This Recruitment and Hiring Privacy Policy is effective as of March 2021. Please note that this policy will be regularly updated to reflect any changes in applicable laws or changes to our practices.
This Recruitment and Hiring Privacy Policy (“Hiring Privacy Policy”) explains how First San Francisco Partners, Inc. (“FSFP”; “we”) protects any information or data we collect and process relating to you (“your personal data”; “your data”) and describes certain rights you have in relation to the processing of your personal data if you apply for a position through FSFP’s career portal. As used in this Hiring Privacy Policy, ‘personal data’ means personally identifiable information, or any information that can be used to describe or identify an individual.
Categories of Personal Data to Be Collected
The categories of personal data requested from you and the manner in which that personal data is collected and accessed is determined by the Federal, state, and/or local laws and regulations of the United States.
The following categories of your data may be collected by FSFP:
- Your personal details;
- Data requested for you to provide during the recruitment process, to the extent allowed by applicable law;
- Data you submit in resumes / CVs, letters, writing samples, or other written materials (including photographs);
- Data generated by interviewers, based on their interactions with you;
- Recommendations provided on your behalf by others;
- Documentation required under immigration laws;
- Data about your prior employment, education, and where applicable, credit history, criminal records or other data revealed during background screenings;
- Data about your health or disability where it is relevant to your ability or availability to work or to a workplace accommodation, subject to legal limits on the timing of collection of such data and other applicable limitations.
- Data about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required, as well as to understand the diversity characteristics of the FSFP workforce.
Another way that we collect data is through the use of cookies. Cookies are small files of information that save and retrieve information about your visit to our tools, career portal, and websites. Please read our general Privacy Policy for further information on this.
You are not required to provide any requested data to FSFP, but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.
By submitting your information, you acknowledge that all representations made by you are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
What Lawful Bases Will Be Used by FSFP to Process Your Personal Data?
FSFP may use your personal data for the following purposes and based upon the following lawful bases:
| Purpose | Lawful Basis |
|---|---|
| Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available. | FSFP’s legitimate interest of ensuring that it recruits the appropriate employees. |
| Manage your application. | FSFP’s legitimate interest of ensuring that it recruits the appropriate employees. |
| Facilitate communication with you. | FSFP’s legitimate interest of ensuring proper communication within the organization and with you. |
| Perform administrative functions (e.g., reimburse you for interview-related expenses). | FSFP’s legitimate interest of ensuring that it recruits the appropriate employees. |
| Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at FSFP and how to attract and keep top talent, as well as analyze the performance of the career portal tool. | FSFP’s legitimate interest of ensuring that it continually improves its recruitment processes. |
| Transfer your contact information, education data, employment data, application information and the resume, all as supplied by you in our recruitment system, to the FSFP recruitment database that we maintain to notify you about new positions that may be of interest to you. | FSFP’s legitimate interest of ensuring that it recruits the appropriate employees. |
| Perform any legally required reporting, and respond to legal process. | Compliance with a legal obligation. |
Where the above table states that we rely on our legitimate interests for a given purpose, we did consider your potential interests, fundamental rights and freedoms and if those could be impacted by our processing activities. We did balance your interests, rights and freedoms against our interests, taking into account the purposes of the processing, the security of your data and our existing relationship with you. Based on this balancing test and with our efforts to inform you in a very transparent way of the processing activities, we are of the opinion that it does not materially impact any of your interests, rights and freedoms by processing your data.
FSFP will not use your personal data for purposes that are incompatible with the purposes listed in this Hiring Privacy Policy, unless it is required or authorized by law, or it is in your own vital interest (e.g., in case of a medical emergency) to do so.
To the extent you are asked to accept this Hiring Privacy Policy in one of our tools, such acceptance will be considered as your consent to process your personal data for the purposes listed in this Hiring Privacy Policy.
Sources that FSFP Will Use to Obtain your Personal Data
FSFP may obtain data about you from the following sources:
- From you, when you submit your resume or other information through the FSFP career portal;
- From conversations with recruiters and interviews with hiring managers and other FSFP personnel or representatives, some of which may be documented;
- From previous employers; and,
- From background checks, as applicable. Where permitted by law, FSFP may contract with a third party to perform a pre-employment background screening. The content of background check information varies, but may include information gathered from publicly available sources, your former employers or colleagues, schools you have attended, credit reporting agencies, and criminal records databases. You will receive more information about the nature of such a background check before it begins. Where required, you may be asked to provide certain background check information, (which may include sensitive data) directly to FSFP or its third-party service provider.
Who Will Have Access to Your Personal Data? Where Is It Located?
In general, access to your personal data will be restricted to minimize the number of people in FSFP’s organization who need it for the purposes set out in this Hiring Privacy Policy, which may include your potential future managers and their designees, or personnel in Human Resources.
FSFP has internal policies to ensure an equivalent level of protection is in place across FSFP’s organization. Your data will be stored and processed in the United States.
Furthermore, where there is a need, FSFP may share your personal data with third parties, such as FSFP’s third-party service providers, professional advisers, and where required, to public authorities. Before doing so, FSFP takes steps to protect your personal data. Any third-party service providers and professional advisors to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with FSFP’s agreements with the third-party service providers and with applicable data protection laws.
How Long Will FSFP Retain My Personal Data?
If you are given and accept an offer of employment by FSFP, your personal data collected during your pre-employment period will become part of your FSFP personnel records, to be retained throughout and for a period after your employment with FSFP. If FSFP does not employ you, FSFP may nevertheless continue to retain and use personal data collected during the recruitment process in order to consider you for new positions, and, if appropriate, to refer back to an earlier application if you submit a resume or other information to FSFP again in the future, as well as for system administration, and to perform research and analysis.
FSFP determines the retention period of your information based on the following retention criteria:
- FSFP retains your personal data as long as it has an ongoing relationship with you;
- FSFP retains your personal data where it is required to do so by a legal obligation to which it is subject;
- FSFP retains your personal data where this is advisable to safeguard or improve FSFP’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).
How FSFP Protects Your Personal Data
We maintain organizational, physical and technical security controls for all the personal data we hold. These controls are implemented in order to maintain the security of your personal data, including the use of encryption, physical access controls, information access controls, anti-virus and anti-malware software, along with service infrastructure support and cloud hosting from leading information technology and security providers, including Microsoft. We also have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.
Please be aware that, despite our best efforts, no security measures or controls are perfect or impenetrable. Therefore, FSFP cannot guarantee or warrant the security of any data collected through the website or career portal and cannot be responsible for the theft, destruction, loss or inadvertent disclosure of any data.
Which Rights Do You Have With Respect to the Processing of Your Personal Data?
You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- request access to your personal data: this right entitles you to request access to personal data we process about you, as well as to certain information on such processing;
- request rectification of your personal data: this right entitles you to request the correction or completion of any of your personal data that would be inaccurate or incomplete;
- request erasure of your personal data: this right entitles you to request the deletion of your personal data, including where such personal data would no longer be necessary to achieve the purposes;
- object to the processing of your personal data: this right entitles you to request that we no longer process your personal data;
- request the restriction of the processing of your personal data: this right entitles you to request that we only process your personal data in limited circumstances;
- request a copy or the portability of your personal data: this right entitles you to receive a copy of personal data that you have provided to us.
CA Consumer Privacy Rights
California Civil Code Section 1798.83 (known as the “Shine the Light” law) requires certain businesses to respond to requests from California consumers about personal information disclosed to third parties for the third parties’ direct marketing purposes. We do not disclose your personal data to third parties for third parties’ direct marketing purposes. In the event we do so in the future, we will not disclose any of your personal data to third parties for third parties’ direct marketing purposes unless you consent at the time that you provide your personal data.
Changes to this Hiring Privacy Policy
This Hiring Privacy Policy may be updated from time to time. FSFP will publish any changes to this Hiring Privacy Policy by posting the new Hiring Privacy Policy and changing the “Effective Date” above. You should consult this Hiring Privacy Policy regularly for any changes. You can then decide whether you would like us to continue to keep your personal data for the purposes stated in this Hiring Privacy Policy.
Contact us to exercise any of your rights. You can also contact FSFP at 1-888-612-9870 or via post, clearly marked for the attention of the Data Privacy Officer, at the following address: First San Francisco Partners, 4200 Park Blvd # 276, Oakland, CA 94602.
