Candidate Privacy Notices
Effective: 1 January 2019
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CoorsTek Group companies (collectively, “CoorsTek”, “we”, “us”, or “our”) respect your privacy and are committed to processing your personal information in a fair and transparent manner and in accordance with all applicable data protection regulations and other applicable privacy laws. This Candidate Privacy Notice applies to job applicants only (whether as an employee, contingent worker, contractor, or otherwise) and describes how CoorsTek collects, uses, shares, and processes personal information about you during and after the job recruiting process.
CoorsTek, Inc. and any CoorsTek Group company operating in the location of the job to which you applied are the data controllers of your personal information. These are the organizations that determine how and why your personal information is processed.
A list of CoorsTek Group companies operating in each country, including the contact information for the company and its Data Protection Officer, if applicable, is attached to this Candidate Privacy Notice.
What personal information does CoorsTek collect and use?
In the course of our recruiting activities, we may collect, use, process, share, transfer, and store the following categories of personal information about you:
- Personal details such as name, title, addresses, telephone numbers, email addresses, date of birth, or gender;
- Work history and other relevant experience, including information contained in a resume, CV, cover letter, or job application;
- Education information including degrees awarded, transcripts, and other information provided in support of the job application;
- Compensation history;
- Information collected during phone screenings and interviews, including opinions and comments of interviewers;
- Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and information about compensation and benefits;
- Reference information and information received from background checks or other pre-employment screens, tests or assessments, where applicable;
- Information relating to previous applications to CoorsTek or previous employment history with CoorsTek; and
- Any additional personal details that you otherwise voluntarily provide to us.
Why does CoorsTek collect and use your personal information?
CoorsTek will collect, use, process, share, transfer, and store your personal information only in a manner permitted or required by law.
Most commonly, we will use your personal information in the following circumstances:
- Where necessary to enter into a contract with you, such as deciding whether to enter into an employment, service or other contract with you;
- Where necessary to comply with a legal obligation that applies to us under labor and employment laws, such as:
- Ensuring equal opportunity monitoring and reporting; and
- Complying with legal processes or enforceable government requests, such as search warrants, subpoenas, or court orders; and
- Where necessary to pursue our or a third party’s legitimate interests and your fundamental rights do not override those interests, such as:
- Identifying and evaluating job applicants, including assessing skills, qualifications, and interests;
- Verifying your information and carrying out employment, background, and reference checks, where relevant to the position and permitted by applicable law and subject to your consent if required by applicable law;
- Communicating with you about the recruiting process and your application;
- Keeping records related to our recruiting processes; and
- Analyzing and improving our recruiting process.
We need all the categories of your personal information listed above to accomplish these purposes. Some of the above grounds for processing will overlap, and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information when requested that is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application successfully.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, then we will notify you and will explain the legal basis which allows us to do so. Otherwise, we will request your express written consent to allow us to process your personal information for such unrelated purpose. In this situation, providing your consent is entirely voluntary and you may withdraw consent at any time after granting it.
We do not envision that any recruiting decisions will be taken about you using automated means, however we will notify you in writing if this position changes. Regardless, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
Does CoorsTek collect and use sensitive personal information?
The following categories of personal information may be considered sensitive under the laws of your location and may receive special protection:
- Race or ethnicity, country, region or city of birth, and primary or additional nationalities or citizenships;
- Political opinions or affiliations;
- Religious, moral, or philosophical beliefs;
- Trade union membership;
- Social welfare, sexual life, or sexual orientation;
- Criminal or alleged criminal behavior, convictions or offences;
- Personal credit or financial data;
- Genetic and biometric data; and
- Physical or mental health or condition or disability status.
Mainly, we will not collect, use, process, share, transfer, and store your sensitive personal information unless it is necessary for us to carry out our legal obligations in connection with the recruiting process. For example, in certain locations we may be required under applicable local law to collect and use information about your race or ethnic origin to ensure meaningful equal opportunity monitoring and reporting.
In addition, in locations where we are legally permitted to do so, we may need to collect and use information about unlawful or objectionable conduct, criminal charges or convictions, credit references, physical or mental health or condition, disability status, and other sensitive information resulting from a background check, if such information is necessary, relevant and appropriate to evaluate fitness for a particular position and where we have received your express, prior written consent, if required by law.
If you have any questions about whether any of your sensitive personal information is collected and used in your recruiting process and the purposes for which that sensitive personal information is collected and used, you may contact the CoorsTek Human Resources department at firstname.lastname@example.org or the local Data Protection Officer, if applicable.
How and when does CoorsTek collect your personal information?
Generally, we collect personal information directly from you through the recruiting process, such as through your application or interview.
We may also collect your personal information from:
- Recruiting or staffing agencies;
- Pre-employment screening providers, such as background, employment or reference check providers and credit reference agencies;
- Your former employers; and
- Publicly available sources, such as national authorities and public profiles on work-related social media platforms (for example, LinkedIn).
Who will have access to your personal information?
Access to your personal information is on a “need to know” basis. We will provide access to your personal information to only those persons who are required to use your personal information to achieve the purposes set out in this Candidate Privacy Notice, to administer our recruiting process, or to accomplish a legal obligation.
These persons may include persons at other CoorsTek Group companies or locations and at third-party service providers who assist us with administering the recruiting process, such as third-parties who provide recruiting or staffing services, IT/IS platforms or services, or employment verification, background check, or reference review services.
Third-party service providers will only have access to the personal information they need to carry out the tasks assigned to them. All third-party service providers are prohibited from using your personal information for their own purposes, for any purpose unrelated to their primary service function, or for any purpose not in accordance with our instructions. We require also all our third-party service providers, by written contract, to implement appropriate security (technical and organizational) measures to protect your personal information consistent with our policies and all data security obligations or requirements under applicable law. You may contact the Human Resources department at email@example.com or the local Data Protection Officer, if applicable, for an up-to-date list of such third-party service providers.
Finally, we may be required to disclose your personal information to regulatory authorities, including the government of the United States or its agencies, to comply with applicable law or valid legal processes, such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with an applicable law or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.
Where is your personal information transferred to and stored?
Your personal information may be transferred outside of the country where you work when necessary to administer our recruiting process, to accomplish the purposes set out in this Candidate Privacy Notice, or to comply with a legal obligation. This may include the transfer of your personal information to other CoorsTek Group companies and/or third-party service providers located outside of the country in which you live or the country where the job you have applied for is located. For example, if you applied for a job through Workday, the centralized global human resources information system used by CoorsTek, your personal information is transferred to the United States, stored by Workday on its servers located in the United States, and accessed by other CoorsTek Group companies worldwide.
CoorsTek is committed to protecting the privacy and confidentiality of your personal information when it is transferred outside of the country you are based in.
With respect to international transfers of your personal information from locations in the European Economic Area (EEA) to jurisdictions that are not considered to provide an adequate level of data protection under EU law, we have implemented standard contractual clauses approved by the European Commission as appropriate safeguards to secure the transfer of your personal information to the United States and other jurisdictions. With respect to international transfers of your personal information from locations outside of the EEA, we have implemented data transfer agreements or obtained your informed consent where necessary to secure the transfer of your personal information to the United States and other jurisdictions. You may obtain a copy of these documents by contacting the CoorsTek Legal Department at firstname.lastname@example.org.
How will your personal information be secured?
CoorsTek maintains appropriate organizational and technical safeguards to protect your personal information from unauthorized or unlawful processing and from accidental loss, destruction, or damage, such as:
- Establishment and enforcement of internal control plans;
- Regular training on personal information protection; and
- Installation of technical systems for access control and encryption.
In addition, we limit access to your personal information to those employees, agents, contractors, and other third-parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
For further information regarding the security of your personal information on CoorsTek’s and third-party networks, please contact the IT Department at ITHelpDesk@CoorsTek.com or the local Data Protection Officer, if applicable.
How long will CoorsTek retain your personal information?
We will only retain your personal information for as long as you are participating in our recruiting process, and we will endeavor to dispose of your personal information within three (3) months of the date you have ceased participation in our recruiting process, except where:
- We are required by applicable law to retain your personal information for a longer or shorter period of time. For further information regarding specific retention periods applicable to your personal information in your location, please contact the CoorsTek Human Resources department at email@example.com or the local Data Protection Officer, if applicable.
- We may retain and use your personal information to inform you about and consider you for other positions that may be appropriate for you. If you do not want to be considered for other positions or would like us to remove your personal information, you may contact the CoorsTek Human Resources department at firstname.lastname@example.org.
If you are offered and accept employment with CoorsTek, your personal information that we collected during the recruiting process will become part of your personnel file, and we may use it in connection with your employment, as further described in our Staff Privacy Notice.
What rights do you have with respect to your personal information?
If you reside in the European Union or a jurisdiction with similar data protection regulations or privacy laws, you enjoy the following rights in respect of your personal information we hold:
- Right to access the personal information that we process about you. Please note that your access may be restricted or limited if providing such access would be a violation of applicable law or regulation or if providing such access could be unreasonable, such as compromising the privacy of another person or exposing sensitive company information. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
- Right to rectify your personal information without undue delay where that personal information is inaccurate, out-of-date, or incomplete. Please keep us informed if your personal information changes during the recruiting process, so that we may promptly revise it and inform any third-party service providers who have received your personal information to revise it. We reserve the right not to revise any personal information that we consider accurate, current, or complete.
- Right to erase your personal information without undue delay under the following circumstances:
- When your personal information is no longer needed for the purposes for which it was collected;
- If you have revoked your consent and there is no other legal basis for processing your personal information;
- If you object to the processing of your personal information and there is no overriding legitimate reason for its processing;
- If your personal information is processed unlawfully; or
- If your personal information must be erased in order to comply with a legal obligation.
Please note that before erasing your personal information we must check whether there is a legitimate reason for continued processing your personal information.
- Right to restrict the processing of your personal information in certain circumstances, such as for a period enabling us to verify the accuracy of your personal information if its accuracy is contested by you.
- Right to object to the processing of your personal information on grounds relating to your particular situation or for direct marketing purposes.
- Right to data portability. You have the right to receive your personal information that you have given us for processing in a transferable and machine-readable format.
- Right to make a complaint with the relevant data protection authority, where applicable, in your country.
- Right to withdraw your consent. In limited circumstances or where required by applicable law, CoorsTek may be collecting, using, processing, sharing, transferring, or storing your personal information based on your consent to do so. Where you have provided such consent, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact a member of your local Human Resources department, the local Data Protection Officer, if applicable, or the CoorsTek Legal Department at email@example.com.
If you want to exercise any of these rights in relation to your personal information, please contact the local Data Protection Officer, if applicable, a member of your local Human Resources department, or the CoorsTek Legal Department at firstname.lastname@example.org. Any such communication must be in writing, and we may request specific information from you, so we can confirm your identity, your right to access the information requested, and your entitlement to exercise your rights.
We try to process your requests and claims as quickly as possible in order to protect your rights appropriately. Depending on the frequency of enquiries, however, it may take up to 30 days before we can provide you with further information about your request. If it should take longer, we will inform you promptly of the reasons for the delay and discuss the further process with you.
Who may you contact with further questions regarding your personal information?
If you have any questions about this Candidate Privacy Notice or if you believe that your personal information is not handled in accordance with applicable law or this Candidate Privacy Notice, you may contact the local Data Protection Officer, if applicable, the CoorsTek Human Resources department at email@example.com, or the CoorsTek Legal Department at firstname.lastname@example.org.
We reserve the right to update this Candidate Privacy Notice at any time, and we will publish and announce a new Candidate Privacy Notice when we make any substantial updates.
CoorsTek Group Company
CoorsTek, Inc. located at 14143 Denver West Parkway, Suite 400, Golden, Colorado 80401
CoorsTek Advanced Materials Hamilton located at 45 Curtis Avenue N, Paris, Ontario N3L 3W1 Canada
CoorsTek Advanced Materials Turnov located at Za Viaduktem 2150, 51101 Turnov, Czech Republic
CoorsTek GmbH located at Am Winkelsteig 1, D-91207 Lauf a.d. Peg., Germany
Data Protection Officer:
United Kingdom –
CoorsTek Netherlands B.V. located at Frontstraat 4, 5405 AK, Uden, Netherlands
CoorsTek Sweden AB located at Fabriksvӓgen, S-91532 Robersfors, Sweden
CoorsTek Korea, Ltd. located at 23-28, 4 Gongdan-ro, 7 Gil, Gumi-si, Gyeongsanbuk- do, Korea, 39422
CoorsTek Advanced Materials (Thailand) Co., Ltd. located at 616/4 Moo 5, Maenam Khu. Pluak Daeng, Rayong, Thailand 21140
CoorsTek Trading (Shanghai) Co. Ltd. located at Room 907, World Trade Tower, No. 500 Guangdong Rd., Huang Pu District, Shanghai, China 200001