Privacy Policy

N. Harris Computer Corporation and its affiliated companies (“Harris” “Company”, “we”, “our”, or “us”) are committed to protecting and respecting your privacy. We respect the privacy of the personal information of the individuals with whom we interact. If you are a job applicant, this Privacy Policy describes the personal information that we collect from or about you, and how we use and to whom we disclose that information. The Company has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals and specific issues relating to the use of our website. This Privacy Policy applies only to the personal information of all individuals who seek to be employed by us. We have developed other documents that describe our privacy policies and practices with respect to our employees, customers, suppliers and other parties with whom we interact (see our “Privacy Policy”). If you submit a job application through our website, your personal information will be processed in accordance with this Privacy Policy. If you are unsure of which Privacy Policy applies to you, please contact the office of our Privacy Officer for more information.

This notice sets out the basis on which any personal data (“Personal Data" means any data that can or may be used whether alone or in combination with other information in order to identify you) that you provide to us, or that we otherwise collect, will be processed. Personal data does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual). This notice does not form part of any contract of employment or other contract to provide services.

The Company endeavours to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy was developed to guide the activities of the Harris family of companies as a whole. In addition to the practices set forth in this Privacy Policy, Harris or certain members of the Harris family may adopt specific information handling and privacy practices to address privacy issues unique to their operations and jurisdictional requirements. This Privacy Policy has a limited scope and application and the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact the office of our Privacy Officer for more information.

We are committed to ensure that the Personal Data we process about you will be:

• Used lawfully, fairly and in a transparent way.
• Collected for specified, explicit and legitimate purposes, and not further processed in a manner that is incompatible with those purposes.
• Adequate, relevant and limited to what is necessary in relation to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for those purposes.
• Kept securely.

We collect, store and process Personal Data during recruitment process about you for the following purposes:

• Create and manage the recruitment system, job applications and a database of interested individuals
• Assess and evaluate your skills, qualifications and interests against the position applied for and/or other positions within the Harris.
• Communicate with you in relation to your expressed interest in Harris job opportunities, application or the recruitment process.
• Verify your information, including through reference checks and, where applicable, background checks.
• Send you information about the new hire and employee experience at Harris prior to your first day.
• With your consent, send you information about positions within the Harris family which may be of interest to you.
• Operate, evaluate and improve the recruitment system, our application tracking and recruitment activities (this includes analyzing our job applicant base, our hiring practices or trends, identifying qualifications or skills shortages, and using information to match candidates and potential opportunities).
• The process of onboarding you as a Company employee.
• Detect, prevent and respond to fraud or potentially illegal activities (such as intellectual property infringement), misuse of the recruitment system, this Privacy Policy or other Harris policies.
• Perform audits, assessments, maintenance and testing or troubleshooting activities related to the recruitment system and our recruitment processes.
• Comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies.
• Respond to your enquiries and requests.

We will only use your Personal Data for the purposes for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sometimes, we may process your personal information using solely automated means to make decisions about your candidacy, for example, based on your answers to the questionnaire. This is known as "automated decision-making" and is only permitted when we have a legal basis for this type of decision-making. This may have significant effects for you, namely that you may be rejected for the role you applied for without a recruiter ever reviewing your application.

The logic involved is that if our recruiters do not progress you forward in our recruitment system within seven days, it may result in your application being automatically rejected. Our recruiters can reactivate candidates that have been rejected at a later date, if necessary.

We may make these automated decisions about you:

• Where such decisions are necessary for entering into a contract.
• Where such decisions are required or authorised by law.
• Where you give your explicit consent to us carrying out automated decision-making.

We collect, store, use and process all or some of the following categories of Personal Data about you:

• Resumes and/or applications;
• References and interview notes;
• Letters of offer and acceptance of employment;
• Wage expectations
• Background screening information; where this is both applicable and permitted by law.
• Other information collected for the purposes of your recruitment - including copies of right to work documentation information regarding your training and education, and professional certifications.
• Publicly available online information - such as your LinkedIn profile URL or other similar social network.

We may also collect, store, use and process the following “special categories” of more sensitive Personal Data:

• Information about criminal convictions and offense, where this is applicable by law.

Mandatory policy acknowledgement sign-off sheets;

• social insurance number, pay cheque deposit information, and retirement and savings plan information;
• wage and benefit information;
• forms relating to the application for employee health and welfare benefits; including, short- and long-term disability, medical and dental care;
• beneficiary and emergency contact information;
• photographs and video;
• personal details - such as: your name, contact information, personal email addresses, date of birth, gender, Identification number, as well as a copy of your ID or passport.

We collect Personal Data through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider (where this is permitted by law). We may also collect additional information from third parties including former employers, credit reference agencies or other background check agencies or publicly available resources (such as social networks). Personal Data of this kind will only be collected where it is permitted by law in the country of hire.

Information about criminal convictions and offenses - We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you.

Your Consent - In some circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Where required by law, necessary to administer the recruitment and application process with you or where we have another legitimate interest in doing so, we may have to share your data with third parties, including third-party service providers and other entities in the Company group.

We may transfer your Personal Data outside the EU. If we do, you can expect a similar degree of protection in respect of your Personal Data.

• Sharing of Personal Data with other entities in the group - We may share your Personal Data with:
  • Other entities in our group as part of our regular reporting activities on Company performance.
  • In the context of a business reorganization or group restructuring exercise.
• Sharing of Personal Data with relevant internal personnel – for example:
  • The Company management and HR teams, consisting of a limited number of individuals.
  • Individuals performing administrative and IT support functions.
• Sharing of Personal Data with third parties - We may share your Personal Data with other third parties, for example:
  • Recruiters working with us, hiring managers and other interviewers. Often these individuals will be based in the country where the position is based, but in some cases, they may be in other countries.
  • In the context of the possible sale or restructuring of the Company.
• Sharing of Personal Data with Authorized personnel at our service providers – for example:
  • Providers of talent acquisition systems.
  • Providers of HR and payroll management systems.
  • Companies contracted to perform candidate background screenings. These companies may be based in another country and may obtain data from other countries where you have lived, worked or studied, as may be relevant as part of a background check.
• Law enforcement, governmental authorities and regulators – for example, where legal reporting requirements may exist, or law enforcement agencies or private litigants in response to valid law enforcement process (warrant, subpoena, or court order).

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have 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.

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your Personal Data are available in our Data Retention Policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights in connection with Personal Data Under certain circumstances, by law you have the right to:

• Access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Correction of your Personal Data. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.
• Object to processing of your Personal Data. Where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data (Right of portability). This enables you to request to receive your personal data in a structured, commonly used and machine-readable format and to transmit those data to another party.

If you wish to exercise any of the rights, please contact us through the below details. You also have the right to make a complaint to the applicable supervisory authority for data protection issues.

We reserve the right to update this Privacy Policy from time to time to reflect changes in our legal or regulatory obligations or in the way we deal with your Personal Data. We will communicate any revised version of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated. For any substantial update that relates to how or why we collect, use, or process your data, we will provide you with a notice regarding the new policy. If you have any questions about this Privacy Policy, please contact us through the email address below.

If you have any questions about this privacy notice or how we handle your Personal Data, please contact us.