PagerDuty EEA CANDIDATE DATA PROCESSING NOTICE
This EEA Candidate Data Processing Notice (this “Notice”) describes how PagerDuty, Inc., a corporation located at 600 Townsend St., #200, San Francisco, CA 94103 (“PagerDuty” or “we”), as data controller, will collect, process and use the personal data you submit when applying for a position with PagerDuty or one of its affiliates through this website. The specific entity you are applying to work for is part of a wider group of companies with headquarters at PagerDuty, Inc. (the “PagerDuty Group”). In this Notice, “personal data” means any information relating to you, that identifies you, or could reasonably be used to identify you.
If you do not want your personal data processed via the website as described in this Notice, please do not submit any information or apply for a job through this website. You may alternatively contact us at the contact information provided below for further information on how to apply for a position. We will in any case need to collect certain personal data from you to assess your employment application.
What personal data do we process?
We will collect, process and use the following types of personal data which you provide as part of your initial submission or otherwise make available to us as part of the application process:
- Identification information, such as your name, date and place of birth, and address;
- Experience information, such as education and work experience, contact details of your former/current employer, information about your educational background, your work experience and other experience; and
- Other information you submit, such as the information you provide in an application form, CV or resume or public profile you share with us.
If your application progresses, we may also collect and process the following:
- Information collected as part of the interview process, such as notes taken from your interview;
- Background check information, such as information obtained through reference checks, subject to any further permissions or notifications required by applicable law; and
- Information required to initiate employment, such as proof of eligibility to work in country (g., a passport or visa), tax information, bank account information, benefits eligibility information and other information you provide for the purposes of starting employment or performing an employment contract.
For what purposes do we process your personal data?
In summary, we will collect and use the personal data you provide to process your application for employment and comply with statutory obligations we have in relation to your application. Your personal data will be used and disclosed only for the legitimate business purposes of administering and evaluating your application and completing the on-boarding/new hire process, should you be offered and accept a position with a PagerDuty company.
We will use your personal data for a variety of reasons linked to processing your application as set out below (the “Processing Purposes”):
- Administering and processing your application, including your identification, experience and other information you submit and, if your application progresses, any interview information and background check information;
- Determining your suitability for the role for which you have applied or for similar roles within the PagerDuty Group, including your identification, experience and other information you submit and, if your application progresses, any interview information and background check information;
- Conducting background checks as part of your application, subject to applicable law, including your identification, experience and other information you submit and, if your application progresses, any interview information and background check information; and
- Complying with applicable laws and employment-related requirements, including identification information and information required to initiate employment, for purposes such as confirming ability to legally work, setting up payroll, withholdings and benefits, and complying with statutory reporting requirements.
What are our legal justifications for the processing of your personal data?
We process the personal data you submit in your initial submission on the basis of your consent, pursuant to GDPR Art. 6(1)(a).
We process any personal data that you provide as part of our follow-on interactions with you to comply with our legal obligations, pursuant to GDPR Art. 6(1)(c), and to pursue legitimate interests, including to evaluate your credentials to determine whether to hire you, pursuant to GDPR Art. 6(1)(f).
What information should be submitted?
Resumes/CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). If you provide information about others (e.g., reference contact details), please first ensure you have informed them that you will be providing their information and that they are happy for you to provide it to us.
Generally, we recommend that you do not disclose sensitive personal characteristics (e.g., gender, height, weight, religion, philosophical or political beliefs, financial data, age) in your resume/CV or any materials you submit in support of your application.
Any misleading, false or willful omission of relevant information may be sufficient reason for refusal of employment, or suspension or dismissal from employment. Please submit only accurate information.
Who, other than PagerDuty, may access your personal data?
Your personal data may be shared with the following parties as necessary for the Processing Purposes:
- Other PagerDuty Group companies: PagerDuty Group companies share human resources and management decisions, and we may transfer your personal data to the hiring entity to make the hiring decision and to other entities within the group to monitor and assure compliance with applicable policies and procedures and applicable laws.
- Third-party service providers: Our service providers may carry out instructions relating to IT hosting services or similar functions, recruitment or workforce administration. Where required, they will be subject to contractual obligations to implement appropriate technical and organizational measures to safeguard personal data, and to process it only as instructed.
- Regulators, authorities and other recipients: These parties include courts and other public authorities, independent external advisers and internal compliance and investigation teams.
Only authorized PagerDuty personnel (talent acquisition, human resources, legal, and appropriate managers) will have access to your personal data for the legitimate business purposes described in this Notice.
What is the legal justification for our transfer of personal data to recipients?
Some recipients located outside of the European Economic Area (“EEA”) are located in countries for which the European Commission has issued adequacy decisions. In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (GDPR Art. 45).
Some recipients are located in countries for which the European Commission has not issued an adequacy decision in respect of the level of data protection there, mainly the United States. By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in GDPR Art. 46(5) or other adequate means, we have established that all such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including to our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by applicable law.
You can ask for a copy of such appropriate data transfer agreements by contacting us as set out at the bottom of this Notice.
How long is your personal data retained?
PagerDuty will retain personal data no longer than is necessary to carry out the Processing Purposes described in this Notice and/or as required by applicable law.
We may, with your consent, and also subject to different retention requirements under any applicable law, retain your information after the recruitment process is complete to contact you about potential future opportunities or for record keeping purposes.
We will delete your personal data when we no longer need it for the Processing Purposes. Any personal data retained will be processed, used, disclosed, and stored in accordance with this Notice. If you do not want your information retained in the event that you are not offered a position, you can request deletion by contacting us. However, we may retain some of your information for longer in an anonymized form for statistical purposes, including to meet statutory and regulatory requirements.
What are your rights in respect of your personal data?
Under the conditions set out under applicable law (i.e., the GDPR), you have the following rights:
- Right of access: You have the right to obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to the personal data. The access information includes, among other things, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You have the right to obtain a copy of the personal data undergoing processing. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs.
- Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure (to be forgotten): You have the right to ask us to erase your personal data.
- Right to restriction of processing: You have the right to request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.
- Right to data portability: You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.
Please note that these rights might be limited under applicable national data protection laws. You also have the right to lodge a complaint with the competent supervisory authority. If you would like to exercise any of these rights, please contact us via the details listed below.
How can you obtain more information?
If you have questions about this Notice, our privacy practices or the personal data we collect about you, or have requests related to such personal data, please contact firstname.lastname@example.org.