CPRA Candidate notice supplement | HCLTech

CPRA Candidate notice supplement

For California Residents

This privacy statement (‘California Privacy Notice’) supplements the information contained in the Global Candidate Data Privacy Notice of HCL Technologies Inc. (‘HCLTech’ or ‘we’) and applies solely to California resident job applicant(s)/candidate(s) (‘you’). We adopt this California Privacy Notice to comply with the California Consumer Privacy Act of 2018 (‘CCPA’), as amended by the California Privacy Rights Act of 2020 (‘CPRA’) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

Information We Collect

We collect information that relates to, is capable of being associated with, or could reasonably be linked to you or one of your devices (‘personal information’). In particular, where permissible, we have collected the following categories of personal information within the last twelve (12) months:

  • Identifiers, such as name, postal address, email address and government-issued identifier;
  • Personal information, as defined in the California Customer Records statute, including without limitation, address, contact details, education, social security number and employment history;
  • Characteristics of protected classifications under California or federal law, including citizenship, race, gender, ethnicity, disability, nationality or veteran details;
  • Internet or network activity information, such as browsing history and interactions with HCLTech information systems;
  • Geolocation data, such as device location;
  • Audio, electronic, visual and similar information, such as call and video recordings;
  • Professional or employment-related information, such as work history and prior employer;
  • Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
  • Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Categories of Sources of Personal Information

We collect this personal information directly from you or from third-party sources as part of your recruitment process with HCLTech.

Use of Personal Information

In course of managing employment relationships and accomplishing our business objectives, we may use your personal information for the following purposes:

  • Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, and onboarding;
  • Verifying identity and communicating with employees and/or employees’ reference contacts;
  • Performing accounting, audit, and other internal functions including internal investigations;
  • Conducting risk and security controls and monitoring;
  • Engaging in workforce research and analytics;
  • Complying with applicable state and federal laws including labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity and workplace safety laws;
  • Complying with internal policies; and
  • Exercising and defending legal claims.
Disclosure of Personal Information

We may disclose your personal information to third parties, such as our service providers and affiliates, for our operational business purposes including background checks, third-party human resources and information application services, outside legal counsel services, and state or federal governmental agencies requests:

When we disclose personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the past twelve (12) months, we have disclosed (where permissible) the following categories of personal information for our business purposes:

  • Identifiers
  • California Customer Records
  • Characteristics of protected classifications under California or federal law
  • Internet or network activity information, such as browsing history and interactions with our websites;
  • Geolocation data, such as device location;
  • Audio, electronic, visual and similar information, such as call and video recordings;
  • Professional or employment-related information;
  • Non-public education information (per the Family Educational Rights and Privacy Act); and
  • Inferences drawn from any of the information
Sharing and Sale of Personal Information

For the purposes of CCPA, HCLTech does not “sell” or “share” your personal information and has not “sold” or “shared” your personal information in the last 12 months.

Your Rights and Choices

CCPA provides you with specific rights regarding your personal information. This section explains those rights.

Access to Specific Information and Data Portability Rights: You have the right to request that we disclose certain information to you about our collection, use, disclosure, and/or sale of your personal information (if applicable) over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:

  • The categories of personal information we have collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting, selling or sharing (if applicable) your personal information;
  • The categories of third parties to whom we disclose your personal information;
  • The categories of personal information that the business disclosed about you for a business purpose; and
  • The specific pieces of Personal Information we collected about you (also known as right to ‘data portability’).

Correction or Deletion: You can request rectification (correction, updating or modification) or deletion of the Personal Information that HCLTech has collected from your use of our services. We will comply with your request as required by law, but this right does not apply where HCLTech needs to retain the personal information in order to provide goods or services to you, detect or resolve security issues or functionality-related issues, comply with the law, and carry out internal business requirements.

Should you choose to exercise any of your rights, HCLTech will not discriminate against you in any way.

How to Exercise Your Rights

To exercise any of the rights described above, please submit a verifiable request to us through our Data Subject Request Portal or alternatively, email us at privacy@hcl.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request. The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or an authorized representative).
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity and confirm the personal information relates to you. We will only use personal information provided in a verifiable request to verify the requestor's identity and/or authority to make the request.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing, by mail or electronically, at your option. We will deliver our written response by mail or electronically.

You can designate an authorized agent to make a request under the CCPA on your behalf provided that (1) it is a natural person or a business entity registered with the Secretary of State of California; and (2) you have authorized the authorized agent to act on your behalf.

Authorized agents may use the Data Subject Request Portal for further instructions. To protect your information, please note that we may take steps to verify your identity and we will also ask for a signed permission from you authorizing the authorized agent to submit a request on your behalf.

How long do we retain your personal data?

We retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected, or longer if required to fulfil our legal and contractual obligations. After expiration of the retention period, your personal data will be deleted. If We are unable to completely delete the personal data from our systems, We will ensure that there are appropriate measures in place to secure the information and protect it from further use.