Brambles Applicant Privacy Notice

Brambles Ltd. and its affiliates including its companies operating under the CHEP, brands (collectively, “Brambles” or “we” or “our” or “us”), respect your right to privacy and your right to control the dissemination of your personal information. Please click here for a list of our business locations and contact information. 

This Applicant Privacy Notice (“Privacy Notice”) explains how Brambles uses personal information about you in our recruitment process. 

The personal information you provide will be used and processed by or on behalf of the Brambles hiring entity identified in the job posting and will be processed in accordance with this Notice. Additionally, if you elect to join our Talent Network or request to be considered for other job opportunities, your information will be used and processed by us or on our behalf to consider you for other Brambles’ job opportunities. 

By visiting our Career Portal (“Portal” or “Website”) and/or using the services offered on or through the Portal, you acknowledge you have read and understood the terms of this Notice. This Notice is incorporated into, and part of, the Terms and Conditions of our Portal, which governs your use of the Portal. 

This Privacy Notice addresses the following topics: 

  • Information We Collect  

  • IP Addresses and Cookies 

  • How We Use Your Personal Information 

  • Disclosure of Your Personal Information 

  • Legal Basis to Collect and Process Your Personal Information 

  • Special Provisions for Our European and UK Users 

  • Your Privacy Rights 

  • Data Retention 

  • Security 

  • How to Contact Us 

  • Privacy Notice Updates 

Please note that this Privacy Notice uses the terms personal data and personal information as equivalent terms as any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; or as may be further specified by applicable data protection or privacy law.  

1.  INFORMATION WE MAY COLLECT  

Information We Collect From You 

In the twelve months preceding the effective date of this Privacy Notice, the specific pieces of personal information that Brambles collects, uses, and shares depends on the services you use on our Website. We may collect the following categories of personal information: 

  • Contact information (such as name, email address, postal address, phone number, unique personal identifier, online identifier, and Internet Protocol address). 

  • Personal identifiers (such as name, signature, postal address, telephone number, education history, employment history, and, in some cases, medical information). 

  • Protected classification characteristics (such as age, race, ethnicity, ancestry, national origin, citizenship, medical information, physical or mental disability, sex gender, gender identity, and veteran or military status). 

  • Employment information (such as current or past job history or performance evaluations, resume, job or professional preferences, and employee reference checks). 

  • Geo-location information (such as physical location or movements). 

  • Internet or other Electronic Network Activity information (such as browsing history, IP address, device type, operating system, and duration of user session(s)). 

  • Inferences drawn from the above categories of personal information reflecting your preferences, characteristics, behaviors, attitudes, skills, and abilities. 

1.1. Information Collected from Third Parties 

Where necessary for certain roles, and to the extent permitted by law, Brambles may check the accuracy of personal information you provide during the recruitment process. We may also collect personal information about you from third parties, including referees. 

In each case, Brambles will tell you in advance which part of your personal information will be verified and whether personal information will be collected from third parties, including an explanation of how this will be carried out and whether external agencies will be used. 

Brambles will only collect specific and not general information. 

If a third party source requires your consent before disclosing any personal information about you, Brambles will ask you to give your consent before contacting the third party. 

You will be given the opportunity to explain any unexpected results which might affect your application. Brambles will normally not approach your family and colleagues. 

 

1.2.How We Collect Information 

 

We collect information from a variety of sources. The following are categories of source from which information is collected: 

 

  • Directly from you when you complete an application on our Career Portal or Talent Network; 

  • From third parties, such as friends or colleagues you have shared your resume with and referees; 

  • From third party service providers or business partners, including recruiting agencies, recruiting platforms , advertising networks and data analytics providers; and  

  • Through automated technologies and online browser tools, including the use of cookies, pixel tags and other technologies. 

 

2. IP ADDRESSES AND COOKIES 

 

2.1. IP Addresses 

Our web servers may collect the name of the domain you used to access the Internet, the website you came from, and the website you visit next. This information is aggregated to measure the number of visits to the Portal, average time spent, page views, and other statistics about visitors to the Portal. We may also use this aggregated data to monitor site performance and to make the site both easier and more convenient to use. 

When you visit our Portal, we collect certain technical and routing information about your computer to facilitate your use of the Portal. For example, we may log environmental variables, such as browser type, operating system and CPU speed, and the Internet Protocol ("IP") address of your originating Internet Service Provider, to try to bring you the best possible service. We may also record search requests and results to try to ensure the accuracy and efficiency of our search engine. We may use your IP address to track your use of the site. This "Click Stream" data may be matched with other information you provide. 

2.2. About Cookies 

Cookies are files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server. 

Cookies can be used by web servers to identity and track users as they navigate different pages on a website, and to identify users returning to a website. Cookies are either placed by our Website (first- party cookies) or other websites whose content appears on our Website (third-party cookies). 

Cookies may be either "persistent" cookies or "session" cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 

We or other parties may collect personal information about your online activities over time and across different websites when you use our Website. 

 

3. HOW WE USE YOUR PERSONAL INFORMATION 

We may use your personal information we obtain about you to: 

 

  • Assess your suitability for the job opportunities to which you apply and, as the case may be, to make you a job offer; 

  • Consider you for job opportunities that match your qualifications (subject to your preferences collected at the time you submit a job application or elect to join our Talent Network); 

  • Operate, evaluate and improve our Website; 

  • Ensure that the content from our Website is presented in the most effective manner for you and for your computer; 

  • Communicate with you about job opportunities we believe may be of interest to you, such as through email alerts and newsletters (subject to your preferences collected at the time you submit a job application or elected to join our Talent Network); 

  • Gather your feedback about and improve our recruitment process; 

  • Analyze and enhance our recruitment communications; 

  • Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users; and  

  • Comply with applicable legal requirements and industry standards and with our policies 

 

If you elect to join our Talent Network, you will have the option of providing additional information- including areas of interest, city, state, country, and whether you are open to relocation- which enables us to better identify job opportunities that may be of interest to you. 

Subject to your preferences, collected at the time you submit your application for a specific job or elect to join our Talent Network, we may contact you about other job opportunities. You have the right to "opt in” and "opt out” of these communications. 

 

4. DISCLOSURE OF YOUR PERSONAL INFORMATION 

When we use your information according to the previous sections, we may share that information as follows: 

 

  • To facilitate the recruitment process, your information will be processed by members of our Global Recruitment Team, who are based in North America, EU/EEA, APAC, South Africa and Latin America on a need-to-know basis. These individuals have received appropriate privacy training, understand their obligations regarding processing personal information and have committed themselves to confidentiality.   

    Sharing your information within Brambles group is subject to an Intragroup Data Transfer Agreement. Additionally, as some of Brambles group entities are located outside the European Union (EU), the European Economic Area (EEA) and the United Kingdom (UK), International Data Transfers will take place in application of the safeguards foreseen in the Standard Contractual Clauses and/or Standard Data Protection Clauses adopted or approved by the European Commission or equivalent supervisory authority. 

  • In order to carry out your requests, to make various features, services and materials available to you, to respond to your inquiries, for the purposes described in the "How We Use Your Personal Information" section of this Notice, we may share your personal information or usage information with third parties that perform functions on our behalf, such as companies or individuals that: provide IT services; host or operate our systems and sites; analyze data; and provide recruitment process support. 

  • We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties for data analysis in order to improve our services and products; our sites and our communication with you. 

  • We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Notice.  

  • If any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties as part of the restricting process. 

  • We may disclose information about you to others if we have a good faith belief that we are required to do so by law or legal process, to respond to claims, or to protect the rights, property or safety of Brambles or others. 

 

5. LEGAL BASIS OF PROCESSING 

We will only collect and process personal data about you where we have a legal basis including: i)your consent- (e.g. when you apply for a job position on our Career Portal or when you join our Talent Network or request that we consider you for other job opportunities); ii) compliance with a legal obligation (e.g. when we need to retain your personal information in order to comply with applicable legal obligations) and iii) the fulfilment of a legitimate interest.  

We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. Please keep in mind that if you object this may affect our ability to perform certain services for your benefit. 

We process your personal information based on legitimate interests in order to: 

  • Protect you, us, or others from security threats 

  • Comply with laws that apply to us 

  • Improve our Portal performance  

  • Enable or administer our business, such as for invoicing and platform maintenance and  

  • Manage complaints regarding a selection process 

 

6. SPECIAL PROVISIONS FOR OUR EUROPEAN AND UK USERS 

By applying for a job opportunity with us and/or by joining our Talent Network, you understand and acknowledge that we may collect, use and disclose personal information in connection with our recruitment process and may provide such information (consistent with the terms of this Notice) within Brambles - any or all of which may be outside your resident jurisdiction. Such processing will occur only where appropriate safeguards are in place, including but not limited to contractual clauses pursuant to the European Commission’s decision 2021/914 as published in O.J. EU 2021 L 199/31 (and is also available online by clicking here or via URL https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj)  or the International Data Transfer Clauses approved by the UK Authorities (“Model Clauses”). 

6.1. Where we store your personal information 

Please be aware that the personal information we collect will be stored outside of the EU/EEA and outside of the UK, and in a database and on servers in the United States and other countries in which the privacy laws may not be as comprehensive as those in your country of residence or citizenship. Such transfers will occur only where appropriate safeguards are in place, including but not limited to Model Clauses. 

For instance, our applicant tracking system is designed and supported by Workday, Inc. and the personal information you provide when applying to a particular job will be stored on its servers located in the United States. 

Similarly, our Talent Network is designed and supported by Workday. If you elect to join our Talent Network your contact information, areas of interest, city, state, country, and whether you are open to relocation, will be stored on Workday servers located in the United States. 

This third party vendor is located in the United States, store personal information on servers in the United States, and provide system support from the United States. Accordingly, Workday has entered into Data Processing Addendum with us that are GDPR compliant and include Model Clauses. 

6.2 European and UK Supervisory Authorities 

You have the right to register a complaint with a European data protection or supervisory authority about our collection and use of your personal information. For more information, please contact your local data protection authority (contact details for data protection authorities are available at https://ec.europa.eu/newsroom/article29/items and for the UK data protection authority at https://ico.org.uk/). 

7. YOUR PRIVACY RIGHTS 

Depending on the country where you are based, you may: (i) request information on and access to the personal information we hold about you including requesting a copy of your personal information (Right of Access); (ii) request that we correct any inaccurate personal information we hold  about you (Right to Rectification); (iii) object to certain types of processing of your personal information we carry out (including the right to opt-out of any direct marketing) (Right to Object);  (iv) request that we delete the personal information We hold about you (Right to Erasure);  (v) request that we restrict our processing of your personal information in certain circumstances, such as when you contest the accuracy of that personal information (Right to Restriction of Processing); (vi) request a copy of your personal information in a machine readable, commonly used format or request we transfer your personal information in such a format to a third party service provider (Right to Data Portability);  (vii) request not be subject to an automated decision-making or profiling; and/or (viii) withdraw your consent at any time when we process your personal information based on your consent.  

Whilst some of these rights can be exercised by you directly through this Website, many of the rights, such as those relating to requests to delete your personal data, will need to be submitted to privacy@brambles.com or by clicking here to complete the Privacy Rights Intake Form. If you are a California user, you could also exercise your privacy rights by calling 1-855-409-0019 (toll-free number).  If you have any questions about the form, the exercise of privacy rights, or privacy related questions in general, you can contact us at privacy@brambles.com.  

We will consider each request and respond to you within the applicable deadline as per the applicable jurisdiction. If we deny the request, we will notify you of the reasons for the denial. We may charge you a small fee and may require verification of your identity before providing a copy of your information as permitted by law. 

8. DATA RETENTION 

If you are not the successful candidate for a job opportunity to which you applied, we will securely store your information and will destroy your information after the lesser of two years or the maximum period in which a legal claim about the recruitment process may be brought against us. In any event, your personal data will be retained consistent in accordance with the Brambles Global Record Retention Policy and Schedule. 

We will not retain your employment information to consider in relation to job opportunities to which you have not applied unless you have been asked for, and have given, your consent (e.g., by joining our Talent Network). 

9. SECURITY 

We maintain certain administrative, technical and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of your personal information. However, no electronic data transmission or storage of information can be completely secure. We cannot ensure or warrant the security of any information you transmit to us or that we acquire. Accordingly, you must use our Website at your own risk. 

If, despite all our efforts, a data breach does occur, we shall do everything reasonably practicable to limit the damage. In case of a data breach, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. 

10. HOW TO CONTACT US 

If you have any questions, comments or concerns about this Notice, or data protection concerns in general, please  send us an email to privacy@brambles.com. For the exercise of Privacy Rights, please visit “Your Privacy Rights” section of this Privacy Notice. . 

 

11. PRIVACY NOTICE UPDATES 

We reserve the right to modify or supplement this Privacy Notice at any time. Changes to the policy will be posted at least 30 days prior to the effective date of the changes. The date below indicates when this Notice was last changed. 

This Notice was last updated on April 30, 2022, effective May 3, 2022. 

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Brambles Applicant Privacy Notice | CHEP