Brazil Job Applicant Privacy Notice
Last updated: August 2022
CSG Systems International Inc. and its affiliates (Brazilian applicants, please see list of Brazilian employers in Annex A (“CSG”) care about the privacy of our job applicants (“You” or “Your”) during the recruitment and application process. CSG is committed to processing Your individually identifiable information (“personal information”) in accordance with fair information practices and applicable data protection and privacy laws, including the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, “LGPD”).
This notice (“Notice”) explains how CSG collects, uses, and processes the personal data of job applicants. For Brazilian applicants, a list of CSG entities in Brazil who may be the prospective employer for the position for which You are applying is at Annex A CSG may amend this Notice from time to time, should it become necessary to do so. This Notice may also be supplemented by other statements, as needed, to comply with local requirements in the country where You live.
COLLECTION AND USE OF PERSONAL INFORMATION
Types of Personal Information We Collect About Job Applicants
In the normal course of the recruitment and application process, We may collect the following types of personal data:
- Personal Details: Name; birth date; national identification number; education and qualification details; professional work details; and passwords;
- Contact details: E-mail address; telephone number(s); and home address; and
- Qualifications and Talent Management Information: Details contained in letters of application and resume/CV; previous employment or work background; education history; professional qualifications; background check reports; and language and other relevant skills.
There may also be situations where we collect information that reveals information about Your health, which is considered by the LGPD as “sensitive personal data”. For example, You may need to provide us with information about Your physical or mental condition so that we can provide work-related accommodations or to assess Your fitness for a particular position.
Legal Basis for Processing Sensitive Personal Data
CSG will rely on the following legal basis for the collection and processing of sensitive personal data:
- Express consent, as permitted by local data protection law;
- Carrying out the obligations and exercising the specific rights of CSG or You in the field of employment and social security and social protection law as required by Brazilian legislation or by a collective agreement;
- For the regular exercise of rights, including in a contract and in a judicial, administrative and arbitration procedure. This includes data processing for the performance of a contract or preliminary procedures of a contract. For the purposes of this notice, said contract is the employment contract;
- Establishing, exercising, or defending legal claims or as required whenever courts are acting in their judicial capacity; and
- For assessment of Your working capacity, as permitted by local data protection law.
The provision of personal information as described in this Notice is partly a statutory requirement and partly a requirement necessary in order to carry out the potential employment relationship with You. In general, You are required to provide the personal information, except in limited instances when we indicate that the provision of certain information is voluntary. Not providing personal information may prevent CSG from carrying out the potential employment relationship with You.
If You are accepted for a job at CSG, the information collected during the recruitment process will form part of Your ongoing employment record. You will be asked to provide additional information at the time in accordance with our applicable Data Privacy Notice.
If CSG is relying on Your consent to process Your personal data, You have the right to withdraw Your consent at any time by contacting us as described in the Questions and Comments section below. This will not however affect the lawfulness of the processing before Your consent has been withdrawn.
Sources of Personal information
Usually You will have provided the information we hold about You but there may be situations where we collect personal information from other sources, such as references supplied by former employers and background check reports. We will seek this information only after the job offer has been made and we will inform You that we are seeking this information from other sources.
Purposes for Processing Personal Data and Legal Basis
CSG may collect and use Your personal data for the following purposes:
- Management and Administration of Job Applicants: Strategic planning; making business travel arrangements; maintaining records relating to business activities; budgeting, financial management and reporting; communications; and monitoring activities if and as permitted by applicable law (including the monitoring telephone, email, Internet and other resources within the CSG group of companies);
- Planning and Allocating Work: Allocating assets and human resources within the CSG group of companies;
- Human Resources Management: Managing and administering the job application process; and operating and managing the IT and communications systems; and
- Compliance: Complying with applicable legal and other requirements, such as recordkeeping and reporting obligations; conducting audits; administration of the CSG compliance hotline; compliance with law enforcement and similar requests in accordance with applicable law; pursuing legal rights and remedies; defending litigation and managing any internal complaints or claims; and complying with internal policies and procedures.
Sharing of Your Personal Data with Third Parties
CSG takes care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever CSG permits a third party to access personal data, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the confidentiality and integrity of the data is maintained.
- We share Your personal data with other members of the CSG group around the world for the purposes described above, in particular to manage and administer the job application process.
- We make certain personal data available to third parties who provide services to us. We do so on a “need to know basis” and in accordance with the LGPD and applicable data protection law. For example, some personal data will be available to our employee benefit plans service providers and other third parties who provide us with services related to the application process, such as: job application administration, recruitment or executive search administration, background check administration.
- We make certain personal data available to existing or potential business partners, suppliers, independent external advisors (such as auditors), banks, insurance carriers, and other third parties to operate the business.
Data Retention Periods
Personal data will be stored only as long as is necessary to carry out the purposes described in this Notice or as otherwise required by contractual agreements with third parties, law or other CSG policies. When CSG no longer needs to use Your personal data, we will remove it from our systems and records and/or take steps to properly render it unintelligible so that You can no longer be identified from it.
If You are not successful with Your job application, You can choose for us to keep Your data on file for any future job openings. In such cases, we will retain Your application data for one year. You can opt out of this at any time.
Transfers of Your Personal Data
CSG is a global group of companies headquartered in the United States. As CSG operates at a global level, we may need to transfer personal data to other countries outside of Your home country, in particular to our parent company for management purposes. Transfers may also need to be made to other countries where we operate in order to communicate with Your potential manager or other staff members regarding Your potential employment relationship with CSG.
When we transfer Your personal data to a different country, we will take necessary steps to ensure that such data transfers comply with applicable laws and legislation, especially with regard to the international data transfer mechanisms set out by the LGPD.
You can request a copy of the appropriate safeguards by contacting us as set out in the Questions and Comments section below.
This Privacy Notice includes details of third parties CSG US shares your personal data with under Recipients of Personal Information. You can find out more about your rights under the Your Data Protection Rights section below.
For further information, which is not contained in this Privacy Notice, please contact us using the details under Questions and Answers below.
Your Data Protection Rights (Applicants in Brazil Only)
You have data protection rights provided under applicable laws (“Data Subject Rights”), which You may exercise by making a request to CSG through the e-mail provided in the section “Questions and Comments” below. As a data subject, You have the following rights:
(i) to obtain confirmation as to whether or not we process Your personal data;
(ii) to access Your personal data;
(iii) to rectify incomplete, inaccurate or outdated data;
(iv) to have unnecessary, excessive or noncompliant personal data anonymized, blocked or erased;
(v) data portability;
(vi) to have personal data processed under the Your consent erased — please note, however, that we almost never use “consent” as a legal basis for processing Your personal data;
(vii) to be informed about third parties with which their data has been shared;
(viii) to be informed about the possibility to refuse providing personal data and the corresponding consequences;
(ix) to withdraw Your consent, when applicable; and
(x) to request a review of automated decisions that affect their interest and were solely based on automated processing of their personal data (the review does not need to be necessarily made by a natural person).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Before responding to those requests, however, You may be asked to provide information and/or documentation that allow Us to verify Your identity. That information will be used solely for identity verification purposes and will be promptly deleted once this is done.
You may learn more about these rights or exercise these rights by going to the CSG Data Rights Request Portal or by contacting us as set out in the Questions and Comments section below. Please note that these rights might be limited under the national data protection law in Your home country.
Updates to This Notice
This Notice may be updated periodically to reflect any necessary changes in our privacy practices. Where such changes will materially affect Your privacy rights, we will inform You through the job application portal and indicate at the top of the Notice when it was most recently updated. We encourage You to check back on this Notice periodically so that You are aware of the most recent version of it.
Questions and Comments
You can address any questions or comments relating to this Notice and our privacy practices to [email protected] You have a right to lodge any complaints with the Brazilian Data Protection Authority (ANPD) although we ask that You raise Your objections directly with CSG in the first instance.
ANNEX A – LIST OF CSG EMPLOYERS AND CONTRACTING ENTITIES IN BRAZIL
Intec Telecom Systems do Brasil Ltda
Rua Doutor Rafael de Barros
209, 6th and 7th floors
São Paulo- SP
Intec Telecom Systems do Brasil Ltda
Av. Higienopolis 1601, 2fl