems, and corporate network for specific, lawful purposes. Information may be collected during such monitoring and will be used to support GoodLeap’s legitimate interest in security its offices and systems.

When GoodLeap is required by local law to collect certain personal data about you, your failure to provide this data may prevent or delay the fulfillment of our legal obligations and may impact our ability to GoodLeap you. If GoodLeap ask for your consent to process your personal data, you may withdraw your consent at any time by contacting GoodLeap using the details at the end of this privacy statement.

Your Rights Over Your Personal Data and Contact

You have certain rights regarding your personal data, subject to applicable local laws. These include the following rights to:

access your personal data.
fix any errors in your personal data.
erase or delete your personal data.
restrict our use of your personal data.
object to our use of your personal data.
receive your personal data in a usable electronic format and transmit it to a third party (right to data portability).
lodge a complaint with your local data protection authority or regulatory body.

To exercise your rights in connection with Personal Data processed by GoodLeap on its own behalf, please contact GoodLeap by using the information in the “Contacting GoodLeap” section, below.

Automated Decisions About You

We may process your personal information using solely automated means to make decisions about your candidacy. This is known as “automated decision-making” and is only permitted when GoodLeap has a legal basis for this type of decision-making. This may have significant effects for you, namely that you may be rejected for the role you applied for without a recruiter ever reviewing your application. Your application may be automatically rejected if you do not meet minimum job requirements, or if an open role is filled while you are in the first or review stage of the recruitment process, your application may not be considered. Our recruiters can reactivate candidates that have been rejected at a later date, if necessary. GoodLeap may make these automated decisions about you:

Where such decisions are necessary for entering into a contract.
Where such decisions are required or authorized by law.
Where you give your explicit consent to GoodLeap carrying out automated decision-making. Subject to local legal requirements and limitations, you can contact GoodLeap using the details below to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by a human being.

Data Security

Security is an integral part of our business model and GoodLeap puts significant resources into making sure your data is protected. This involves technical measures (such as implementing security software) and organizational measures (such as only allowing staff to access your data if there is a business need to do so). These measures are aimed at ensuring the on-going integrity and confidentiality of personal data. GoodLeap evaluates these measures on a regular basis to ensure the security of the processing. GoodLeap will keep your personal data until the position you are applying for has been filled, after which GoodLeap will retain your personal data for a period of time that enables GoodLeap to:

Maintain business records for analysis, understanding market trends and/or audit purposes.
Comply with record retention requirements as required by local law or other relevant legal or regulatory requirements.
Defend, establish, exercise or bring any existing or potential legal claims.
Ensure fraud detection and prevention.
Respond to any queries or complaints you may have.
With your consent, suggest roles that may be of interest to you. GoodLeap will delete your personal data when it is no longer required for these purposes. If there is any personal data that GoodLeap is unable, for technical reasons, to delete entirely from our systems, GoodLeap will ensure that appropriate measures are taken to prevent any further processing or use of the personal data.

International Data Transfer

Because GoodLeap operates as part of a global business, GoodLeap may transfer, store, or process your personal data in a country different from where you reside. Your personal data may be processed in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction. In these instances, GoodLeap put in place appropriate safeguards (such as the Standard Contractual Clauses) to ensure that your personal data is adequately protected.

GoodLeap’s Policy Toward Children

GoodLeap does not intend to solicit applications or GoodLeap individuals under 18, and GoodLeap does not knowingly collect Personal Data from children under 18. Any individuals under the age of 18 must have consent from their parent or guardian to apply for job opportunities at GoodLeap or work at GoodLeap. If a parent or guardian becomes aware that his or her child has provided GoodLeap with Personal Data without their consent, he or she should contact GoodLeap at privacy@goodleap.com. GoodLeap will take steps to delete such information from GoodLeap’s files.

California Privacy Rights

A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed Personal Data information within the previous calendar year, along with the type of Personal Data disclosed, for the third parties’ direct marketing purposes. Please note that under California law, businesses are only required to respond to a customer request once during any calendar year. If you are a California resident and would like to make either type of request described above, please contact GoodLeap at privacy@goodleap.com

Additional Privacy Rights EEA, UK, Switzerland

This section only applies to Interactions with individuals who are in the European Economic Area, United Kingdom or Switzerland (collectively, the “Designated Countries”) at the time of data collection.

The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.

GoodLeap and its US subsidiaries identified at www.GoodLeapinc.com/subsidiaries/ complies with the EU-U.S. Data Privacy Framework and, as applicable, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Frameworks (the “Frameworks”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union, the United Kingdom and Switzerland to the United States. GoodLeap has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. The Federal Trade Commission has jurisdiction over GoodLeap’s compliance with the Privacy Shield. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In the context of an onward transfer, GoodLeap has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. To learn more about the Privacy Shield program, and to view an GoodLeap entity certification, please visit https://www.privacyshield.gov/. If you are a European, United Kingdom or Swiss data subject with an unresolved complaint or dispute arising under the requirements of the Privacy Shield Framework, GoodLeap agree to refer your complaint under the Framework to an independent dispute resolution mechanism. GoodLeap’s independent dispute resolution mechanism is the International Centre for Dispute Resolution (“ICDR”), operated by the American Arbitration Association (“AAA”). For more information and to file a complaint, you may contact the International Centre for Dispute Resolution by phone at (+1) 212-484-4181, or by visiting the website http://go.adr.org/privacyshield.html

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. You also have a right to lodge a complaint with a competent supervisory authority situated in a Designated State of your habitual residence, place of work, or place of alleged infringement.

Changes to the Privacy Notice

GoodLeap will update this Employment Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If GoodLeap does, GoodLeap will reflect this in the date at the top of this Employees Privacy Notice. If GoodLeap makes a change to this Employees Privacy Notice that GoodLeap reasonably believes materially affects how GoodLeap process your Personal Data, GoodLeap will provide notice of such change on GoodLeap’s website. By continuing your Interactions after those changes become effective, you accept the provisions of GoodLeap’s revised Privacy Notice.

In addition, GoodLeap may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices. These notices may provide more information about GoodLeap’s privacy practices, or provide you with additional choices about how GoodLeap process your Personal Data. The notices and information are subject to this Privacy Notice unless specifically indicated otherwise in the notice.

Contact Us

If you would like to exercise any such right under this policy, please contact GoodLeap at privacy@goodleap.com. GoodLeap encourages you to contact us to update or correct your information if it changes or if the personal data GoodLeap hold about you is inaccurate.