Privacy Statement
Workers

Quick Summary

Privacy Mission Statement

Sterling Talent Solutions is committed to the protection of individual privacy rights. We hold ourselves to the highest legal and ethical standard for compliance and strive to be a privacy champion in the human resources technology industry. We value the trust our clients, colleagues and suppliers place in us, and we work to maintain that trust by building privacy protection into everything we do.

Table of Contents

  1. Scope of application
  2. What types of personal information do we collect and why do we collect it?
  3. When, why and how do we communicate personal information outside of Sterling?
  4. How do we ensure your personal information is accurate?
  5. Do we engage in automated decision-making, profiling, or research using personal information?
  6. How long do we keep personal information?
  7. Do we transfer personal information between countries?
  8. Do we participate in the EU-U.S. and Swiss-U.S. Privacy Shield Framework?
  9. How do we protect personal information?
  10. How can you choose how and whether we collect and use your personal information?
  11. How can you access or correct your personal information, request that it be deleted, or ask for it to be transferred to another organization?
  12. How can you make a complaint about how we have handled your personal information or responded to a request to exercise your rights?
  13. Contact Information
  14. Glossary

1   Scope of application

This statement applies to the collection and processing of personal information, which means information about an identifiable individual (you), that Sterling Talent Solutions (Sterling, we or us) collects about current or former employees, job applicants, contractors, subcontractors, and employees of contractors or subcontractors (collectively referred to as workers).

Work product you create for Sterling is not your personal information and is generally outside the scope of this document. However, work product may be the personal information of another worker if it is about that worker, such as a performance appraisal.

2   What types of personal information do we collect and why do we collect it?

The table below outlines the purposes for collecting personal information, the general types of personal information we collect, and where we collect it from.

*Items marked with an asterisk may be considered sensitive or may be subject to special protections in some places. They will not be collected in every case. They will not be collected where prohibited by law, and where permitted, they will only be collected and used in accordance with applicable law.

Legal basis for collection and processing of personal information

We collect and process workers’ personal information based on one or more of the following:

  • We need to do so to fulfil an obligation under applicable law;
  • We need to do so to fulfil an obligation under our contract with you;
  • We need to do so in emergencies to protect your vital interests;
  • We have a legitimate interest to do so, and have taken your rights into consideration;
  • We have your free and informed consent to do so.

Reuse of personal information for new purposes

We will not reuse personal information for a new purpose other than the original one(s) for which it was collected, unless one or more of the following is true:

  • the new use is compatible with the original one, meaning you should reasonably expect it;
  • we have notified you of the new use and given you an opportunity to object to it; or
  • the new use is otherwise permitted or required by law.

3   When, why and how do we communicate personal information outside of Sterling?

We collect personal information for the following purposes. Select and expand the section for the activity that applies to you to understand that activity, the personal information we collect for it, how we use that personal information, and our legal basis for doing so.

4   How do we ensure your personal information is accurate?

Much of the personal information we collect comes directly from you, in which case you are in control of its accuracy. You are encouraged to update your personal information regularly to ensure it is accurate and up to date. Information that is found to be inaccurate, either through our own audits or following your request for correction, is updated.

5   Do we engage in automated decision-making, profiling, or research using personal information?

We do not make automated decisions about you, nor do we attempt to analyze or predict your behavior, preferences, interests, health or other personal characteristics. We only conduct research using personal information that is explicitly collected for that purpose, such as demographic information and surveys.

6   How long do we keep personal information?

We keep personal information as long as we need it to fulfill our obligations. This is dependent on why we collected the information in the first place. Once we no longer need it, it is deleted or anonymized.

Most personal information is retained for as long as you perform work for us and a certain period afterwards. Certain information must be kept to comply with legal obligations under local employment and tax laws. For information about how long your personal information will be retained, contact the HR or Privacy teams.

7   Do we transfer personal information between countries?

Yes. We store and process personal information in Canada, India, the Philippines, the United Kingdom and the United States. We occasionally also use service providers in various other countries, usually to collect or translate information from that service provider’s country or region that we require to provide services.

If your personal information is subject to European Union (EU) or Swiss law, it may be transferred outside of the EU or Switzerland based on one or more of the following legal mechanisms:

  • Relevant authorities have issued a decision that personal information will benefit from an adequate level of protection in the country to which it is transferred. This is the case for Canada and, under the EU-U.S. and Swiss-U.S. Privacy Shield Framework, the United States. This is not the case for India or the Philippines.
  • We have signed contractual clauses within our corporate group or with a third-party vendor that are deemed by the relevant authority to ensure adequate protection of personal information.
  • You have provided your free and informed consent for us to transfer data outside of the EU or Switzerland.

In all cases, we ensure that appropriate safeguards are in place to ensure the protection of your personal information. For more information about these safeguards, please contact the Privacy team.

8   Do we participate in the EU-U.S. and Swiss-U.S. Privacy Shield Framework?

Yes. Sterling Infosystems Inc. and its U.S. affiliates and subsidiaries operating under the brand name of Sterling Talent Solutions (listed below under “Privacy Shield Covered Entities”) comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the EU and Switzerland to the United States. Sterling has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Sterling remains responsible for personal information that is communicated to third parties for processing as described in Section 4 (“When, why and how do we communicate personal information outside of Sterling?). If there is any conflict between the terms in this statement and the Privacy Shield Principles, the Privacy Shield Principles will prevail. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov. The Federal Trade Commission has jurisdiction over Sterling’s compliance with Privacy Shield.

9   How do we protect personal information?

We have advanced security measures in place to secure and protect your personal information, such as internal and external firewalls, monitoring and alert systems to prevent and detect intrusion attempts, and 128-bit encryption of data both in transit and at rest. Our servers are located within a securely managed infrastructure, and undergo multiple reviews by independent auditors. Our employees access data through secure virtual desktop interfaces and our online interfaces are encrypted, password protected and monitored.

We employ equally rigorous physical security policies to prevent physical access to our premises. Our servers and offices, including personal information in hard copy form, are kept in access-controlled and monitored environments.

All of our employees have been carefully screened and undergone thorough security and privacy training. We restrict access to your personal information to individuals who need it to perform their work functions. Our human resources, facilities, information technology, finance, legal and quality teams, as well as people managers and executive leadership, may have regular access to your personal information and employees in other departments may access it occasionally as required to manage our relationship with you and fulfill our legal obligations.

We also enter into contractual agreements with service providers with which we may need to share your personal information, which require them to protect your personal information to the same level as we do, and allow us to audit their compliance with those obligations.

10   How can you choose how and whether we collect and use your personal information?

In some cases, providing your personal information is mandatory. For example, this is the case when we are required by law to collect the personal information from our workers (such as for tax or workers’ compensation purposes), when the collection is necessary to fulfill our contract with you (such as for payroll purposes), and when we have determined that the collection is in our legitimate interest and is done in accordance with your rights (such as for background screening).

In other cases, providing your personal information is voluntary. If you choose not to provide your personal information in these cases, you may not be able to receive certain optional benefits.

To understand whether it is mandatory or optional to provide your personal information, and the consequences of choosing not to provide it, speak to the department requesting the personal information or the HR or Privacy teams.

Whenever our legal basis for collecting and using personal information is your consent, you can withdraw or modify your consent for future collection or use of your personal information at any time, and we will explain the consequences of doing so.

If we use your personal information for sales or marketing purposes, you can ask us to stop at any time and we will do so.

11   How can you access or correct your personal information, request that it be deleted, or ask for it to be transferred to another organization?

At any time, you can request access to your personal information, request that any inaccuracies be corrected, and request that comments or explanations be added to records about you.

You can also ask about:

  • whether and why we have your personal information;
  • how we got your personal information;
  • what we have done with your personal information;
  • to whom we have communicated your personal information;
  • where your personal information has been stored, processed or transferred;
  • how long we will retain your personal information, or how that retention period will be determined; and
  • the safeguards in place to protect your information when it is transferred to third parties or third countries.

Finally, you can ask us not to collect or use your personal information for certain purposes, you can ask us to delete your personal information, or you can ask us to provide your personal information to a third party.

Depending on which laws apply to your personal information, we may only be able to do some of these things for you. If you request one of these things and we refuse to do it, we will explain your legal rights, the reason for our refusal and any recourse you may have.

12   How can you make a complaint about how we have handled your personal information or responded to a request to exercise your rights?

We commit to investigating and resolving complaints about our collection or use of your personal information. To make a complaint, contact the HR or Privacy teams.

13   Contact Information

United States and all other countries

1 State Street Plaza
New York, NY 10004 USA
privacy@sterlingts.com

Canada

Suite 200-19433 96th Avenue
Surrey, BC V4N 4C4 CANADA
privacy@sterlingts.com

United Kingdom

8th Floor, Alexandra House
1 Alexandra Road
Swansea SA1 5ED UK
privacy@sterlingts.com
Information Commissioner’s Office Registration Number: Z9745943

14   Glossary

Anonymized means that sufficient information has been removed from personal information so that it can no longer be associated with an identifiable individual.

Individual or you means the individual that personal information is about.

Personal information means information about an identifiable individual.

Processing, handling or use means anything we do with personal information.

Profiling means automated use of your personal information to analyze or predict things like your performance at work, creditworthiness, reliability and conduct.

Sterling Talent Solutions, Sterling, we or us means Sterling Infosystems, Inc. and all of the subsidiaries listed in the Contact Information section.

Service provider means a company engaged to process personal information on behalf of another company.

Third party means a person or organization that is neither you nor us.

Worker means a current or former employee, job applicant, contractor, subcontractor, or employee of a contractor or subcontractor

Published: September 18th, 2017

Version history

Revision Date Available Statement
September 8 Current version
10 August 2017 Click to download this version