Privacy Policies

TNS Job Applicant Privacy Policy – USA

Updated 08 October 2020

DEFINITIONS

In this document:

• “Personal Data” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
• “Job Applicant Privacy Policy” means the current version of this TNS Job Applicant Privacy Policy – USA.
• “We” or “TNS” means Transaction Network Services, Inc., a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA.
• “You” means the person who is applying for a job on our websites.

PRIVACY COMMITMENT

We are committed to respecting your personal privacy, to processing your Personal Data in accordance with your consent, and to protecting any Personal Data that we have collected from you. This Job Applicant Privacy Policy is intended to describe processes for collecting, distributing, and protecting Personal Data, as well as your rights with regards to your Personal Data, specifically in connection with your application for a job through our websites. On our websites, you will be required to indicate that you have read and agree with this Job Applicant Privacy Policy before you will be allowed to apply for a job with us.

This Job Applicant Privacy Policy is intended to apply only to those persons who are residents of the United States of America.

TYPES OF PERSONAL DATA COLLECTED

In connection with your application for a job with us, Personal Data collected by us includes information that you voluntarily submit to us, and may include the following:

• Biographical Information: This includes information you provide to us about yourself, including your name, alias(es), former name(s), gender, date of birth, email address, mobile telephone number, home telephone number, address(es), protected classification(s), language proficiencies, and other information required to determine your eligibility and suitability for a job with us, as well as information about you provided to us by your current or former employers, educational institutions, and co-workers.
• Educational Information: This includes information you provide about educational history, such as the names, places, and dates of attendance and graduation of your schools, trade schools, colleges, and universities, as well as the certificates, diplomas, and degrees awarded, as well as information provided to us by your current or former educational institutions.
• Professional Information: This includes information you provide about your employment history, such as the names, places, and dates of former or current employers, the positions you held, professional qualifications (such as licenses, permits, certifications, and memberships relevant to your work history), as well as information provided to us by your current or former employers and co-workers.
• Job Preference Information: This includes information you provide about the geographical locations, positions, and compensation you seek, as well as your willingness to relocate.
• Interview Information: This includes information you provide to us (whether in person, over the phone, in a virtual meeting, on paper, or otherwise) in the process of our interviewing you for a position with us.
• Other Information: This may include any additional information which you voluntarily provide to us, or make available to us through a third party, in the process of your application for a job with us.

 

COLLECTION OF PERSONAL DATA

Providing Personal Data to us in connection with your application for a job with us is voluntary. However, if you do not provide us with certain information, or do not provide sufficiently detailed information, we may be unable to consider you for a job with us.

To the extent you voluntarily provide us with your Personal Data in connection with your application for a job with us, or make such Personal Data available to us through a third party, we may collect such Personal Data in the following ways:

• Personal Data You Provide: You may give us your Personal Data (as described above) when you contact us to inquire about available jobs; when you apply for a job with us (whether on our websites, via mail, via email, or otherwise); and/or when you interview with us.
• Personal Data Received from Third Parties: We may receive information about you from third parties, including current or former employers, current or former educational institutions, and current or former co-workers.

USE AND SHARING OF PERSONAL DATA

We may use your Personal Data in several ways, including the following:

• Screening, Recruiting, and Hiring Applicants: We may use your Personal Data to evaluate your eligibility and suitability for one or more positions with us; to schedule and conduct interviews with you; to communicate with you regarding your job application(s); to satisfy our legal obligations (including, for example, our obligations under Equal Opportunity Employment laws); to evaluate and improve our recruiting process; and for routine business purposes.
• Sale of Personal Data: TNS does not sell any Personal Data collected in the job application process.

RETENTION OF PERSONAL DATA

At the time we collect your Personal Data in connection with your application for a job with us, we may store such Personal Data for the purposes of evaluating your eligibility and suitability for one or more positions with us. In addition, after the job application process, we may continue to store such Personal Data for the purposes of evaluating your eligibility and suitability for future positions with us. We may also retain certain information obtained from your Personal Data where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you, for the purposes of evaluating and improving our recruiting process.

PROTECTION OF PERSONAL DATA

We take precautions to protect the Personal Data we collect and store. All of our employees, as well as all of our service providers who have access to Personal Data, are obligated to protect it and keep it confidential. However, no system or electronic data transmission is completely secure. If you give us your Personal Data, you do so at your own risk. We expect that you will use appropriate security measures to protect your Personal Data.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Rights of California Residents (this section applies only to California consumers)

California consumers have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). Your rights and our obligations under CCPA are explained below.

Access and Disclosure Requests: Under CCPA, California consumers have the right to request, up to two times in a 12-month period, that a business disclose what Personal Data it has collected, disclosed, and sold about them in the 12 months immediately preceding the request. Here are the specific types of information California consumers may request, as well as an explanation of TNS’s practices for each one:

The categories and specific pieces of Personal Data that the business collected about them in the preceding 12 months, the business purpose for such collection, and corresponding categories of sources from which the business collected the information.

1. • In the last 12 months, TNS has (or may have) collected the following Personal Data:
     • TNS has (or may have) collected the Personal Data you provide to us, or that you make available to us through a third party, in connection with your application for a job with us as described in the “TYPES OF PERSONAL DATA COLLECTED” AND COLLECTION OF PERSONAL DATA” sections (above).
   • You may send an access request to TNS through the following channels:
     • Send an email to privacy@tnsi.com
     • Call 1-833-613-0205
     • Visit https://tnsi.com/forms/california-customer-privacy-act-ccpa/

 

2. The categories of Personal Information, and the categories of third parties to whom the business disclosed their Personal Information in the preceding 12 months, and the business or commercial purpose for such disclosure.
   • In the last 12 months, TNS has disclosed no Personal Data in connection with job applications with us to any third parties.

 

3. The categories of Personal Information and the categories of third parties to whom the business sold their Personal Information in the preceding 12 months, and the commercial purpose for such sale.
   • TNS does not sell any Personal Data in connection with the job application process.

 

Deletion Requests: Under CCPA, California consumers may request that a business delete any Personal Data that the business collected from or about them. Each such request is subject to reasonable verification of the consumer’s identity by the business. Note that there are some reasons a business will not be able to fully address a California consumer’s request, such as if the business needs to complete a transaction for the consumer, to detect and protect against fraudulent and illegal activity, to exercise the business’s rights, for the business’s internal purposes, or to comply with a legal obligation.

• You may send a deletion request to TNS through the following channels:
  • Send an email to privacy@tnsi.com
  • Call 1-833-613-0205
  • Visit https://tnsi.com/forms/california-customer-privacy-act-ccpa/
• You will need to provide enough information such that TNS can verify your identity. If TNS cannot reasonably verify your identity, your request may be denied.

Opt-out Requests: Under CCPA, California consumers may direct a business that sells Personal Data about the consumer to third parties not to sell the consumer’s Personal Data.

• TNS does not sell any Personal Data in connection with the job application process. Accordingly, TNS is not required under CCPA to respond to consumer requests to stop selling Personal Data provided by California Consumers in connection with their application for a job with us.

CONTACT INFORMATON REGARDING PRIVACY

• Contacting Us: You may contact us at any time if you have any questions about this Job Applicant Privacy Policy, to exercise your rights regarding your Personal Data, to file a complaint regarding how we process your Personal Data, or for any privacy-related queries. Please direct all queries and questions regarding privacy to our Data Protection Officer at the following email address: privacy@tnsi.com
• Contacting a Privacy Regulator: If you are not satisfied with our response, you can contact the relevant privacy regulator or agency in your state, or at the federal level, you can contact the Federal Trade Commission.

JOB APPLICANT PRIVACY POLICY UPDATES

This Job Applicant Privacy Policy is periodically reviewed and updated. The date of the last update to this Job Applicant Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice.

TNS Job Applicant Privacy Policy (Europe)

Effective: [ 30 ] October 2020

1. Introduction

1.1 TNS Job Applicant Privacy Policy (Europe) (European Privacy Policy) has been adopted by Transaction Network Services (“TNS”, “we”, “us”) and the following TNS Group operating companies in Europe (“TNS Europe”) who are responsible for your personal data are committed to protect any personal data that they collect in accordance with applicable privacy legislation.

Country	Company Name	Registered Details	Registered Office
UK	Transaction Network Services (UK) Limited	02952557	Sheffield Business Park, 5 Europa View, Sheffield S9 1XH
Ireland	Transaction Network Services (Ireland) Limited	539032	Suite 2, Third Floor, 23 Shelbourne Road, Ballsbridge, Dublin 4, Ireland
France	Transaction Network Services S.A.S.	RCS Paris 421 285 941	1 rue Saint Georges, 75 009 Paris, France
Italy	Transaction Network Services S.r.l	13403090155	Via Pergolesi, 2A 20124 Milano, Italy
Germany	Transaction Network Services GmbH	HRB 48703	Martin-Behaim-Str. 12 D-63263 Neu-Isenburg, Germany.
Spain	Transaction Network Services S.A.U.	A-82959529	Via de las Dos Castillas 33 Atica Edificio 6, Planta 3, 28224 Pozuelo de Alarcon, Madrid.
Netherlands	Transaction Network Services BV	34131544	Prinsengracht 449, 1016 HN Amsterdam, Netherlands
Austria	Transaction Network Services GmbH	FN 270335b	Mariahilfer Straße 32/5. Stock, A-1070 Wien, Austria
Sweden	Transaction Network Services AB	556443-6193	c/o Advice Företagsassistans AB Västmannagatan 10, 1 tr S-111 24 Stockholm
Poland	Transaction Network Services sp. z o.o.	526-286-44-19	ul. Grzybowska 5A, 00-132 Warszawa, Poland

 

For the purposes of this European Privacy Policy, “TNS Group” means the relevant TNS Europe operating entities specified above or any other TNS Group affiliate of the following TNS Group parent company:

Country	Company Name	Registered Details	Registered Office
USA	Transaction Network Services Inc.	Delaware Corporation	10740 Parkridge Blvd., Suite 100, Reston, Virginia 20191.

1.2 The European Privacy Policy applies to applicable to individuals who reside in the European Economic Area (EEA), the United Kingdom (UK) and Switzerland and their respective personal data. The relevant TNS Europe company who collects the data will be the data controller of your personal data. In addition, where processing of personal data is undertaken by other TNS Europe or TNS Group (for their own independent purposes), these associated companies may be joint controllers of your personal data.

1.3 We hold and process data on all current and former employees, workers, individual contractors, contingent workers, applicants, interview candidates, interns, agency workers, consultants, directors, and members (“staff” or “you” or “your”), and third parties whose information you provide to us in connection with the employment or other working relationship (e.g. next‑of‑kin, emergency contact information and/or dependents).

1.4 We take your data protection rights and our legal obligations seriously. Your personal data will be treated in a secure and confidential manner and only as set out below or otherwise notified to you in writing.

1.5 Please read the following carefully to understand our views and practices regarding your personal data and how we treat it. The following Data Privacy Notice describes the categories of personal data we may process, how your personal data may be processed, for what purposes we process your data and how your privacy is safeguarded in the course of our relationship with you. It is intended to comply with our obligations to provide you with information about the Company’s processing of your personal data under privacy laws. It does not form part of your contract of employment or engagement.

1.6 Purely for the purposes of this Data Privacy Notice, references to employment include engagement where you do work for us and you are not an employee.

1.7 TNS Europe may amend the European Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business.

 

2. Responsibility for data privacy

2.1 You may contact TNS’s Data Protection Officer (“DPO”) securely and confidentially at any time if you have any concerns about the processing of your personal data or any data protection issue.

Data Protection Officer
Transaction Network Services (Europe)
Sheffield Business Park,
5 Europa View,
Sheffield
S9 1XH

Email: privacy@tnsi.com

 

2.2 If you have any questions regarding the processing of your personal data, please email the Human Resources department at HR-EU@tnsi.com. If you are aware of an unauthorised disclosure of data or if you believe your privacy rights have otherwise been violated, please contact the Data Protection Officer at privacy@tnsi.com ..

 

3. Processing of personal data

3.1 The Company collects and processes your personal data for the purposes described in this European Privacy Policy. Personal data means any information describing or relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

4. What data do we process?

4.1 We collect various types of personal data about you for the purposes described in this European Privacy Policy including:

4.1.1 Personal details: your title and name, birth name, preferred name, any additional names, gender, nationality, second nationality, civil/marital status, date of birth, age, home contact details (eg address, telephone or mobile number, e‑mail), national ID number, immigration and eligibility to work information, driving licence, languages spoken; next‑of‑kin/dependent/emergency contact information, details of any disability and any reasonable adjustments required as a result;

4.1.2 Recruitment and selection data: skills and experience, qualifications, references, CV and application, record of interview, interview notes and assessment, vetting and verification information (eg results of credit reference check, financial sanction check and a basic disclosure criminal record check relating to unspent convictions where carried out and permitted by applicable law), right to work verification, information related to the outcome of your application, details of any offer made to you;

4.1.3 Data related to your engagement: contract of employment or engagement, work contact details (eg corporate address, telephone number, e‑mail), employee or payroll number, photograph, work location default hours, default language, time zone and currency for location, your worker ID and various system IDs, your work biography, your assigned business unit or group, your reporting line, your employee/contingent worker type, your hire/contract begin and end dates, terms and conditions of engagement, your cost centre, your job title and job description, your working hours and patterns, whether you are full or part time; your termination/contract end date; the reason for termination; your last day of work; exit interviews, references to be provided to prospective employers, status (active/inactive/terminated); position title; the reason for any change in job and date of change;

4.1.4 Regulatory data: records of your registration with any applicable regulatory authority, your regulated status and any regulatory certificates and references;

4.1.5 Remuneration and benefits data: your remuneration information (including salary/hourly plan/contract pay/fees information as applicable, allowances, overtime, bonus and commission plans), payments for leave/absence (eg holiday pay, sick pay, family leave pay), bank account details, grade, national insurance number, tax information, third party benefit recipient information (eg expression of wish and dependents information), details of any benefits you receive or are eligible for, benefit coverage start date, expense claims and payments, loans, deductions, salary sacrifice arrangements, childcare vouchers, share scheme participation, information and agreements;

4.1.6 Leave data: attendance records, absence records (including dates and categories of leave/time‑off requests and approvals), holiday dates, requests and approvals and information related to family leave (maternity, paternity, adoption, parental, shared parental, dependents), information related to special leave (eg bereavements, jury service, compassionate);

4.1.7 Absence management data: absence history, fit notes, details of incapacity, details of work impact and adjustments, details of treatment and prognosis, manager and HR communications, return to work interviews, meeting records, medical reports, occupational health reports;

4.1.8 Flexible working procedure data: requests, consideration, correspondence, meeting notes and outcome records

4.1.9 Restructuring and redundancy records: change plans, organisation charts, consultation records, selection and redeployment data;

4.1.10 Performance management data: colleague and manager feedback; your appraisals and performance review information, outcomes and objectives; talent programme assessments and records; succession plans; formal and informal performance management process records;

4.1.11 Training and development data: data relating to training and development needs or training received or assessments completed;

4.1.12 Disciplinary and grievance data: allegations, complaints, investigation and proceeding records and outcomes;

4.1.13 Health and safety data: health and safety audits, health and safety screening requests and results, risk assessments, incident reports;

4.1.14 Monitoring data (to the extent permitted by applicable laws): closed circuit television footage, system and building login and access records, keystroke, download and print records, call recordings, data caught by IT security programmes and filters;

4.1.15 Employee claims, complaints and disclosures information: subject matter of employment or contract based litigation and complaints, pre‑claim conciliation, communications, settlement discussions, claim proceeding records, employee involvement in incident reporting and disclosures;

4.1.16 Equality and diversity data: where permitted by law and provided voluntarily, data regarding gender, age, race, nationality, religious belief and sexuality (stored anonymously for equal opportunities monitoring purposes);

4.1.17 Any other persona data which you choose to disclose to Company personnel during the course of your engagement whether verbally or in written form (for example in work emails);

4.1.18 Informal opinion data generated in the course of your engagement relating to the administration or management of the Company’s relationship with you.

4.2 Certain additional information will sometimes be collected where this is necessary and permitted by local applicable laws.

5. Special categories of data

5.1 To the extent permitted by applicable laws the Company collects and processes a limited amount of personal data within the above data listed at 4.1 falling into special categories, sometimes called “sensitive personal data”. This term means information relating to:

5.1.1 racial or ethnic origin;

5.1.2 political opinions;

5.1.3 religious or philosophical beliefs;

5.1.4 physical or mental health (including details of accommodations or adjustments);

5.1.5 trade union membership;

5.1.6 sex life or sexual orientation;

5.1.7 biometric and genetic data; and

5.1.8 criminal records and information regarding criminal offences or proceedings.

 

6. How does the Company collect data?

6.1 The Company collects and records your personal data from a variety of sources, but mainly directly from you. You will usually provide this information directly to your managers or local Human Resources contact or (where applicable) enter it into the relevant systems (where self-service access is available) your participation in HR processes, emails [and instant messages] you send or through verbal information which may be recorded electronically or manually). In addition, further information about you will come from your managers or Human Resources or occasionally your colleagues.

6.2 We also obtain some information from third parties: for example, references from a previous employer, medical reports from external professionals, information from tax authorities, benefit providers or where we employ a third party to carry out a background check (where permitted by applicable law).

6.3 In some circumstances, data will sometimes be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, CCTV, telephone logs and recordings, instant message logs and email and Internet access logs), if and to the extent permitted by applicable laws. In these circumstances, the data may be collected by the Company or a third-party provider of the relevant service. This type of data is generally not accessed on a routine basis but access is possible. Access can occur, for instance, in situations where the Company is investigating possible violations of Company policies such as those relating to travel and expense reimbursement, use of the telephone system and the Internet, or employee conduct generally, or where the data are needed for compliance or billing purposes. More frequent access to such data may occur incidental to an email surveillance program, if and to the extent permitted by applicable laws.

6.4 Where we ask you to provide personal data to us on a mandatory basis, we will inform you of this at the time of collection and in the event that particular information is required by the contract or statute this will be indicated. Failure to provide any mandatory information will mean that we cannot carry out certain HR processes. For example, if you do not provide us with your bank details, we will not be able to pay you. In some cases, it may mean that we are unable to continue with your employment or engagement as the Company will not have the personal data we believe to be necessary for the effective and efficient administration and management of our relationship with you.

6.5 Apart from personal data relating to you, you may also provide the Company with personal data of third parties, notably your dependents and other family members, for purposes of HR administration and management, including the administration of benefits and to contact your next‑of‑kin in an emergency. Before you provide such third party personal data to the Company you must first inform these third parties of any such data which you intend to provide to the Company and of the processing to be carried out by the Company, as detailed in this European Privacy Policy.

7. What are the purposes for which data are processed?

7.1 Your personal data are collected and processed for business purposes, in accordance with applicable laws and any applicable collective bargaining agreements. Data may occasionally be used for purposes not obvious to you where the circumstances warrant such use (eg in investigations or disciplinary proceedings).

7.2 We collect and process your personal data for purposes including:

7.2.1 Recruitment and selection including:

7.2.1.1 To assess your suitability to work for us including short listing, agreements and interviews;

7.2.1.2 to conduct pre‑employment checks including verification of your identity, checking your legal right to work and checking references;

7.2.1.3 to conduct a pre‑employment credit reference check, financial sanction check and a check in relation to suspect criminal activities in order to prevent crime and other unlawful acts and to protect the business and its clients/customers from the risk of dishonesty, malpractice or improper conduct;

7.2.1.4 to compare you with other applicants and make a decision whether to offer you employment;

7.2.1.5 to consider any reasonable adjustments either for the recruitment process or if you were to commence employment with us in the event you have a disability;

7.2.1.6 to make a job offer and provide a contract of employment;

7.2.1.7 to prepare to bring you on board as an employee where you accept an offer of employment from us. In this case we will customise to make sense of the information gathered during recruitment for the purpose of your employment and will transfer some of this to our employment systems and files;

7.2.1.8 to contact you if you are not successful should another potentially suitable vacancy arise during the six months following the completion of the recruitment process for the role you applied for; and

7.2.1.9 to deal with any query, challenge or request for feedback received in relation to our recruitment decision; training, development, promotion, career and succession planning and business contingency planning;

7.2.2 providing and administering remuneration, benefits and incentive schemes and reimbursement of business costs and expenses and making appropriate tax and social security deductions and contributions;

7.2.3 allocating and managing duties and responsibilities and the business activities to which they relate, including business travel;

7.2.4 identifying and communicating effectively with staff;

7.2.5 managing and operating appraisal, conduct, performance, capability, absence and grievance related reviews, allegations, complaints, investigations and processes and other informal and formal HR processes and making related management decisions;

7.2.6 consultations or negotiations with representatives of staff;

7.2.7 conducting surveys for benchmarking and identifying improved ways of working and employee relations and engagement at work (these will often be anonymous but may include profiling data such as age to support analysis of results);

7.2.8 processing information about absence or medical information regarding physical or mental health or condition in order to: assess eligibility for incapacity or permanent disability related remuneration or benefits; determine fitness for work; facilitate a return to work; make adjustments or accommodations to duties or the workplace; make management decisions regarding employment or engagement or continued employment or engagement or redeployment; and conduct related management processes;

7.2.9 for planning, managing and carrying out restructuring or redundancies or other change programmes including appropriate consultation, selection, alternative employment searches and related management decisions;

7.2.10 operating email, IT, internet, social media, HR related and other company policies and procedures. To the extent permitted by applicable laws, the company carries out monitoring of the Company’s IT systems to protect and maintain the integrity of the Company’s IT systems and infrastructure; to ensure compliance with the Company’s IT policies and to locate information through searches where needed for a legitimate business purpose;

7.2.11 satisfying our regulatory obligations to supervise the persons employed or appointed by the Company to conduct business on its behalf, including preventing, detecting and investigating a wide range of activities and behaviours, whether relating to specific business dealings or to the workplace generally and liaising with regulatory authorities;

7.2.12 protecting the private, confidential and proprietary information of the Company, its employees, its clients and third parties;

7.2.13 complying with applicable laws and regulation (for example maternity or parental leave legislation, working time and health and safety legislation, taxation rules, worker consultation requirements, other employment laws and regulation to which the Company is subject in the conduct of its business);

7.2.14 monitoring programmes to ensure equality of opportunity and diversity with regard to personal characteristics protected under applicable anti‑discrimination laws;

7.2.15 planning, due diligence and implementation in relation to a commercial transaction or service transfer involving the Company that impacts on your relationship with the Company for example mergers and acquisitions or a transfer of your employment under applicable automatic transfer rules;

7.2.16 for business operational and reporting documentation such as the preparation of annual reports or tenders for work or client team records including the use of photographic images;

7.2.17 to operate the relationship with third party customer and suppliers including the disclosure of relevant vetting information in line with the appropriate requirements of regulated customers to those customers, contact or professional CV details or photographic images for identification to clients or disclosure of information to data processors for the provision of services to the Company;

7.2.18 where relevant for publishing appropriate internal or external communications or publicity material including via social media in appropriate circumstances;

7.2.19 to support HR administration and management and maintaining and processing general records necessary to manage the employment, worker or other relationship and operate the contract of employment or engagement;

7.2.20 to comply with reference requests where the Company is named by the individual as a referee;

7.2.21 to set and change access permissions;

7.2.22 to provide technical support and maintenance for HR information systems;

7.2.23 to enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you;

7.2.24 to comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country; and

7.2.25 for other purposes permitted by applicable laws, including legitimate interests pursued by the Company where these are not overridden by the interests or fundamental rights and freedoms of staff and where these have been explained to you before the relevant data is collected or the processing is carried out.

7.3 Special categories of data may be collected and processed by the Company for the following purposes:

7.3.1 Documentation such as work permits, details of residency, proof of citizenship will be processed to assess and review eligibility to work for the Company in the jurisdiction in which you work;

7.3.2 your racial or ethnic origin, religion, philosophical or political belief, sexual orientation or disability status may be used for the collection of statistical data subject to local laws, or where required to record such characteristics to comply with equality and diversity requirements of applicable local legislation or to keep the Company’s commitment to equal opportunity under review;

7.3.3 health and medical information may be used to comply with employment, health and safety or social security laws. For example to provide statutory incapacity or maternity benefits, avoid breaching legal duties to you, to ensure fair and lawful management of your employment, avoid unlawful termination of your employment, to administer the Company’s private medical and long term disability schemes, to make reasonable accommodations or adjustments and avoid unlawful discrimination or dealing with complaints arising in this regard;

7.3.4 trade union membership may be recorded to ensure that you receive any relevant rights that you may have in connection with any Trade Union membership, as required to enable us to meet our obligations under employment law, or in order to operate trade union subscription check off at your request;

7.3.5 information regarding your racial or ethnic origin, religion, philosophical or political belief, sexual orientation, sexual life and sexual orientation may be used in the event of a complaint under the Company’s grievance, whistleblowing, anti‑bullying and harassment or similar policies where such characteristics or information are relevant to the particular complaint, in order to comply with employment law obligations.

8. Legal bases for processing

8.1 Personal data

8.1.1 Whenever the Company processes your personal data we do so on the basis of a lawful condition for processing. Processing of special categories of data is always justified on the basis of an additional lawful condition.

8.1.2 In the majority of cases, the processing of your personal data will be justified on one of the following bases:

8.1.2.1 The processing is necessary for compliance with a legal obligation to which the Company is subject (for example, disclosing the information to HMRC, making statutory payments, avoiding unlawful termination, avoiding unlawful discrimination, meeting statutory record keeping requirements or health and safety obligations); or

8.1.2.2 Where there is no legal obligation we will process your data where the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract (for example collecting bank details to pay your salary or processing information to provide you with the contractual benefits you are entitled to).

8.1.2.3 Where the above two grounds at 8.1.2.1 or 8.1.2.2 do not apply we may process your personal data where the processing is necessary for the legitimate interests pursued by the Company (being those purposes described in the section above), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (for example reviewing your performance at work).

8.1.3 We will on occasion process your personal data for the purpose of legitimate interests pursued by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

8.1.4 In exceptional circumstances where we have no legitimate interest in processing but you ask us to process data for a particular purpose we will occasionally carry out the processing on the basis of your consent (for example if you ask us to provide pay information to a bank for a mortgage application made by you). Where we rely on your consent we will make this clear at the time.

8.2 Special categories of data

8.2.1 The special categories of personal data that may be processed by the Company are set out in this European Privacy Policy. Where we process special categories of data it will be justified by a condition set out at [8.1.2] above and also by one of the following additional conditions:

8.2.1.1 The processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or the Company in the field of employment law, social security and social protection law, to the extent permissible under applicable laws;

8.2.1.2 The processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, to the extent permitted by applicable laws;

8.2.1.3 The processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional emergency situations, such as a medical emergency);

8.2.1.4 The processing is necessary for purposes authorised by applicable law.

8.2.1.5 The processing is necessary for the establishment, exercise or defence of legal claims; or

8.2.1.6 In exceptional circumstances the processing is carried out subject to your explicit consent (as explained below).

8.2.2 We will occasionally seek your consent to certain processing which is not otherwise justified under one of the above bases. If consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and explicit. Information regarding such processing will be provided to you at the time that consent is requested, along with the impact of not providing any such consent. You should be aware that it is not a condition or requirement of your employment to agree to any request for consent from the Company.

8.3 Processing data relating to criminal convictions and offences

• Personal data relating to criminal convictions and offences will only be processed where authorised by applicable laws. For example:

8.3.1 a criminal record check may be carried out on recruitment or transfer or intermittently where ongoing screening is required where authorised by applicable laws; or

8.3.2 an allegation of a criminal offence or conviction arising during your relationship with the Company may be processed where required or authorised by applicable law. For example:

8.3.2.1 where we have a legal or regulatory requirement to report an offence; or

8.3.2.2 where applicable laws authorise the Company to process information about the offence (e.g. in a disciplinary process) for the purpose of making decisions regarding your relationship with the Company.

9. automated decision making and profiling

Unless written notice is provided on the contrary, no automated decision making or profiling is undertaken on your personal data.

10. Retention of personal data

10.1 The Company endeavours to ensure that personal data are kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable.

10.2 The Company’s general approach is to only retain personal data for as long as is required to satisfy the purpose for which it was collected by us or provided by you. This will usually be the period of your employment/contract with us plus the length of any applicable statutory limitation period following your departure, although some data, such as pension information, may need to be kept for longer. We may keep some specific types of data, for example, tax records, for different periods of time, as required by applicable law. However, some personal data may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

11. Disclosures of personal data

11.1 Within the Company, your personal data can be accessed by or will be disclosed internally on a need‑to‑know basis to:

11.1.1 local, regional and global Human Resources, including managers and team members;

11.1.2 local, regional and executive management responsible for managing or making decisions in connection with your relationship with the Company or when involved in an HR process concerning your relationship with the Company (including, without limitation, staff from Compliance, Legal, Employee Relations and Information Security);

11.1.3 system administrators; and

11.1.4 where necessary for the performance of specific tasks or system maintenance by staff in the Company teams such as the Finance and IT Department and the Global HR information systems support team.

11.2 Certain basic personal data, such as your name, location, job title, contact information, employee number and any published skills and experience profile may also be accessible to other employees. The security measures in place within the Company to protect your data are set out below.

11.3 Your personal data will be accessed by third parties whom we work together with (including without limitation, with Hire Right (background checking) and Cornerstone (application management) and their associated companies and sub‑contractors) for providing us with services, such as hosting, supporting and maintaining the framework of our HR information systems.

11.4 Personal data will also be shared with certain interconnecting systems and local payroll and benefits systems. Data contained in such systems may be accessible by providers of those systems, their associated companies and sub‑contractors.

11.5 Examples of third parties with whom your data will be shared include tax authorities, regulatory authorities, the Company’s insurers, bankers, IT administrators, lawyers, auditors, investors, consultants and other professional advisors, payroll providers, and administrators of the Company’s benefits programs. The Company expects such third parties to process any data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security.

11.6 Where these third parties act as a “data processor” (for example a payroll provider) they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes. In this case your personal data will only be disclosed to these parties to the extent necessary to provide the required services.

11.7 In addition, we may share personal data with national authorities in order to comply with a legal obligation to which we are subject. This is for example the case in the framework of imminent or pending legal proceedings or a statutory audit.

12. Security of data

12.1 The Company is committed to protecting the security of the personal data you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk. The Company uses a variety of technical and organisational methods to secure your personal data in accordance with applicable laws.

12.2 If you are in possession of personal data of any kind (e.g. data collected in emails, address books, Excel spreadsheets or contained in curricula vitae or elsewhere) you must ensure that the data are kept in a safe place where unauthorised access cannot occur. Where data is retained in hard copy, storage in a locked drawer or cabinet, accessible only to authorised individuals, is generally the most effective means of securing the data. Where data is kept in electronic form, appropriate password protection and appropriately secured areas should be used.

12.3 You should not create, copy or export personal data relating to any other person outside of official company storage locations and systems except where necessary for a specific authorised and lawful purpose under this European Privacy Policy. In this event appropriate measures must be taken to protect the confidentiality and integrity of the data during the processing. Once the relevant processing is complete, steps should be taken to store or return the relevant data within the official storage locations/systems with all less formally held records (e.g. local folders, hard copies, emails saved outside of formal manged folders) securely erased.

13. INTERNATIONAL Transfer of Personal Data

13.1 From time to time your personal data (including special categories of personal data) will be transferred to TNS Group associated companies to process for the purposes described in this European Privacy Policy. This will be applicable for example where the relevant company or a manager from that company is responsible for conducting or approving the relevant process or the data is part of a global directory where other individuals need to have access.

13.2 Personal data may also be transferred to third parties (e.g. service providers or regulators as set out above), who may have systems or suppliers located outside the European Union.

13.3 As a result, in some circumstances your personal data will be transferred to countries outside of the country in which you work or outside of the European Union to countries whose data protection laws may be less stringent than yours.

13.4 The Company will ensure that appropriate or suitable safeguards are in place to protect your personal information and that transfer of your personal information is in compliance with applicable data protection laws.

13.5 Where required by applicable data protection laws, the Company has ensured that service providers (including other Company associated companies) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant Company exporter. You can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal data by contacting HR-EU@tnsi.com.

13.6 TNS Group has an intra‑group data transfer agreement in place which regulates cross‑border transfers of your data within the Group.

13.7 You have a right to request a copy of any data transfer agreement under which your personal data is transferred, or to otherwise have access to the safeguards used. Any data transfer agreement made available to you may be redacted for reasons of commercial sensitivity.

14. Your rights as a data subject

14.1 Right to access, correct and delete your personal data

14.1.1 The Company aims to ensure that all personal data are correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address and bank accounts) are notified to the Company so that we can ensure that your data is up‑to‑date.

14.1.2 You have the right to request access to any of your personal data that the Company may hold, and to request correction of any inaccurate data relating to you. You furthermore have the right to request deletion of any irrelevant data we hold about you. Please send an email to privacy@tnsi.com.

14.1.3 To correct/update certain information (such as your address or bank details), you will need to contact local Human Resources at HR-EU@tnsi.com

14.2 Data portability

• Where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to the Company in a structured, commonly used and machine‑readable format, and also to require us to transmit it to another controller where this is technically feasible.

14.3 Right to restriction of processing:

• You have the right to restrict our processing of your personal data where:

14.3.1 you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;

14.3.2 where the processing is unlawful but you do not want us to erase the data;

14.3.3 where we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or

14.3.4 where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether the Company has compelling legitimate grounds to continue processing.

• Where personal data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

14.4 Right to withdraw consent

• Where we have relied on your consent to process particular information and you have provided us with your consent to process data, you have the right to withdraw such consent at any time. You can do this by (i) in some cases deleting the relevant data from the relevant HR system (although note that in this case it may remain in back‑ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting your local Human Resources contact. It will only however be rarely that we rely on your consent to process personal data for your employment or engagement.

14.5 Right to object to processing justified on legitimate interest grounds

• Where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

14.6 Right to complain

• You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law.

14.7 For further information regarding your rights, or to exercise any of your rights, please contact your Data Protection Officer by email at privacy@tnsi.com or your local Human Resources at HR-EU@tnsi.com

TNS Job Applicant Privacy Policy – Rest of World

Updated 15 October 2020

DEFINITIONS

In this document:

• “Personal Data” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
• “Job Applicant Privacy Policy” means the current version of this TNS Job Applicant Privacy Policy.
• “We” or “TNS” means Transaction Network Services, Inc., a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA. TNS has offices in various regions of the world. Please check our websites for more information on our office locations.
• “You” means the person who is applying for a job on our websites.

PRIVACY COMMITMENT

We are committed to respecting your personal privacy, to processing your Personal Data in accordance with your consent, and to protecting any Personal Data that we have collected from you. This Job Applicant Privacy Policy is intended to describe processes for collecting, distributing, and protecting Personal Data, as well as your rights with regards to your Personal Data, specifically in connection with your application for a job through our websites. On our websites, you will be required to indicate that you have read and agree with this Job Applicant Privacy Policy before you will be allowed to apply for a job with us.

If you are a resident of Europe, the Asia-Pacific Region, or the USA, please see our websites for the Job Applicant Privacy Policy specific to your region. This Privacy Policy is intended to apply to those persons who are residents of other parts of the world.

TYPES OF PERSONAL DATA COLLECTED

In connection with your application for a job with us, Personal Data collected by us includes information that you voluntarily submit to us, and may include the following:

• Biographical Information: This includes information you provide to us about yourself, including your name, alias(es), former name(s), gender, date of birth, email address, mobile telephone number, home telephone number, address(es), protected classification(s), language proficiencies, and other information required to determine your eligibility and suitability for a job with us, as well as information about you provided to us by your current or former employers, educational institutions, and co-workers.
• Educational Information: This includes information you provide about educational history, such as the names, places, and dates of attendance and graduation of your schools, trade schools, colleges, and universities, as well as the certificates, diplomas, and degrees awarded, as well as information provided to us by your current or former educational institutions.
• Professional Information: This includes information you provide about your employment history, such as the names, places, and dates of former or current employers, the positions you held, professional qualifications (such as licenses, permits, certifications, and memberships relevant to your work history), as well as information provided to us by your current or former employers and co-workers.
• Job Preference Information: This includes information you provide about the geographical locations, positions, and compensation you seek, as well as your willingness to relocate.
• Interview Information: This includes information you provide to us (whether in person, over the phone, in a virtual meeting, on paper, or otherwise) in the process of our interviewing you for a position with us.
• Other Information: This may include any additional information which you voluntarily provide to us, or make available to us through a third party, in the process of your application for a job with us.

COLLECTION OF PERSONAL DATA

Providing Personal Data to us in connection with your application for a job with us is voluntary. However, if you do not provide us with certain information, or do not provide sufficiently detailed information, we may be unable to consider you for a job with us.

To the extent you voluntarily provide us with your Personal Data in connection with your application for a job with us, or make such Personal Data available to us through a third party, we may collect such Personal Data in the following ways:

• Personal Data You Provide: You may give us your Personal Data (as described above) when you contact us to inquire about available jobs; when you apply for a job with us (whether on our websites, via mail, via email, or otherwise); and/or when you interview with us.
• Personal Data Received from Third Parties: We may receive information about you from third parties, including current or former employers, current or former educational institutions, and current or former co-workers.

USE AND SHARING OF PERSONAL DATA

We may use your Personal Data in several ways, including the following:

• Screening, Recruiting, and Hiring Applicants: We may use your Personal Data to evaluate your eligibility and suitability for one or more positions with us; to schedule and conduct interviews with you; to communicate with you regarding your job application(s); to satisfy our legal obligations (including, for example, our obligations under Equal Opportunity Employment laws); to evaluate and improve our recruiting process; and for routine business purposes.
• Sale of Personal Data: TNS does not sell any Personal Data collected in the job application process.

RETENTION OF PERSONAL DATA

At the time we collect your Personal Data in connection with your application for a job with us, we may store such Personal Data for the purposes of evaluating your eligibility and suitability for one or more positions with us. In addition, after the job application process, we may continue to store such Personal Data for the purposes of evaluating your eligibility and suitability for future positions with us. We may also retain certain information obtained from your Personal Data where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you, for the purposes of evaluating and improving our recruiting process.

PROTECTION OF PERSONAL DATA

We take precautions to protect the Personal Data we collect and store. All of our employees, as well as all of our service providers who have access to Personal Data, are obligated to protect it and keep it confidential. However, no system or electronic data transmission is completely secure. If you give us your Personal Data, you do so at your own risk. We expect that you will use appropriate security measures to protect your Personal Data.

CONTACT INFORMATON REGARDING PRIVACY

• Contacting Us: You may contact us at any time if you have any questions about this Job Applicant Privacy Policy, to exercise your rights regarding your Personal Data, to file a complaint regarding how we process your Personal Data, or for any privacy-related queries. Please direct all queries and questions regarding privacy to our Data Protection Officer at the following email address: privacy@tnsi.com
• Contacting a Privacy Regulator: If you are not satisfied with our response, you can contact the relevant privacy regulator or agency in your region.

JOB APPLICANT PRIVACY POLICY UPDATES

This Job Applicant Privacy Policy is periodically reviewed and updated. The date of the last update to this Job Applicant Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice.