United HealthCare Services, Inc., and its subsidiaries and affiliated companies (collectively, the “Company”) strives to properly address applicable data protection and privacy legal requirements.
The primary data controller in respect of your Candidate Data is the entity with which you are applying for employment. A list of Brazil entities is available online.
TYPES OF CANDIDATE DATA COLLECTED
Candidate Data is provided by Job Applicants and Successful Candidates, and includes the following types of data:
- ID numbers (RG, CPF, CNH)
- Date of Birth
- Email Address
- Telephone Number (landline and mobile)
- Employment history
- Education history
- Referee contacts
- Place of Birth
- Marital Status
PURPOSE OF COLLECTION AND USES, LEGAL BASES, AND DISCLOSURES OF CANDIDATE DATA
The Company will only use and otherwise process Candidate Data:
- of Job Applicants for recruiting and job placement purposes including notification of future job opportunities; and
- of Successful Candidates for on-boarding purposes including enrollment in payroll and applicable employee benefit schemes, preparation of employment contract, and other administrative purposes necessary for the Successful Candidate to commence employment with the Company.
Company’s legal bases to use and process Candidate Data include that the processing is necessary for:
- the Company’s legitimate interests, including those described above, as processing Candidate Data is necessary to carry out the hiring process and to make it possible for Job Applicants and Successful Candidates to apply for and / or be appointed to a position at the Company);
- compliance with Company’s legal obligations, such as accounting and tax requirements;
- the performance of the employment contract between the Company and Successful Candidates;
- for the purposes of carrying out the obligations and exercising rights under employment law; and
- where applicable, Job Applicants or Successful Candidates, may subsequently withdraw at any time by contacting us via the information in the “Contact Information” section, without affecting the lawfulness of processing before its withdrawal.
As necessary, and in connection with these purposes, authorized processors, including, but not limited to, members of the Human Resources department, the Finance department, the IT department, Compliance and Ethics department, and senior executive Company managers may access and otherwise process Candidate Data in connection with their job responsibilities.
Some of these processors may be employed by the Company at our various global locations outside of Brazil, including in countries that may not provide the same level of data protection as the home country of the Job Applicant and Successful Candidate. The Company takes appropriate steps to ensure that such personnel are bound to duties of confidentiality with respect to Candidate Data, and the Company implements measures such as data protection clauses to ensure that any transferred Candidate Data remains protected and secure. The use and transfer of Candidate Data are only for the purposes outlined in this policy and in accordance with applicable law.
USE OF CANDIDATE DATA FOR BACKGROUND CHECKS AND WHO WE COLLECT DATA FROM
Offers of employment with the Company, where permitted by local law, may be subject to and conditional upon the completion of certain background checks, including searches of the following databases:
- databases relating to organized crimes which are obtained through public source databases managed by regulatory and compliance authorities, web and media databases, and global sanctions and watch lists managed by financial regulatory bodies and law enforcement agencies;
- standard sanctions databases (UN, EU, U.S. lists, etc.) in compliance with economic sanctions laws throughout the world; and
- for Employees who may work on government programs, including, but not limited to United States Federal or State government programs, United States Federal and/or State debarment or exclusion lists or other such lists required by law or contract.
Candidate Data provided by the Successful Candidate following an offer of employment may be used to facilitate the conduct of Background Checks. No Background Checks will be undertaken prior to an offer of employment being made.
Successful Candidates may be requested to provide information related to their family members who hold government positions in order for the Company to assess potential conflicts of interest. When providing this information, it is the responsibility of the Successful Candidate to obtain the family member’s permission to disclose such information to the Company.
Due to the nature of the Company's business, it will carry out regular and ongoing screenings of the databases listed above during the course of employment to ensure that the Successful Candidate remains suitable for a position with the Company and are permitted to provide services to all of the Company's clients and in particular to organisations who prohibit excluded or debarred individuals from working on their account.
Conduct of the Background Checks may involve the collection of additional information about the Successful Candidate from educational institutions, government agencies, previous employers, information in the public domain and law enforcement agencies at the international, national or local level so far as obtained through public source databases. If a Successful Candidate's prior employers and/or other referees are contacted, the report may include this information.
TRANSFER TO THIRD PARTIES
The Company uses third party vendors for certain services, including:
- the online recruitment portal in which Job Applicants enter and submit their application; and
- the recruitment services
- the conduct of the Background Checks described above.
- The conduct of required health examinations for new employees;
When Company retains a third-party vendor, that vendor will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal data.
Some of these third parties are located outside Brazil, including in countries that may not provide the same level of data protection as your home country. To the extent required by applicable law, the Company will address any applicable requirement to assure an adequate level of data protection before transferring Candidate Data and Background Check Data by implementing measures to ensure that any transferred Candidate Data remains protected and secure.
RETENTION OF CANDIDATE DATA AND BACKGROUND CHECK DATA
Candidate Data and Background Check Data will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.
When a Successful Candidate enters employment with the Company, his or her Candidate Data and relevant Background Check Data may be transferred to an employee personnel file and may be processed and retained in accordance with applicable law or the Company's Data Protection Policy from time to time in force, a copy of which is available on the Company’s files.
DATA SECURITY AND DATA INTEGRITY
The Company maintains reasonable security measures to safeguard Candidate Data from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction. The Company also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.
Job Applicants and Successful Candidates may contact us, at the address listed below in the “Contact Information” section, to request confirmation of the existence of processing, access to the personal data we hold about them, to correct any inaccuracies, incompletions or mistakes, or to request anonymization, blocking, or deletion of this data, port personal data to another service provider, or to withdraw consent to the processing of personal data, in accordance with applicable law. Job Applicants and Successful Candidates may also request information about third parties with whom we share personal data.
The Company may be unable to comply with such a request where doing so would place it in breach of its obligations under applicable laws, regulations, or codes of practice. However, in some circumstances, you may be able to request that your data be blocked from further processing. You may also have a right to data portability to another data controller under certain circumstances. Where we rely on consent to process Candidate Data, consent may be withdrawn at any time, free of charge, although the withdrawal may impact or disrupt the services we provide.
If a Job Applicant and Successful Candidate is aware of changes to or inaccuracies in his or her personal data, he/she should inform us of such changes at the address listed below in the “Contact Information” section, so that the personal data may be updated or corrected.
Job Applicants and Successful Candidates have the following rights in relation to their data: (i) confirmation of the existence of data processing; (ii) access to data; (iii) correction of incomplete, inaccurate, or outdated data; (iv) anonymization, blocking, or elimination of unnecessary, excessive or treated data in disagreement with the provisions of the Law; (v) data portability, by means of an express request and subject to commercial and industrial secrecy; (vi) elimination of personal data processed with consent; (vii) information of the public and private entities with which the controller shares its personal data; (viii) information on the possibility of not providing consent, and on the consequences of refusal; and (ix) revocation of consent, all of which may be exercised through mechanisms provided in art. 18 of the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais).
Candidate Data from Job Applicants will be retained on file, to be used for future employment opportunities, subject to applicable law on retention of personal data. If at any point before a Job Applicant is offered employment they wish to have their application information removed from the recruitment database, the Job Applicant should send a written request to the local Human Resources department with the subject line "Please remove me from your Recruitment database". Notwithstanding such a request, certain information may be retained as required by applicable law.
When the application is made through a Job Applicant portal, the Company could retain and store Candidate Data for 12 (twelve) months from the last active date, and thereafter, Candidate Data will be deleted.
DISCLOSURES REQUIRED OR PERMITTED BY LAW
Job Applicants and Successful Candidates can raise any issues regarding their Candidate Data with their local Human Resources Department or our Data Protection Officer by contacting:
Human Resources Department
Data Protection Officer