Effective Date: 9/27/18

This Job Applicant Privacy Notice (“Privacy Notice”) applies to job applicants and tells you how

Havas Health, Inc., Havas PR North America, Inc., Havas PR Arizona, LLC, Havas Gemini, LLC, Symbiotix, LLC, and the Havas Life Toronto, Health4Brands Toronto, and Sciterion divisions of Havas Canada Holdings, Inc. (“Havas”) process the personal data you submit as part of the application and selection process (or ask a recruiter to do so on your behalf). It also describes your data protection rights, including a right to object to some of the processing which Havas carries out. More information about your rights, and how to exercise them, is set out in the “Your Rights” Section.

We may also provide you with additional information when we collect personal data, where we feel this would be helpful to provide relevant and timely information.

What Personal Data We Collect

Havas collects and processes the following types of personal data about you in connection with your job application.

  • Contact details: such as your name, home address, email address, phone number;
  • Information relating to your career: such as job history, academic background, qualifications, professional and personal competencies and skills, your job expectations;
  • Information about your salary expectations;
  • Information relating to your employment references (you will have ensured you have obtained consent from your references prior to providing us the information);
  • Information collected as part of the hiring process such as assessments;
  • Identification information, as part of the pre-hiring process: such as copies of identification documents, immigration status, and where permitted, information concerning your race and ethnicity (for equal opportunity monitoring purposes);
  • Any other information you submit to us as part of the recruitment process.

Such personal data may be collected in different ways: it may be contained in your CV or resume, in your application form, your cover letter, your identification document, or it may be gathered from interviews or assessments you take during the recruitment process. In some cases, it may also be collected from third parties, for example when seeking employment references or if we receive details of a certification or training you obtained. We may also receive your CV or resume from recruiters and the results of verification and vetting checks from background checking providers.

Unless specifically responding to a question asked by us please do not include any sensitive data as part of your application, i.e. information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status or sexuality, or information regarding criminal convictions. If we do require this information in connection with your application, this will be highlighted to you where we will obtain any necessary consents or acknowledgements.

Havas is committed to leveraging each applicant’s skills and competencies to find the right match for a role in the organization as opportunities arise.

If you are successfully hired, Havas keeps this information for the course of the employment relationship and, to the extent permitted, after termination of employment. The protection of your personal data will then be governed by the applicable Havas Privacy Policy.

If your application is not successful, we will retain your personal data for a period so that we can consider you for future job opportunities that may be relevant to you, and so that we can identify those candidates that have previously applied to work for the company in future application processes. Havas determines the retention period of your information based on the following retention criteria:

  • Havas retains your personal data as long as it has an ongoing relationship with you;
  • Havas retains your personal data where it is required to do so by a legal obligation to which it is subject;
  • Havas retains your personal data where this is advisable to safeguard or improve Havas’ legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).

If you wish to have your personal data deleted at any time during this period, you may contact us at the email address set forth in the Contact Us section below.

Why We Collect, Use and Store Personal Data

Havas processes this personal data for the following purposes:

  • As required to establish and perform the employment contract. This includes processing your application for a specific job.
  • Where necessary for Havas’ or another third party’s legitimate interests, as listed below, and where these interests are not overridden by your data protection rights.
    • Administrating the recruitment process,
    • Managing the selection process, making appropriate employment offer,
    • Protecting our legitimate business interests and legal rights,
    • Where permitted, analyzing and monitoring the diversity of the applicants, in accordance with applicable laws – this includes for example, compliance with equal opportunity employment laws,
    • Carrying out background checks to verify the details you have supplied during the recruitment process.
  • Where required by applicable laws, Immigration documentation is processed to ensure the candidate is entitled to work on the territory where the job is located.
  • To comply with specific provisions of law concerning personal data processing at work or for reasons of substantial public interest as determined by local law.

We have conducted balancing tests for all the personal data processing we carry out on the basis of legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us at the email address set forth in the “Contact Us” Section below.

International Transfers

Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Havas global organization. Individuals performing administrative functions and IT personnel within Havas may also have a limited access to your personal data to perform their jobs.

We use third party service providers to provide a recruiting software system. We also share your personal data with other third-party service providers that may assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data.

Havas has appropriate safeguards in place to protect your personal data and, where required by law, we put in place legal mechanisms designed to ensure adequate data protection of your personal data. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, the EU-U.S. Privacy Shield, and the Swiss-U.S. Privacy Shield, please contact us at the address provided at the end of this Privacy Notice.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

How Your Personal Data is Shared

We share some of your information with other members of the Havas companies to administer and manage the recruitment process. We also share your information with any other Havas company to whom you make an application or with whom you communicate.

Where this requires us to transfer your personal data from within the EEA to outside the EEA, please refer to the “International Transfers” Section above for further details on cross-border transfers.

Your personal data will also be shared with companies providing services under contract to the Havas companies such as software and data storage providers. In addition, it may also be shared with government authorities, regulators and/or law enforcement officials if required for the purposes above, if mandated by law and if required for the legal protection of Havas’ legitimate interests in compliance with applicable laws.

How We Protect Your Personal Data

Havas employs organizational, technical, and physical security measures in order to protect your data from loss or misuse. Where we contract with third-party suppliers to provide services that may enable them to access your personal data, we require them by contract to have similar security controls in place.

Your Rights

You have the right to ask Havas for a copy of your personal data, to correct, delete or restrict processing of your personal data, and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular where we don’t have to process the personal data to meet a contractual or other legal requirement).

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Havas processing your personal data, this will not affect any processing which has already taken place at that time. There are exceptions to these rights so that access may be denied, for example, if making the information available would reveal personal data about another person or if Havas is legally prevented from disclosing such information. Relevant exemptions are included in both the GDPR and in local data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

We do not make recruiting or hiring decisions based solely on automated decision-making.

Where we require personal data to comply with legal or contractual obligations, then provision of such personal data is mandatory: if such personal data is not provided, then we will not be able to manage the recruitment process or meet obligations placed on us. In all other cases, provision of requested personal data is optional. However, if not provided, we may not be able to process your application properly.

If you would like to make a request to access, review, correct, or delete the personal data we have collected about you, or to discuss how we process your personal data, please contact us at hh‑privacyadmin@havashealth.com. To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law.

It is important that we maintain up to date records of key information on you. Please notify us of any changes in your personal circumstances as soon as they occur (e.g., change of address).

We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in Havas’ discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law. If you have unresolved concerns, you have the right to complain to the data protection authority in the country where you live, work or where we are located. You may also be able to seek a remedy through the courts if you believe that your rights have been breached.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically. We will update the date at the top of this Privacy Notice accordingly. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Privacy Notice as required by applicable law.

Contact Us

Havas will be the data controller for your personal data.

If you have questions about this Privacy Notice or wish to contact us for any reason in relation to our personal data processing, please contact hh‑privacyadmin@havashealth.com or at the address below:

Bill Gallagher
Data Protection Officer
200 Madison Avenue
New York, New York 10016
Attn: Privacy