Global Employment Applicant and Talent Community Privacy Notice
Lumen is committed to ensuring that your personal data is protected and used appropriately. This Privacy Notice explains how Lumen will collect, use, and store your personal data relating to the talent acquisition and recruitment process, including the Talent Community, as well as your rights with respect to such personal data.
In this Privacy Notice, "Lumen" refers to the Lumen company providing the career website and Talent Community, any Lumen company to which you are applying for a role, and each of their affiliates, subsidiary, or parent.
What is the kind of personal data we hold about you?
When 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:
Lumen is committed to ensuring that your personal data is protected and used appropriately. This Privacy Notice explains how Lumen will collect, use, and store your personal data relating to the talent acquisition and recruitment process, including the Talent Community, as well as your rights with respect to such personal data.
In this Privacy Notice, "Lumen" refers to the Lumen company providing the career website and Talent Community, any Lumen company to which you are applying for a role, and each of their affiliates, subsidiary, or parent.
What is the kind of personal data we hold about you?
When 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:
- Your name, address, and contact details, including postal and email address and telephone number(s);
- CV and Educational/Professional Background information, including degrees you have earned, schools attended, licenses held, memberships in professional associations, academic record, skills, experience, and employment history.;
- IP address and history of searches on Lumen career website;
- Information from you obtained during interviews and phone-screenings;
- Where legally permissable, information about your current level of remuneration;
- Information relating to your entitlement to work in the country where the position reports to work.
We may collect this information directly from you, such as from the application forms or CVs, interviews, or from publicly accessible sources, such as LinkedIn. We will seek information directly from third parties such as for background checks, only once a job offer has been made to you. We may ask you for additional personal data to assist us in evaluating your qualifications and fitness for the position and to process your application. We may also collect some information from you automatically when you use our websites as noted in our privacy policy and our cookie policy.
If you choose to join Lumen's Talent Community, that focuses 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, area of interest (job category), and, if you choose to provide it: city, telephone number, and resume.
Data will be stored in various places, including on your application record, in our HR management systems, and our email system.
What does Lumen do with the personal data and why?
We collect and process your personal data to:
- Identify you and create a careers account
- Facilitate and manage the application and recruitment process
- Assess skills, qualifications, and suitability for the role and decide to whom to offer a job
- Carry out background and reference checks, where applicable and legally permissable
- Communicate with you about the recruitment process, in relation to your application or roles we believe you might be interested in, and to respond to your queries and requests
- Keep records related to our hiring processes and to assist in any legal disputes, claims, or investigations, including defending against any legal claims
- Comply with legal or regulatory requirements or obligations, including assessing whether a work permit, visa, or similar document may be necessary for the role
- Allow us to improve the user experience with our website
- 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
Except as specifically requested or legally required, we ask that you avoid submitting information which may qualify as sensitive information under applicable law. Lumen may collect and process information about your disability status to consider whether we need to provide reasonable adjustment for a candidate who has a disability. We will not use this data for any other purpose than the recruitment and hiring process.
Candidates for positions located in Europe will not be subject to decisions that will have a significant impact on candidates based solely on automated decision-making; however, outside Europe, Lumen does use automated decision-making questions, for example: "Do you have a valid driver's license?" to which candidate's response may automatically eliminate a candidate from consideration for a particular position (for example, a position that requires a valid driver's license).
Lumen must have a lawful basis to process personal data. In most cases, the lawful basis will be to meet our legitimate interest in processing personal data 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, and to comply with our legal obligations. When we process personal data, we put in place appropriate security measures to help prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed.
Who has access to data?
Lumen is a global enterprise headquartered in the United States and comprises a group of companies operating internationally. We share your personal data with 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 HR team, interviewers involved in the recruitment process, and managers in the business area with a vacancy.
Generally, we will not share your data with third parties, however, we may need to share your personal data with law enforcement agencies, courts, regulators, government authorities, or other third party where we believe it is necessary to comply with a legal or regulatory obligation, or to protect our rights or the rights of others. If Lumen makes 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.
How does Lumen protect data?
We take the security of your data 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. In addition, we limit acces to your personal data to those who have a business need-to-know. Lumen has standard contractual clause contracts in place governing transfers of personal data from the EU and EEA to the United States.
How long does Lumen retain data?
We keep your personal data only for as long as we need to for the reasons given in this privacy notice and for as long as we are required by law or regulatory obligation. We will take reasonable steps to delete your personal data when it is no longer required for these purposes.
What are your rights?
You can decide not to provide certain information, or you may ask that certain information you previously shared be deleted. However, if you do not provide the information, we may not be able to process your application.
Under certain circumstances, you may have the right by law to:
- Request access and obtain a copy of your data;
- Request a change to incorrect or incomplete data;
- Request that Lumen delete or stop processing your data, for example, where the data is no longer necessary for the purposes of processing;
- Object to the processing of your data where Lumen is relying on its legitimate interests as the legal ground for processing; or
- Request the transfer of your personal data to another organization.
If you want to review, verify, or correct your personal data, you can do so by logging into the online system. If you wish to request erasure of your personal data or to object to the processing of your personal data, or have other questions, comments, or concerns, or wish to make a complaint about how we use the personal data we hold about you please send an email. If you reside in the EU, you may 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.
Changes to the notice:
You may review this privacy notice on the Lumen career website or request a copy via email. 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 data 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: September 2020