Menlo Global Candidate Privacy Notice
Menlo Security, Inc., along with its affiliates and subsidiaries worldwide (collectively, “Menlo,” “we,” “us,” or “our”), is committed to handling personal data responsibly and in accordance with applicable law. This Candidate Privacy Notice (“Notice”) explains our data collection and processing practices in the context of our employment opportunities.
Please note that this Notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Our processing of personal data is in all cases subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate). To the extent this notice conflicts with local law in your jurisdictions, local law controls.
What information do we collect from job applicants?
When we consider you for opportunities at Menlo, the types of data we collect and process, include:
- Your name, contact information (such as address, phone number, email address), gender, work permit or visa information, employment and education history, referrals or references, and any other information you provide (such as information on your resume or cover letter)
- Desired salary, location preferences, other job preferences
- Information that you make publicly available in connection with your application, such as contact information, your education, and work experience information (e.g. when you share information via job search and career networking sites as far as it is relevant to consider you for career opportunities and in accordance with your privacy settings on those services)
- Interview details, and outcomes of any recruiting exercises you complete
- If disclosed, any special needs, health condition, or information relating to accommodations that you may request during the recruiting process
- If you're being referred, information that the person referring you provides about you
- We also sometimes receive information such as your education and work experience, contact information, and demographics, from third-party data providers who have the rights to provide us with your information. These partners collect your information from publicly available sources, or through third parties they work with.
- Any information that applicable local laws require us to collect in connection with the recruiting process
How do we use this information?
We use the information we collect from and about you to:
- Consider you for employment with Menlo – including to assess your suitability for a particular role or roles, facilitate the recruiting and interview process, verify the information you or others provide about your candidacy, and to present you with an offer of employment if your application is successful
- Communicate and stay in touch with you – when you apply for a position with Menlo, we may also consider you for any current and future opportunities that match your background. To do so, we may contact you from time to time about potential opportunities or employment-related events. You can opt out of receipt of such communications at any time.
- Maintain and improve our recruitment process – for example, to manage and improve our application and interview process and perform management reporting and analysis related to recruiting metrics and success factors.
- Comply with laws and regulations – for example, local laws may require us to submit reports about our recruiting processes and outcomes.
- To perform background checks – if you accept a conditional offer from us, we may need to use your information to perform background checks as permitted or required under local laws.
How do we share this information?
We share job applicant information for some limited purposes as follows:
- Within the Menlo family of companies – we may share your information among the different Menlo entities in the event that your application is relevant to roles across the entities or to collaborate on employment activities and goals.
- With service providers – these are entities that help us manage and improve the recruiting process and who perform services on our behalf, such as recruitment providers, interview and assessment providers, interview travel booking and expense providers, relocation entities, immigration advisors, reporting and analytics services, and pre-employment screening services. These entities are required to protect the information we share with them with appropriate organizational and technical safeguards and to use such information as necessary to provide services to us.
- With regulators and other governmental entities – we may access, preserve, and share your information with regulators, law enforcement, or others in response to a valid legal request if we have a good-faith belief that the law required us to do so; or we conclude that such sharing is necessary to detect, prevent, and address fraud, unauthorized use of our systems, prevent violations of our terms, or protect our rights or the rights of others.
Legal bases for processing applicant data
We process the data we collect during the recruitment process:
- As necessary to prepare and enter into an employment contract with you
- As necessary to comply with our legal obligations
- As necessary for our (or others’) legitimate interests, including our interests in considering candidates for current and future employment opportunities, and in managing and improving our recruitment and hiring processes, unless those interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
- Consistent with specific consents you may provide (if applicable), and which you may revoke at any time
- To protect your vital interests, or those of others
Data retention
We'll retain information we collect from job applicants for as long as required to comply with our legal obligations, to resolve disputes and to enforce our contractual agreements, or as necessary for our legitimate interests, such as to consider you for employment opportunities at Menlo. If you're successful in your application for a position at Menlo, we retain the information you provide during the application process as part of your employee records.
Special category data processing
Data such as health information, race, nationality, religious beliefs, trade union membership, and biometric information is subject to special protections under certain laws. We may process such data where necessary for the establishment, exercise, or defense of a legal claim by us, with your explicit consent, or where necessary for the purpose of carrying out our obligations and for exercising of our rights or your rights in the context of applicable employment law. For example, we may need to process information about your health to accommodate any special needs you have when you come onsite for an interview.
How can you exercise your rights provided under the GDPR?
You have a number of rights in relation to your personal data. These can differ depending on the jurisdiction and there are typically subject to important exceptions, but, where they apply, they can be summarized in broad terms as follows:
- Right of access. You may have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients, and other information about the processing. We do have to take into account the interests of others though, so this is not an absolute right, and in some cases permitted by law we may need to deny your request.
- Right to rectification. You may have the right to rectify inaccurate or incomplete personal data concerning you.
- Right to erasure. You may have the right to ask us to erase certain personal data concerning you.
- Right to restriction of processing. In limited circumstances, you may have the right to request that we restrict processing of your personal data.
- Right to data portability. For certain personal data you have provided to us, you may have a right to receive it in a commonly used and machine-readable format, and you may have the right to have the data transmitted to another entity.
- Right to object and rights relating to automated decision-making. You may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.
- Right to withdraw consent. In the very limited cases in which we may process your personal data on the basis of your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us as described below. You also have the right to lodge a complaint with the competent data protection supervisory authority, which will depend on which country you are located in.
How do we operate and transfer data as part of our global business?
As a global company headquartered in the United States, we share data globally, both internally within the Menlo family of companies, and externally with our service providers. Information we collect and process will be transferred to, or stored and processed in, the United States or other countries outside of where you live for the purposes as described in this Notice pursuant to transfer mechanisms such as approved standard clauses, consent, or contractual necessity, as appropriate.
How to contact us with questions.
The data controller responsible for your information is Menlo Security, Inc., located at 800 W. Camino Real, Ste. 250, Mountain View, CA 94040. If you have any questions, you can contact us at legal@menlosecurity.com.
How can you learn about changes to this Notice?
We may change this Notice from time to time. If we make changes to the Notice that are material, we will provide you with notice in accordance with applicable legal requirements.