PrivacyPolicy

1. Global Employment Applicant and Talent Community Privacy Notice

Lumen is committed to implementing measures to protect and limit use of Personal Information. This Applicant Privacy Notice (“Privacy Notice”) explains how Lumen will collect, use, and store your Personal Information relating to the talent acquisition and recruitment process, including through our careers portal (the “Talent Community”), as well as your rights with respect to such Personal Information.

In this Privacy Notice, "Lumen" refers to the Lumen company providing the career website and Talent Community, and any Lumen affiliate company to which you are applying for a role (for additional details related to Lumen’s privacy practices, you can review Lumen’s Privacy Center).

2. Scope of this Privacy Notice

This Privacy Notice applies to any information we collect about Applicants that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly, with an individual (“Personal Information”). Our information practices may vary depending upon certain circumstances, such as the location or role for which you are applying.

This Privacy Notice does not address or apply to our handling of certain information (for which we may provide additional notices), such as:

Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience
Deidentified/Anonymized Information. Information that is deidentified or anonymized in accordance with applicable laws.
Aggregated Information. Information that relates to a group from which individual identities have been removed.
Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act or similar state laws.
Activities Covered by the Fair Credit Act. This includes information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act, e.g., information contained in background checks reports we obtain as part of our vetting process.

This Privacy Notice also does not apply to the Personal Information we collect from our customers, contractors, employees, or our Applicants when they use our products and services in their personal capacity. For additional information on our general privacy practices, please visit Lumen’s Privacy Center.

3. What Personal Information Do We Collect?

We may provide Applicants with additional notices about our information practices that are covered by other laws (e.g., if we conduct a background check).

If you create a user account on the Lumen Careers or Talent Community website, you will be asked for your email address and to create a password. This will enable you to apply for job vacancies via our online portal. When you apply for a job at Lumen, you will be asked to complete an online job application and to attach a CV/resume.

As part of the recruitment and hiring process, we will collect, use, and store a range of information about you, which may include:

Identifiers, such as your name, address, and contact details, including postal and email address, and telephone number(s).
Characteristics of Protected Classifications, such as age (40 years or older), race, ancestry, national origin, citizenship, physical or mental disability, sex, veteran or military status, and other characteristics of protected classifications under California or US Federal law.
Geolocation Data, such as information derived from your IP address to enable us to show you open positions relevant to your geographic location.
Internet or Other Electric Network Activity Information, such as information about applicants’ interaction with our portals, website, applications, or advertisements, including, but not limited to, IP address, browsing history, clickstream data, and search history.
Audio, Electric, Visual, or Similar Information, such as information collected via call recordings, recorded meetings, videos, photographs, and video footage to secure our offices and premises.
Employment-Related Information, such as previous positions held, skills and experience, results of measures of job related capabilities job duties, entitlement to work in the country where the position reports to work, information obtained during interviews and phone-screening calls, and, when lawful, information about your current level of remuneration.
Education Information, such as educational / professional background information, including degrees earned, schools attended, licenses held, memberships in professional associations, academic record.
Sensitive Personal Information, such as your social security number, government identifier, driver's license number, race or ethnic origin, medical condition, results of drug screening tests, and physical or mental disability.
Inferences and Preferences, such as an applicant's preferences, characteristics, attitudes, behaviors, and abilities.

If you choose to join Lumen's Talent Community (our careers portal focused on Lumen positions located in the United States), we collect the following information to create a talent profile for you: first and last name, email, country, state or province, area of interest (job category), and, if you choose to provide it: city, telephone number, and resume.

4. Sources of Personal Information

We may collect this information directly from the following categories of sources:

From you directly, such as from the application forms or CVs, interviews.
From you automatically when you use our websites or careers portal (as noted in our Cookie Policy).
From recruiters and recruiting platforms.
From publicly accessible sources, such as LinkedIn.
From former employers (with your permission).
From our service providers, representatives, and agents.
From any references you provide.

When we conduct background checks we do so only once a job offer has been made to you. However, for many open positions we may conduct measures of job related capabilities using a service provider prior to an offer of employment. We receive the full results of these measures of job related capabilities from our service provider.

5. Why Do We Collect Personal Information?

We generally collect and process your Personal Information as necessary for the following purposes:

Recruiting and Hiring. We use Personal Information from your application, from measures of job related capabilities, and collected through the interview process to evaluate your qualifications and eligibility for employment. This includes identifying you, creating a careers account, scheduling interviews, conducting background checks, conducting the measures of job related capabilities, evaluating skills and qualifications, extending offers, communicating with you, responding to your inquiries and requests, maintaining applicant information for future consideration, and supporting our equal opportunity employment practices.
Defending and Protecting Rights. We use Personal Information to protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant and other disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, including without limitation, our trade secrets and other intellectual property, and protecting the rights, property, and reputation of Lumen and its workforce, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
Compliance with Legal Obligations. We use Personal Information to comply with applicable legal obligations (such as determining hiring eligibility or responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.
Reasonable Accommodation Determination. Except as specifically requested or legally required, we ask that you avoid submitting information that may qualify as sensitive information under applicable law. To the extent needed, Lumen may collect and process information about disability status to consider whether to provide a reasonable accommodation for a candidate who has a disability. We will not use this information for any other purpose than the recruitment and hiring process or as otherwise described in this notice.

Job Alerts. We use Personal Information to send job alerts and company updates to Talent Community members who indicate interest in a category of information and have not opted out of receiving those emails., or opted in depending on regulations in your region.

Develop and Improve our Site. We use Personal Information to improve the user experience on our website and careers portal, including on Talent Community.

6. Candidates Outside of the United States

Candidates for positions located outside of the United States (including candidates in Quebec, Canada) will not be subject to decisions that will have a significant impact on candidates based solely on automated decision-making. However, Lumen reserves the right to use such decisions where allowed by applicable law. For example, as part of a job application we may ask "Do you have a valid driver's license?" to which a candidate's response may automatically eliminate them from consideration for a particular position if that position requires a valid driver's license.

For EU and UK candidates, Lumen must have a lawful basis to process Personal Information. In most cases, the lawful basis will be to meet our legitimate interest in processing Personal Information during the recruitment process to attract candidates to apply for roles, to determine the best candidate for the role, to keep records of the process, only for the period of time required to comply with our legal obligations. When we process Personal Information, we put in place appropriate security measures to help prevent your Personal Information from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized way.

7. Disclosure of Personal Information

Lumen is a global enterprise headquartered in the United States and comprises a group of companies operating internationally. We disclose your Personal Information to other Lumen companies globally for the purposes outlined in this Privacy Notice. During the recruitment and hiring process, the information may be shared among various employees or teams involved in the recruitment and hiring process who have a business need-to-know, such as members of the Human Resources team, interviewers involved in the recruitment process, and managers in the business area with a vacancy.

We may disclose your Personal Information for the following purposes:

To Evaluate Your Application/Candidacy. We may disclose Personal Information when it is necessary to provide services you request and where it is necessary to identify applicants, schedule interviews, and otherwise evaluate your qualifications and eligibility for employment.
To Make You an Offer. If we make you an offer of employment, we may ask you to share certain information with a third party, or, in limited situations we may provide it, in order to complete the hiring and probationary process.
To Enforce Rights. We may disclose Personal Information if required to do so by law, to protect our rights, property, or the safety of others, or where we have a legitimate interest in doing so.

We may disclose your Personal Information to the following categories of recipients:

Affiliates and Business Partners. We may disclose Personal Information to our affiliates and business partners where necessary to evaluate your candidacy for employment or for business operations purposes.
Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf, such as recruiters or recruitment platform providers. Our service providers are required to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes.
Government Entities and Agencies. To comply with our legal obligations and where otherwise required by law, we may disclose the following categories of Personal Information to applicable regulatory and government entities: identifiers, characteristics of protected classifications, and employment-related information.

8. Security

We take the security of your Personal Information very seriously. We have internal policies and controls in place to help protect your data against loss, accidental destruction, misuse or disclosure, and unauthorized access. Lumen has standard contractual clause contracts in place governing transfers of personal data from the EU and EEA to the United States. Please be aware that despite our efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your passwords and login details.

9. How Long Does Lumen Retain Personal Information?

We store your Personal Information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data).

Rather than delete your Personal Information, we may also deidentify it in accordance with applicable privacy regulations, by removing identifying details. If we deidentify any Personal Information, we will not attempt to reidentify it.

10. Your Rights

When you interact with us you can decide not to provide certain information. However, if you do not provide the information, we may not be able to properly process your application or consider you for a position.

Under certain circumstances and subject to applicable legal requirements, restrictions, and exceptions, you may have the right to:

Request access and obtain a copy of your Personal Information, including certain information about our handling of your Personal Information (such as the categories, sources, and purposes of collection and disclosure);
Request a change to incorrect or incomplete data;
Request that we delete or stop processing your data, for example, where the data is no longer necessary for the purposes of processing;
Request we limit our use of sensitive personal information to certain permissible purposes (however, note that we do not use your sensitive personal information for any purposes other than as necessary to process your application or according to a legal obligation);
Object to the processing of your data where Lumen is relying on its legitimate interests as the legal ground for processing;
Request the transfer of your Personal Information to another organization; or
Not be discriminated against for exercising any of your rights with regard to Personal Information.

If you want to review, verify, or correct your Personal Information, you can do so by logging into our online system. If you wish to make a privacy request relating to your Personal Information (e.g., access, erasure, correction, objection, etc.), or have other questions, comments, or concerns, or wish to make a complaint about how we use the Personal Information we hold about you, you can refer to Lumen’s Privacy Center or send an email to DPO@lumen.com.

To verify your identity, we will need you to provide your full name, the email address you used to communicate with us, your address (if you previously provided it to us), and any applicant number you were assigned. In some cases, we may need additional information from you in order to verify your identity. If we are unable to verify your identity after a good faith attempt, we may deny your request and will explain the basis for the denial.

You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf

If you are located in the EU, you have the right to lodge a complaint with your data protection authority. If you reside in the UK, you can lodge a complaint with the UK Information Commissioner's Office.

11. Changes To This Privacy Notice

You may review this Privacy Notice on the Lumen career website or request a copy by emailing DPO@lumen.com. We may modify or update this Privacy Notice from time to time, so please check back periodically for changes by checking the date posted on the notice. Where changes to this Privacy Notice have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient notice so that you have the opportunity to exercise your rights. By sharing your Personal Information with us, and by continuing to use our careers website, you confirm that you have read and understand the terms of this Privacy Notice.

Dated: June 2023

GLOBAL EMPLOYMENT APPLICANT AND TALENT COMMUNITY PRIVACY NOTICE