Candidate Privacy Notice
Last Updated: September 2022
- Personal Information We Collect
- Use of Information
- Information That We Share With Third Parties
- Transfer of Information
- Data Retention
- Passive Information Collection: Cookies and Similar Technology
- Choices and Access
- Supervisory Authority Contact Information and Complaints
- Automated Processing
- Law Applicable to Job Application
- About Children
- Changes to the Notice
- Contact Us
1. Personal Information We Collect
We collect Personal Information from you in connection with your application. For purposes of this Notice, “Personal Information” means information relating to an identified or identifiable natural person, including any personal information or personal data as defined under the applicable privacy or data protection laws, rules or regulations (“Applicable Law”).
Personal Information that we use during the application and recruitment process may include:
Information Collected or Received From You
- Contact Information: name, address, telephone number, e-mail address, and other contact information;
- Application Materials: CV, résumé, and cover letter;
- National Identifiers: social security number, national identification number, government identification number, or similar national identifiers;
- Experience: previous work, practical and other relevant experience;
- Education: education, including level, type, subject-matter, degrees, diplomas and certificates, and institutions;
- Position of Interest: positions, roles and opportunities of interest, and if applicable, position offered;
- Skills: skills, languages, and other competencies;
- Certifications: professional and other work-related licenses, permits and certifications held;
- Reference Details: information you provide relating to references;
- Online Account Information: username and password to access the Careers Site, and application identifiers
- Device Information: automatically collected information regarding the type of device on which the Careers Site is accessed and used, the operating system name and version of the device used to access the Careers Site, device manufacturer, application version accessed on your device, device ID, IP address, and geolocation data.
- Information from interview and phone screenings;
- Demographic information;
- Communication Preferences: preferred communication method and language;
- On-Premise Monitoring: electronic monitoring of our offices and other workplace facilities (images and video), in accordance with Applicable Law and internal policies, such as monitoring internal and external access points and common areas;
- Event Information: dietary restrictions, travel and accommodation details, government-issued identification to access one of our physical premises, and other details specific to a particular recruiting interview, meeting or other event;
- Work Authorization: work authorization status and relevant visa or other immigration information; and
- Other Information: any other information you otherwise elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).
Please note that we may also ask that you provide information that may be treated as sensitive information, such as race/ethnic origin, gender, and disability of our applicants (“Diversity Information”), for monitoring equal opportunity, or information about your criminal records (“Criminal Records”). We will do so only where permitted by Applicable Law and will follow all applicable processing restrictions associated with processing such data. Where applicable, we will obtain your express permission when any of your sensitive personal information is processed in connection with your job application. Otherwise, we ask that you avoid submitting information that may qualify as sensitive information under Applicable Law, except where such information is legally required.
Depending on Applicable Law, Sensitive information may include race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, veteran status, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, financial and bank account data, personal identification information, or precise positioning information.
Information Collected Using Cookies and Other Web Technologies
Along with our service providers, we may use “cookies” and similar technologies on the Careers Site to collect certain information. Please see our Cookie & Similar Technologies Policy for more information.
Information Collected From Other Sources
Throughout the course of reviewing your Application Material, we may obtain information about you from other sources to the extent permitted by applicable law. Such information may include:
- References: details about experience, education, skills and other information contained in reference letters or otherwise obtained from references;
- Educational Records: transcripts, diplomas, and letters of attendance, verification or similar from educational institutions you attended;
- Licensing / Certification Organizations: registrations with professional licensing organizations;
- Criminal Record Registries: details about criminal records, when permitted by Applicable Law;
- Immigration Status: details about immigration status from applicable local agencies;
- Credit Reports: reports about your credit history and applicable bankruptcies, from local credit bureaus, if applicable and when permitted by Applicable Law;
- Information received from background checks, when permitted by Applicable Law; and
- Social Media Information: details from your social media accounts, such as LinkedIn.
We may combine the Personal Information we receive from various sources with Personal Information we collect from you and use it as described in this Notice.
2. Use of Information
The information that you submit on the Careers Site will be used for Stanley Black & Decker’s global personnel recruitment, management and planning purposes, as permitted by Applicable Law. The purposes of our uses of your Personal Information include:
- Application Review: including the process of evaluating an applicant’s suitability and fit for applicable roles and opportunities;
- Application Processing and Recruitment: including facilitating access to Careers Site, submission, transmission and efficient processing of applications, and interviews and recruitment events, including any related travel and meals;
- Providing Communication and Updates: includes responding to your inquires, communicating with you about your application, and sending you information about the Careers Site and Changes to our terms and Policies;
- Checking References: including contacting references to obtain additional information about candidate suitability;
- Application Verifications and Background Checks: includes conducting verifications and background checks, subject to Applicable Law. This may include reviewing any records of criminal history, contacting references, and confirming the veracity of application details, such as education, experience, work authorization and qualifications;
- On-boarding Activities: including incorporating Personal Information into our human resources system and use it to manage the new-hire process. Any such information may become part of your employee file and used for other employment-related purposes in the event we hire you;
- Diversity and Inclusion: such uses may include Monitoring and fostering equal opportunity in recruitment processes in accordance with applicable law;
- Compliance with Legal Requirements: including compliance with legal and other requirements applicable to our businesses in all countries in which we operate; conducting audits and investigations, undertaking mergers and acquisitions, for financial, accounting, insurance and dispute resolution purposes;
- Improving Recruiting Processes: including identify opportunities and implement changes to make our recruitment processes more effective, efficient and engaging, including through analytics and aggregate reporting;
- General Business Operations: including carrying out internal business activities. This may include conducting internal training, monitoring for and preventing fraud, safety and security, protecting our legal rights, ensuring our privacy and safety, protecting our property and/or that belonging to our affiliates, you or others, detecting and preventing cyberattacks, managing mergers, acquisitions, sales, reorganizations, joint ventures, assignments, transfers, or disposals and integration with purchaser.
- Future Recruitment: to the extent permitted by applicable law, this includes collecting and storing Personal Information for the candidate to be considered for future opportunities.
- To protect our legitimate business interests and legal rights pursuant to applicable law.
Legal Basis for Processing Personal Information - EEA
When collecting and processing the Personal Information of individuals residing in the European Economic Area (“EEA”) and other jurisdiction where a legal basis is necessary for the processing of your data, the legal basis we rely on for collecting and using the Personal Information described in this portion of the Notice depends on the Personal Information we collect and the specific context in which we collect it. The legal bases for our processing of your Personal Information are as follows:
- Contract: We need to negotiate and enter into an employment contract with you.
- Consent: You have given us your express permission to do so, particularly when we process your sensitive data or future recruitment.
- Legitimate Interest: The processing is in our legitimate interests and it is not overridden by your rights, such as:
Finding the best candidate for any given position;
Processing your Personal Information in order to communicate effectively with and respond to your requests;
Conducting business operations including conducting internal training, monitoring for safety and security, protecting our legal rights, protecting our property and/or that belonging to our affiliates, you or others, detecting and preventing fraud or cyberattacks; or
Providing the best user experience and functionality for our Career Site;
- To comply with our legal obligations and applicable laws and regulations.
Vital Interest: We process your Personal Information to protect vital interests for the purpose of detecting and preventing fraudulent or illicit activities that impact a person’s vital interest or public safety.
Separate from the legal bases identified above, we may process your Personal Information to the extent you provide us with your consent to do so, in the relevant jurisdictions where Applicable Law provides for such consent. Thus, depending on the Applicable Laws in your jurisdiction, we may process your Personal Information based on various legal bases as permitted by the Applicable Laws and as outlined above, or we may rely on consent, where allowed by Applicable Laws. Where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by Applicable Law.
With your consent, the Personal Information that we collect about you may be added to Stanley Black & Decker’s international candidate database and may be retained and used to consider you for other opportunities at Stanley Black & Decker and its affiliates beyond the one(s) for which you apply. If you do not wish us to do this, please contact us at the address in the “Contact Us” section below.
Providing Personal Information to us during the application and recruiting process is voluntary. However, if you do not provide sufficient information, Stanley Black & Decker may be unable to consider your employment application.
3. Information That We Share With Third Parties
Stanley Black & Decker is a global company with operations in more than 60 countries and may share Personal Information with affiliates that are involved in evaluating candidates for a given position around the world. Stanley Black & Decker, Inc. will remain responsible for Personal Information that is shared with affiliates. You can consult the list and location of our affiliates here. In such instances, we limit access to Personal Information to personnel with a business need to know the information for the purposes described in this Notice, including personnel in the recruiting, human resources and information technology departments, and the department responsible for the position for which you are applying.
In addition to sharing information with our affiliates, we may also share your Personal Information as described below:
Information Shared in Order To Provide Our Services
We may share your Personal Information to the extent necessary to provide the Application Material. This includes, but is not limited to, updating, securing, and troubleshooting, as well as providing support.
Information Shared With Our Service Providers
We may engage third-party services providers to work with us to administer and support our business. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. Examples include hosting our web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These companies and individuals may be located in a country whose data protection legislation is different from your country, and they will have access to your Personal Information as necessary to perform their functions, but they may not share that Personal Information with any other third party or use that data for any other purpose.
Information Disclosed in Connection With Business Transactions
We may disclose Personal Information to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings.
Information Shared With Third Parties to Market Their Products or Services
If you have not opted out of these disclosures, we may disclose your Personal Information to third parties to market their products or services to you.
Information Disclosed for Our Protection and the Protection of Others
We may disclose your Personal Information if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith – after considering your privacy interests and other factors – that such action is necessary to:
- Conform to legal requirements or comply with legal processes (including subpoenas);
- Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
- Stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in an Aggregated or Anonymized Manner
We also share aggregated or anonymized information about applicants with our partners and other third parties. However, such information is not considered Personal Information because it is anonymized and aggregated in such a way that it cannot reasonably linked back to the individual.
Information Disclosed to Others in Accordance With Your Preferences
We may disclose such Personal Information to third parties if you consent to such disclosure.
4. Transfer of Information
Disclosing your Personal Information can include transferring Personal Information to other countries outside of your jurisdiction, including the United States or any other country in which we or our service providers have operations. Several countries require that organizations put in special protections when information is shared cross border. SBD complies with those obligations and has implemented intercompany mechanisms to meet those requirements. With regard to transfers from EEA to other countries, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your information. Employees in the EEA may obtain a copy of these measures by contacting PrivacyPolicyManager [at] sbdinc.com (PrivacyPolicyManager[at]sbdinc[dot]com).
Moreover, if you are located in a country outside the EEA, SBD may also transfer your data to countries with data protection legislation that does not have the same level of security and standards as your local regulation. In such cases, SBD will carry out the transfers in accordance with the requirements of the Applicable Law to ensure the security, confidentiality and lawfulness of the data processing.
5. Data Retention
We will only retain Personal Information for the period necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by law, to meet legal requirements, or as necessary to protect ourselves from legal claims. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) the duration of our ongoing relationship with you; (iii) the legal obligation to which we are subject; (iv) applicable statutes of limitations, litigation, or regulatory investigations.
We may remove Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, Stanley Black & Decker may delete Personal Information about you (including your CV/résumé) from our database at any time and without providing any reason. Therefore, please retain your own copy of the Personal Information provided to us.
6. Passive Information Collection: Cookies and Similar Technology
We and our service providers use “cookies” and similar technologies on the Careers Site. Please see our Cookie & Similar Technologies Policy for more information.
7. Choices and Access
Depending on your country of residence, you may have certain choices and rights under Applicable Law. These may include the rights to access, correct, update, suppress, restrict or delete Personal Information, or object to the processing of Personal Information. If you register on the Careers Site, you may access, review, and change your Personal Information stored therein by logging into the Careers Site and updating your account information. To change Personal Information that you have already submitted for consideration for a specific position, please update your profile and resubmit your application for that position.
If you would like to exercise any of your rights or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by Applicable Law), you may contact us by: Privacy Web Form (onetrust.com) or PrivacyPolicyManager [at] sbdinc.com (PrivacyPolicyManager[at]sbdinc[dot]com). We will respond to your request consistent with Applicable Law. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests.
Where we rely on your consent to process your Personal Information, you have the right to withdraw your consent at any time. You can request that we stop using your Personal Information for recruiting purposes at any time.
Please note that certain Personal Information may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.
Under California law, applicants who are California residents have specific rights regarding their Personal Information. For more information please see our Additional Information for California Residents below.
Your Rights – EEA, UK, Switzerland Residents
If you located in an EEA jurisdiction, you may have the following data protection rights:
- The Right to Access, Update or Delete the Information We Have On You. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The Right of Rectification. You have the right to have your Personal Information rectified if that information is inaccurate or incomplete.
- The Right to Object. You have the right to object to our processing of your Personal Information.
- The Right of Restriction. You have the right to request that we restrict the processing of your Personal Information in certain circumstances.
- The Right to Data Portability. You have the right to be provided with a copy of the Personal Information we have on you in a structured, machine-readable and commonly used format.
- The Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your Personal Information.
- The Right to Complain to a Data Protection Authority. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA.
8. Supervisory Authority Contact Information and Complaints
Should you wish to raise a complaint about how Stanley Black & Decker processes your personal information, you may contact us by using our Privacy Web Form (onetrust.com) or PrivacyPolicyManager [at] sbdinc.com (PrivacyPolicyManager[at]sbdinc[dot]com), or, by contacting the Stanley Black & Decker data protection officer responsible for your country or region, if applicable, here. You may raise a concern or lodge a complaint with a supervisory authority or other regulatory agency for your country or region if you believe that we have violated any of the rights concerning your Personal Information. A list of EEA Supervisory Authorities is available here.
We use reasonable organizational, technical and administrative measures intended to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Stanley Black & Decker hereby disclaims, as far as permitted by Applicable Laws, any liability for itself and its affiliates and contractors for any Personal Information collected by SBD in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Careers Site.
10. Automated Processing
We may use automated tools to assist us in processing and evaluating job applications. These tools leverage complex algorithms and machine-learning technology to assist with the following operations.
- Minimum requirements. We use automated tools to determine whether, based on the information you have provided to us, you meet the minimum requirements for a position. For example, if the job requires three years of experience as a software developer, these tools will analyze the selections you make in forms you submit through the Careers Site and/or the words and textual patterns collected in connection with your application to determine whether this type of experience is present or not.
- Job match ranking. We use automated tools to assign a percentage value to your application that assesses how strong the fit is between your application and the requirements of the target role. Our tools may rely on several factors in assigning these percentages, which may vary per job. For example, for certain jobs specific practical experience may be of more relevance than certifications, for others it may be the other way around. Based on the analysis, our automated tools can provide a Stanley Black & Decker employee with an overview of candidates that are potentially qualified to for the relevant position. The Stanley Black & Decker employee will then assess these recommendations and, based on our standard processes, contact and interview candidates.
11. Law Applicable to Job Application
The Application Materials allow you to apply for jobs world-wide, as a benefit of Stanley Black & Decker’s centralized global recruitment function. This Careers Site is operated from the United States. Accordingly, any Personal Information you submit to the Careers Site will be collected in the United States and will be subject to U.S. laws. If we share your Personal Information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your Personal Information in accordance with this Notice. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.
12. About Children
The Careers Site is intended for individuals who at least 18 years and is not directed toward children under 18. As such, we do not knowingly collect Personal Information from individuals under 18. If we learn that we have accidentally collected Personal Information of a person under 18 we will take steps to delete such information from our files as soon as possible.
13. Changes to the Notice
We may amend this Notice from time to time. When we do so, we will update the “Last Updated” date above to indicate when those changes will become effective. Any information that is collected via the Application Material is covered by the Notice in effect at the time such information is collected.
14. Contact Us
If you have questions, requests or complaints, please feel free to contact us by filling our form at Privacy Web Form (onetrust.com) or by email at PrivacyPolicyManager [at] sbdinc.com (PrivacyPolicyManager[at]sbdinc[dot]com).
For candidate in the EEA, the SBD entity to which you applied for a job is the data controller of your Personal Information, and questions, requests or complaints can be directed to the email above.
Because email communications are not always secure, please do not include sensitive information in your emails to us.
Additional Information for California Residents
This Privacy Notice describes the Personal Information we collect or process about California residents in connection with the Application Materials and the use of our Career Site, how we use, share, and protect that Personal Information, and what your rights are concerning your Personal Information that we collect or process.
Personal Information We Collect and Share, and for What Purpose
In the past 12 months, we have collected and/or shared the following Personal Information of visitors when they interact with our Career Site, as described in detail above in the following sections:
- Information Collected or Received from You;
- Information Collected Using Cookies and other Web Technologies; and
- Information Collected From Other Sources.
In the past 12 months, we have shared the above information with the categories of third parties discussed above in the sections titled:
- Information Shared in Order to Provide our Services;
- Information Shared with Our Service Providers;
- Information Disclosed in Connection with Business Transactions;
- Information Shared with Third Parties to Market their Products or Services; and
- Information Disclosed for Our Protection and the Protection of Others;
We use your Personal Information for a variety of purposes set forth in the section above titled “Use of Information”
Shine the Light: Under California Civil Code Section 1798.83, you can request on an annual basis information regarding the disclosure of your Personal Information to third parties for their direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes.
Sensitive Personal Information We Collect and Share, and for What Purpose
In the past 12 months, we have collected and/or shared the following Sensitive Personal Information (as defined by the CPRA) from candidates when they provide Application Material,
- Nationality or national origin;
- Sex life or practices or sexual orientation;
- Medical or health information (including disability status);
- Genetic or biometric information;
- Biometric templates;
- Political or philosophical beliefs;
- Political party or trade union membership;
- Financial and bank account data; and
- Precise positioning information.
We may use this Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure, and the individuals we interact with. This includes, without limitation, receiving and processing your job application, evaluating your suitability for the position(s) you are applying for, conducting background checks, analyzing and monitoring diversity, making you an offer (subject to our discretion), fulfilling administrative functions, complying with law, legal process, or requests from governmental or regulatory authorities, and exercising or defending legal claims.
Your Rights as a California Resident
Under California law, candidates who are California residents have specific rights regarding their Personal Information. These rights are subject to certain exceptions described below. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.
Right to Correct Inaccurate Information
You have the right to request that we correct any inaccurate personal information about you, considering the nature of the personal information and the purposes of the processing of the personal information. Upon a receiving such a request, we shall use commercially reasonable efforts to correct the inaccurate personal information.
Right to Disclosure of Information
You have the right to request that we disclose the specific pieces of personal information that we have collected about you, such as:
- The categories of Personal Information SBD has collected about you in the last 12 months.
- The categories of sources for the Personal Information SBD has collected about you in the last 12 months.
- SBD’s business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom SBD shares that Personal Information.
- The specific pieces of Personal Information SBD collected about you.
- If SBD disclosed your Personal Information to a third party for a business purpose, a list of the Personal Information types that each category of recipient received.
Right to Limit Our Use of Your Sensitive Personal Information
You may, at any time, to direct us to limit our use of your Sensitive Personal Information to that which is necessary to perform the services (i.e., process your application). In the event you make such a request, we shall not otherwise process, share, or use your Sensitive Personal Information without your consent.
Right to Opt-Out of Sale or Sharing of Personal Information
You have a right to opt-out of the sale or sharing of your Personal Information for purposes of cross-contextual advertising.
We do not sell or share your Personal Information and therefore do not provide any mechanism for you to exercise the right to opt out.
Right to Non-Discrimination
You have the right not to be discriminated against for the exercise of your California privacy rights described above.
Right to Delete Personal Information
You have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.
How to Exercise These Rights
You may submit a verifiable consumer request to us for disclosure or deletion of Personal Information by clicking here: Privacy Web Form (onetrust.com).
Alternatively, you may call us at +1 (888) 997-6648 or contact us via the methods provided in the Section entitled “Contact Us” above.
In order to protect your privacy and the security of your information, we verify consumer requests. Any additional information you provide will be used only to verify your identity and not for any other purpose.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney under Probate Code sections 4000-4465 may submit a request on your behalf.
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent. In addition, we may require the individual on whose behalf you are making the request to verify their own identity or your permission to submit the request.