This Privacy Notice for California Job Applicants supplements the information contained in EPAM’s Applicant Privacy Notice, The Americas. and applies solely to applicants who are residents of the State of California. This notice is being provided pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (CCPA). 

Definitions

What Categories Of Personal Information Do We Collect About You?

We collect the following categories of your personal information when you apply to EPAM. Those categories marked with an “*” include some sensitive information.

• Identifiers*. Information such as your full name, contact information (home address, phone number, and email address), alias, and signature.
• Government Issued Identifiers*. Information such as social security number, work authorization information, passport and visa information, and immigration status and immigration-related documentation.
• Demographic Data*. Information such as your name, address, date of birth; and gender, race, ethnicity, veteran status, religion, and disability status (generally when required for government reporting purposes).
• Content of your Communications*. Information such as your communications with us, as well as communications with others.
• Educational and Professional Information*. Information such as information related to work experience history, educational history and degrees attained; interview notes; professional and other certifications; other job qualification criteria; and information we may obtain (directly or through a service provider) when conducting a background check such as relative to references, criminal history, credit history, drug-check, finger-print check, and other screening results that may be applicable.
• Health and Safety Information*. Information such as health conditions and disabilities (if relevant to your employment), and potential job-related restrictions.
• Employment Related Information*. Information such as details of any job offer made to you, including those that may be communicated in an offer of employment and/or related documents.
• Information Systems Information / Network Activity*. Information such as login information used to access our premises or online network; and Internet Protocol (IP) address or other device location information of devices used to access our online network.
• Geolocation Information. Information such as time and physical location related to use of an internet website, application, device, or physical access to our office locations.
• Sensory / Surveillance Information. Information such as call monitoring/recording and video recording, where applicable (such as to record certain applicant interviews), which you would have notice of if applicable.
• Employee Staffing and Survey Information. Information such as information about an applicant’s preferences, characteristics, attitudes; information about perceptions regarding an applicant’s attitude, intelligence, abilities, aptitude, and information about job criticality and leveling used for hiring purposes.

How Do We Collect Your Personal Information?

We obtain your personal information:

• Directly from you verbally or in other communications;
• Directly from you through your use of EPAM emails, websites, networks, and company devices;
• From other employees and contractors that may have worked with you or assessed you;
• From background check vendors for purposes of background check administration; and
• From previous employers or clients you may work with.

How Long Do We Keep Your Personal Information?

EPAM keeps your personal information, including sensitive personal information, for so long as is reasonably necessary and proportionate to the original purpose for which we collected the information or for another disclosed purpose. We base our criteria in determining appropriate retention periods on regulatory and legal requirements, contractual requirements, business needs, and the expectations of you.

How Do We Use Your Personal Information?

We may use your personal information for the following purposes: 

• For financial or risk management, including fulfilling our audit requirements, and accounting and cost/budgeting analysis and control.
  
• In order to fulfill our legal, regulatory, administrative and organizational obligations, including compliance with employment and immigration laws, Federal Contractor Compliance Program regulations, and applicable tax and other legislation.
  
• Conducting internal audits and workplace investigations.
• Maintaining commercial insurance policies and coverages.
• Monitoring and ensuring compliance with applicable Company and client policies and procedures.
• Managing compliance with client contract requirements.
• Managing corporate information technology, including helpdesk, corporate directory, IT support, and IT security.
• Conducting security screenings, to the extent permitted by law.
• For employment qualification, verification, and other background checks, including recruiting and evaluating job applicants.
• Engaging in corporate transactions requiring review of applicant records, such as for evaluating potential mergers and acquisitions of the Company.
• Performing workforce analytics, data analytics, and benchmarking.
• Administering and maintaining the Company’s operations, including for safety purposes.
• Exercising or defending the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.

How Do We Disclose Your Personal Information?

EPAM may disclose your personal information, including your sensitive personal information, for the following purposes:

• Within the EPAM group of companies: As part of our global structure, employee managers or certain regional or global departments may be located at other EPAM companies. Therefore, other EPAM entities within the global EPAM group of companies may collect and/or receive your personal information for the purposes outlined above. In order to provide adequate protection for such personal information transfers, EPAM implements organizational and technical security measures and appropriate data transfer agreements.
• With certain non-EPAM parties: Existing or potential business partners, suppliers, customers, independent external advisors (e.g., auditors), banks, insurance carriers, benefits providers, and other third parties may also receive your personal information as necessary in connection with our business operations, in particular to carry out our contractual relationships with such third parties, to administer and provide compensation, administer and provide applicable benefits, administer the workforce, comply with applicable laws and employment-related requirements, communicate with employees and third parties, to comply with corporate financial responsibilities, and respond to and comply with requests and legal demands.
• With certain acquiring or acquired entities: If the EPAM business to which you are applying is sold or transferred in whole or in part or if EPAM is acquiring and integrating another entity into the EPAM business to which you are applying (or any similar transaction is being contemplated), your personal information may be transferred to the other entity (e.g., the new employer, potential new employer, the new acquired entity, or potential new acquired entity) prior to the transaction (e.g., during the diligence phase) or after the transaction, subject to any rights provided by applicable law, including jurisdictions where the other entity is located.
• With other personal information processors: Certain parties, whether affiliated or unaffiliated, may receive your personal information to process such information under appropriate instructions as necessary to support and facilitate any of the above processing purposes. Such parties will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard your personal information, and to process your personal information only as instructed and to provide adequate protection to personal information transfers. 

Your Rights

You may submit any request below by emailing [email protected] or contacting us at +18443860005. We will verify your identity using the information you provide us with the request. We reserve the right to request additional information for verification purposes. You may designate an authorized agent to submit a request on your behalf. When you use an authorized agent, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

We may take steps to verify your identity by matching the information you provide with your request with the information we have on file about you. Depending on the sensitivity of the information at issue, we may utilize more stringent verification methods, including but not limited to requiring you to sign a declaration under penalty of perjury.

• Right of Access. Subject to certain exceptions under the law, you may request that we disclose the categories of personal information and sensitive personal information we have collected about you, including information about how that information has been used and disclosed. You also have the right to request specific pieces of your personal information and sensitive personal information.
• Right to Correct. Subject to certain exceptions under the law, you may request that we correct your personal information in our possession.
• Right to Delete. Subject to certain exceptions under the law, you have a right to submit a request that we delete your personal information and sensitive personal information. We may be unable to complete this request if the information is necessary to complete a transaction with you, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, comply with the law, or to use internally for purposes aligned with your expectations. There are other exceptions that may apply to this request.
• Right to Non-Discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section.

Notice of Collection

• To learn more about the categories of personal information we collect about California residents, please see What Categories of Personal Information Do We Collect About You? and How Do We Collect Your Personal Information? above.
• For more information about how we use those categories of personal information, please see How Do We Use Your Personal Information? above.
• For more information about how we collect categories of personal information, please see How Do We Collect Your Personal Information? above.
• To learn more about how we disclose categories of personal information, and the categories of third parties with whom we disclose such information, please see How Do We Disclose Your Personal Information? above.
• To learn more about how long we keep your information, please see How Long Do We Keep Your Personal Information? above. 

Notice of Disclosure for a Business Purpose

To learn more about the categories of personal information we have disclosed for a business purpose, and the categories of third parties with whom we’ve disclosed such information, please see How Do We Disclose Your Personal Information? above. 

Notice of Sale and Sharing

We do not “sell” or “share” your personal information. We are legally obligated to also specifically advise you that we do not sell or share the personal information or sensitive personal information of any California resident who is 16 years or younger.

For purposes of this section, “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration.

For purposes of this section, “share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by other means, your personal information to a third party for “cross-context behavioral advertising,” whether or not for money or other valuable consideration. 

Notice of Use of Sensitive Personal Information

We do not use California resident sensitive personal information for any purpose other than is permissible under the CCPA. Specifically, we do not use sensitive personal information of California residents to infer characteristics about California residents (i.e., make assumptions about you as a person based on the substance of your sensitive personal information).

Accessibility

You may access this Privacy Notice and other notices in an alternative format by contacting us at [email protected] or +18443860005.

Changes

We may change this Privacy Notice from time to time. Changes to this Privacy Notice will be available at https://www.epam.com/epam-privacy-notice-for-california-job-applicants, and may be provided via e-mail or another method, as appropriate under applicable law. The last updated date will be stated at the top of this Privacy Notice. You should regularly check https://www.epam.com/epam-privacy-notice-for-california-job-applicants for any changes to this Privacy Notice.

Contact

If you have any questions about this Privacy Notice, you should contact [email protected].