Effective Date: April 12, 2023

Last Updated:

Randolph College (“Randolph College”, “we”, or “us”) is committed to protecting the privacy and security of your personal information. This Job Applicant Privacy Notice (“Privacy Notice”) applies solely to candidates who reside in the United States and apply for an open position to work at Randolph College (“you” or “applicant”).

This Privacy Notice describes how we collect and use your personal information during the application, recruitment, interview, and/or any on-boarding process prior to employment, when you choose to apply for an open position at Randolph College. We will only use your personal information in accordance with this Privacy Notice.

DISCLAIMER: Providing you with this Privacy Notice is not an indication and does not guarantee that you will be interviewed for the position to which you applied or that you will be offered employment by Randolph College.

1. Information We Collect

For purposes of this Privacy Notice, “personal information” means any information about an identifiable individual or otherwise as defined in accordance with applicable privacy law. Personal information excludes anonymous or de-identified data that is not associated with a particular individual.

1. 1. Personal Information You Provide to Us

We may collect the following categories of personal information from you in connection with our recruiting activities:

• Identifiers and personal contact details such as name, name pronunciation, preferred pronouns, title, address and location, telephone number, and email address.
• Social media accounts that you choose to provide as part of your application (such as your LinkedIn profile).
• Employment history and other relevant professional experience, including information contained in your resume, CV, cover letter, or job application, such as your employment history, qualifications, and/or professional memberships.
• Education information, including degrees awarded, transcripts, graduation year, and other information provided in support of the job application.
• Information collected during phone screenings and interviews.

• Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
• Reference information and information you provide during any background check, where applicable.
• Information necessary to demonstrate your ability to work in a particular jurisdiction.
• Other information that you provide and/or that we may need to collect during the recruiting and/or during any on-boarding process prior to employment (for example, if you are traveling for an interview with us, we may need to collect your date of birth, gender and/or other information to book your flight)

1. 1. Personal Information We Collect from Third Parties

We may receive certain information about you from third parties in connection with our review of your application and our recruiting activities. Third parties that provide us this information may include personal or professional references, recruiters, service providers (such as those that conduct background checks), and recruiting tools and services. Information we collect from them may include the types of information listed in Section 1.A, above.

1. 1. Non-Personal Information

Randolph College may collect and use de-identified, anonymized, and/or aggregated information, which is not considered personal information. De-identified, anonymized, or aggregated data may be derived from your personal information, but is not considered personal information, since it does not directly or indirectly reveal your identity.

1. Collection and Use of Personal Information

We will collect, use, and process your personal information in connection with carrying out our application, recruitment, and on-boarding process (as applicable), including to:

• Process and review your job application, including any cover letter, resume, and/or references.
• Consider you for employment opportunities and assess your skills, qualifications, and interests for a particular position.
• Contact you if we need more information related to your application or respond to questions from you.
• Schedule and/or conduct an interview with you.
• Reimburse you for any travel expenses relating to interviews and/or any on-boarding prior to employment.
• Verify your information and carry out employment, background, and reference checks, where applicable and/or where required or permitted by applicable law.
• Communicate with you about the recruitment process and your application.
• Manage any on-boarding process or procedures.
• Keep records related to our hiring processes, and monitor for diversity and equal opportunities.

• Analyze and assess the effectiveness of our recruiting processes.
• Create and submit reports, as required by applicable laws or regulations.
• Comply with legal, compliance, regulatory, and/or other corporate governance requirements (including, for example, to ensure compliance with applicable non-discrimination laws).
• Protect and defend the rights and property of Randolph College, other job applicants, our employees, or the public.
• Detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity, or violations of Randolph College’s policies or the law; for fraud and crime prevention; and for information protection and cybersecurity.
• Collect information for internal business, product, strategy, and technological development.
• Comply with our disaster recovery, business continuity, and record keeping obligations.

1. Data Sharing

We may share your personal information with the following parties:

External Parties

• Vendors, service providers, and contractors we use to assist in providing services to us or assist us in administering the recruitment process. We require all our third-party vendors, service providers and contractors, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us.
• Background check providers that verify information about you as part of your application.
• Professional advisers, such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business.
• Law enforcement agencies, courts, supervisory authorities, regulatory bodies and certain other third parties, to the extent that we are permitted or required to do so by applicable law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.
• To protect the rights, property, or safety of Randolph College, our services, employees or others; to investigate, prevent, or take action regarding suspected or actual illegal activities; or to otherwise exercise or defend legal claims or comply with our legal obligations.
• To other third parties with your authorization or upon your direction, such as to conduct a reference check.
• To other third parties, in connection with a change of corporate control or other investment in Randolph College, such as a restructuring, merger, transfer, or sale of some or all of our assets.

1. Data Transfer and Storage

Recruiting is managed by Randolph College, Inc., which is headquartered in the United States.

Your personal information may be disclosed in response to inquiries or requests from governmental or regulatory authorities.

1. Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

1. Data Retention

If you are hired, your application information becomes part of your employment record, and we may use it in connection with your employment consistent with our employee privacy notice.

If you are not hired, we keep your application to allow you to obtain information about the recruitment process and to consider you for other job openings.

We also will retain your personal information to comply with our legal obligations under applicable law; for the time that Randolph College uses the data in furtherance of fraud prevention, security, or to otherwise help ensure the integrity of our company and services; the time that Randolph College uses the data in furtherance of establishing or defending a legal, regulatory, or law enforcement claim or investigation; and/or for any other permitted purpose under the CCPA.

1. Additional Information for Applicants that are California Residents

We are providing this additional information to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). This section applies solely to applicants who reside in the State of California. Any terms defined in the CCPA have the same meaning when used in this section of the Privacy Notice.

1. 1. Categories of Personal Information We Collect

During the application, recruitment, interview, and/or any onboarding process prior to employment at Randolph College, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. The table below identifies the categories of personal information that Randolph College has collected from you as an applicant to an open position at Randolph College in the preceding twelve (12) months:

Randolph College will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes, without providing appropriate notice to you.

1. 1. Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you submit your application and resume/CV, or correspond with us by post, phone, e-mail or otherwise.

• Indirectly from you. For example, through automated technologies or your interactions with us.

• Third Parties. We may receive personal information about you from various third parties, such as your references, background check providers, service providers, or other third parties that you direct to share information with us.

1. 1. Purposes for Collecting and Using Your Personal Information

We collect, use, and process your personal information for various business purposes as an employer to evaluate you as a candidate, including those listed in Section 2 above.

In addition to the reasons listed above, we collect sensitive personal information for the following business purposes:

• Monitoring equal employment opportunities.
• Conducting background verification processes (to the extent permitted by applicable laws).

1. 1. Disclosures of Your Personal Information

We describe in Section 3 above the context in which your personal information may be disclosed to a third party. The table below identifies the categories of personal information disclosed to third parties, service providers, or others for a business purpose in the preceding twelve (12) months.

In addition, Randolph College may disclose any or all of the personal information identified in the categories above to the following categories of third parties for a business purpose, depending on how you interact with our Services and/or where Randolph College has an obligation to make such disclosure:

• Government entities, where required by law or in order to comply with our legal or regulatory obligations
• Other third parties, where required by law or in order to protect our rights, or the rights of our customers or others
• Third parties, in connection with a change of corporate control or other investment in Randolph College.
• Third parties, where you have expressly consented to the disclosure your personal information

Randolph College does not “sell” or “share” your personal information (including sensitive personal information) as each term is defined under the CCPA. Randolph College does not use or disclose your sensitive personal information, except as necessary to evaluate you as a candidate (as detailed further in this Privacy Notice).

1. 1. Your Rights Under the CCPA

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

To exercise a CCPA consumer right as described above, you can submit a verifiable consumer request to us by emailing humanresources@randolphcollege.edu.

Making a Verifiable Consumer Request:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Using an Authorized Agent: If you use an authorized agent to submit a consumer request, the authorized agent must provide documentation or other proof indicating that they are authorized to act on your behalf. For requests to correct, access or delete, we may require you to verify your identity directly with us (for example, by emailing us directly from your email address associated with