WHAT IS THE PURPOSE OF THIS DOCUMENT?

EPAM Systems Inc. and its affiliates (“EPAM”, “we”) are committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your application process.

This privacy notice applies to all applicants for employment or contracting engagements based in South America, Africa, Middle East, Asia and Australasia, and describes how we collect and use personal information about you during and after your application process. This privacy notice does not apply to TestIO freelancers.  

We may update this privacy notice at any time.  The most current version can always be accessed on our Career Site.

This privacy notice should be read in conjunction with the general privacy policy and cookie notice for general use of our corporate websites, and specific EPAM platform notices.

We have set out below the full details of the relevant EPAM entity based on the country of the role you are applying for and the entity which decides how we process your personal information.

This privacy notice does not imply in any way any contract of employment or contract for services or any other relationship between you and EPAM. 

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data, or personal information, means any information, by itself or combined with other information, about an individual from which a person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Date of birth, social security number and/or other government issued identifiers in connection with post-offer background checks, where applicable
• Your CV, professional social media profile such as LinkedIn, cover letter, application forms and other information regarding your employment history such as dates of employment, job titles, job descriptions, skills, reason for leaving, previous salary and benefits information, any websites or blogs you own or have contributed to, any photographs contained in your CV or professional social media profile, areas of interests, notice periods/availability for employment;
• Your salary or other remuneration expectations and details of any offers made by us to you and your responses;
• Interview history, questions, notes and technical assessment results;
• Information obtained when conducting a post-offer background check, where applicable, such as relative to references, criminal history, credit history, drug-check, finger-print check, and other screening results that may be applicable;
• Your feedback on EPAM’s recruitment process;
• How you heard about EPAM or any specific position;
• Information EPAM receives from your use of any EPAM websites, such as the IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and location information such as country/state of user
• CCTV footage from attendance at any EPAM sites where we control the CCTV systems and any recordings of online video meetings, interviews or assessments;
• Any requests for reasonable accommodations or accommodations to comply with applicable equality legislation;
• Information to assess your right to work in the hire location, such as for example work permit status;
• Details of communications with you, how you interact with email communications and marketing communications;
• Your data privacy and marketing communications preferences.

If you use your online profile using epam.com we will also collect, store, and use the additional following categories of personal information about you, such as:

• Your username and data required for log-in;
• Your log in frequency and activity;
• What software, devices or hardware you use to access your profile;
• Your profile preferences and other forms you may complete in the online profile;
• Any privacy or communication channel and frequency preferences.  

HOW IS YOUR PERSONAL DATA COLLECTED?

We mainly collect personal information about applicants from:

• Directly from you, when you share the information with us during discussions or communications;
• Directly from you, when you use our website epam.com/careers, other EPAM online platforms or applications, email applications or at a recruitment fair;
• From recruitment agencies that you are registered with and have agreed for them to provide us with your application information;
• From current EPAM employees or contractors, with your prior permission, as part of our internal referral program;
• From third party websites and job boards that you have used to seek employment or display a professional profile on, such as LinkedIn, Monster, etc.;
• From third party websites or platforms that help us obtain your contact details (if we do not already have it) or verify employment history from publicly available sources 

HOW WE WILL USE INFORMATION ABOUT YOU?

We may use your personal information for the following purposes:

• To allow you to register, set up, and maintain an online profile
• To consider you or contact you for any role you have applied to or that we are otherwise considering candidates for
• To review or report on federal contractor compliance or other legal requirements
• Updating you on any changes to our privacy notice, security updates, changes to our website or online profile area
• To make a decision regarding your recruitment or candidacy for employment or other engagement
• To determine any terms on which you may work for us
• To determine whether any reasonable adjustments or accommodation are required in connection with your application
• Internal reporting and understanding how we can improve our internal recruitment processes and website
• Understanding user traffic to our website
• Physical security of our people, visitors and property
• If you are hired or engaged, information may be incorporated into our HR or vendor system and become part of your HR or vendor file, and used for employment or engagement-related purposes

DATA SHARING

Where you are represented by a recruitment agency, we will share information about your recruitment activity (such as interview feedback, any offers etc.) so they can discuss this with you.

Given the nature of EPAM’s business, from time to time our clients would like to receive summary CVs of applicants like you, as well as our existing employees. At times we might provide only an anonymized summary CV but this is not always possible.

In order to understand how we can improve our internal recruitment processes, we may use a third party survey provider to (i) send you an invitation to a survey and or (ii) collect your responses.  Typically, we only share your name and email address. Only team leaders and recruitment managers in EPAM’s appropriate Talent Acquisition teams will have access to replies from applicants under their remit. Your replies will not affect the progress or outcome of any recruitment process with EPAM. 

We may also partner with a background check vendor to assist in any post-offer background checks of applicants, which may require sharing certain personal information such as name, date of birth, address, social security number, etc., for purpose of ordering the check.  Such checks will only be performed after securing your express consent.

Where we need to technical testing of your skills, we may use third party providers to undertake the testing on our behalf. We may typically share your name and contact information, primary skills, the role or the type of role you are applying for and your resume or CV, if required.

We may also use third party communication providers to help us manage communications around our recruitment and information campaigns.

We may also need to use third party service providers, for example, to help us manage our applicant tracking system or to host our websites or servers. We put contractual terms in place to protect your personal data.

We will share your data with other companies within the EPAM group only for the purposes set out above.  As EPAM is a global company with a presence in over 25 countries, we transfer the personal information we collect about you to our group companies which may include outside of your country. To ensure that your personal information receives an adequate level of protection we have put in place an intragroup data transfer agreement to ensure that your personal information is treated in a way that is consistent with and which respects data privacy laws.

Note, where, in accordance with this notice, we send or outsource your personal information to a country other than the country in which you are applying to render services for the Company, that personal information may be available to the applicable foreign government or its agencies under a lawful order made in that foreign country for purposes other than described herein.

We may need to disclose all or any part of your personal information if required to do so by law, or pursuant to a request from a governmental or regulatory entity/body or if we believe in good faith that such disclosure is necessary to (1) comply with legal or regulatory requirements or for the purposes of compliance with legal process; (2) prevent crime; (3) prevent any terrorist activity or threat to national security; or (4) protect the safety or wellbeing of users of our staff or any other person.

We will not otherwise sell your data that you provide to us in connection with the application process.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, contractors and third parties who have a business need to know. They will only process your personal information 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 follow any legally required breach notification processes where we are required to do so.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 unauthorised 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 anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

RECRUITMENT CAMPAIGNS

You can opt out of receiving information about our recruitment campaigns from EPAM.

You may unsubscribe from these emails at any time by a) unsubscribing using our website, b) logging into your online profile, if you have one, or b) by clicking the unsubscribe link on any recruitment campaign email from us.

We will take reasonable steps to unsubscribe you from these emails, but it may take up to 72 hours to take effect.

YOUR CONSENT

By proceeding with your application, where required by applicable law, you indicate your acceptance of our collection, saving, use, transfer and disclosure of personal information as described in this notice.  If you do not accept the terms you will not be allowed access to apply for a position online or have your written, offline submission considered for a position.  

By using EPAM’s career site or otherwise applying for work with us, you also agree to the transfer of personal information about you to countries outside the country in which you reside, which may include countries with a different data protection regime than in place in the country in which you reside, as outlined above.  We will take appropriate technical, organizational, and legal steps to secure personal information about you.

The provision of personal information is voluntary.  Please note however, failure to provide sufficient information may result in EPAM being unable to consider your application. 

YOUR RIGHTS

According to applicable law, you may have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular 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 information for direct marketing purposes such as our recruitment campaigns or “hot jobs” emails.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact [email protected] in writing.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

QUESTIONS, REQUESTS AND COMPLAINTS

All queries and requests for should be sent initially by email to: [email protected]

EPAM SYSTEMS IN YOUR LOCATION

8 October 2020