Job Applicant Privacy Notice
LAST UPDATED: JULY 2021
CSG Systems International Inc. and its affiliates (EU/EEA/UK applicants, please see list of EU and UK employers in Annex A) (collectively, “CSG” or “We”) 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.
This notice (“Notice”) explains how CSG collects, uses, and processes the personal information of job applicants. For EU/EEA/UK applicants, a list of CSG entities in the EU and/or the UK 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 information:
- 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 EU and/or UK data protection law 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.
For EU/EEA/UK Applicants Only
CSG will rely on the following legal grounds 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 permitted by EU or local data protection law or by a collective agreement;
- 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.
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.
For EU/EEA/UK Applicants Only
Under EU and/or UK data protection laws, there are various grounds on which We can rely when processing Your personal data. In some contexts more than one ground applies. CSG relies on the following legal grounds for the collection and processing of personal data:
- In order to take steps to enter into the employment contract with You;
- Legitimate interest of CSG, CSG’s affiliates or other third parties (such as existing or potential business partners, vendors, customers, governmental bodies, or courts) where the legitimate interest could be in particular:
- Implementation and operation of a group-wide matrix structure and group-wide information sharing
- Prevention of fraud, misuse of CSG IT system, or money laundering
- Operation of a whistleblowing/compliance hotline
- Addressing physical security, IT and network security
- Conducting internal investigations
- Compliance with legal obligations, in particular in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.
If We process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, We will make sure that one of the grounds for processing sensitive personal data applies, including (for example) that the processing is for equality and diversity purposes to the extent permitted by law.
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 “How to Contact Us” section below. This will not however affect the lawfulness of the processing before Your consent has been withdrawn.
Recipients of Personal Information
CSG takes care to allow access to personal information 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 information, 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 information is maintained.
- We share Your personal information 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 information available to third parties who provide services to us. We do so on a “need to know basis” and in accordance with applicable data protection law. For example, some personal information will be available to our employee benefit plans service providers and other third parties who provide us with services such as: job application administration, recruitment or executive search administration, background check administration.
- We make certain personal information 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 information 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 information, 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, You can choose for us to keep Your information on file for any future job openings. In such cases, We will retain Your application information for one year. You can opt out of this at any time.
Transfers of Your Personal information
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 information 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 export Your personal information to a different country, We will take necessary steps to ensure that such data exports comply with applicable laws and legislation. For example, for transfers of personal information from the European Economic Area (“EEA”) or the United Kingdom (“UK”) to other affiliates within the CSG group of companies located outside of the EEA or the UK, We have an intra-group agreement which includes appropriate safeguards.
Where applicable, when We transfer Your personal information to third parties outside of the EEA or the UK, We ensure that such transfers to countries not providing an adequate level of data protection are based on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission together with binding and enforceable commitments of the recipient.
You can request a copy of the appropriate safeguards by contacting us as set out in the Questions and Comments section below.
In addition, CSG Systems International, Inc, CSG Systems, Inc., and Intec Billing, Inc., (collectively, “CSG US”) each continue to comply with its respective obligations and commitments under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce. The entities listed in our Privacy Shield record can be found here. CSG US no longer relies on the Privacy Shield as a lawful mechanism to transfer Your personal information.
This Privacy Notice includes details of third parties CSG US shares Your personal information 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 (EU/EEA/UK Applicants Only)
You have data protection rights provided under applicable laws (“Data Subject Rights”), which You may exercise by making a request to CSG.
- If You wish to access, correct, update or request deletion of Your personal information, You can do so at any time by contacting us by contacting us here.
- In addition, You can object to processing of Your personal information, ask us to restrict processing of Your personal information or request portability of Your personal information. Again, You can exercise these rights by contacting us here.
- We are unlikely to rely on consent as a ground for processing. However, if We do, You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of Your personal information. For more information, please contact Your local data protection authority. (Contact details for data protection authorities in the EU are available here.)
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 appropriate data protection supervisory authority 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 THE EU/EEA/UK
Independent Technology Systems Limited
100 New Bridge Street
Volubill Danmark Aps
TMF Denmark A/S
Bredgade 6, 1st, 1260 Copenhagen K, Denmark
Söder Mälarstrand 29 11825
Intec Billing Ireland Ltd
IDA Business Park Dangan
Co. Galway, H91 A06C
Intec Telecom Systems (France) SARL
34 avenue des Champs Elysées
Independent Technology Systems SL Unlpersonal
198 Calle Aribau
Intec Telecom Systems Deutschland GmbH49AA
Intec Telecom Systems Italia Spa
Via Monte di Pietà
21 – 20121 Milan
Desingen Commicaco Visual, Lda.
Avenida da Liberdade
6153º Andar, Sala 10
Tango Telecom Ltd.
Walton House, Lonsdal Road
National Technology Park
Kitewheel UK Limited
100 New Bridge Street