Applicant Privacy Notice

This notice explains:

• What information we collect during our application and recruitment process and why we collect it;
• How we use that information; and
• How to access and update that information.

Types of information we collect
This notice covers the information you share with us and/or which may be acquired or produced by VSP Vision (VSP), its subsidiaries and its affiliates during the application or recruitment process including:

• Your name, address, email address, telephone number and other contact information;
• Your resume or Curriculum Vitae, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
• Information from interviews and phone-screenings you may have, if any;
• Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
• Details of how you heard about the position you are applying for;
• Any sensitive and/or demographic information obtained during the application or recruitment process such as but not limited to gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin;
• Reference information and/or information received from background checks (where applicable), including information provided by third parties;
• Information relating to any previous applications you may have made to VSP for which you authorized VSP to retain those records for future reference and/or any previous employment history with VSP;
• Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile);
• Information related to any assessment you may take as part of the interview screening process; and/or
• If you receive contingent offer of employment, information related to government identification (such as Social Security Number or Tax Identification Number) and date of birth.

How we use information we collect
Your information will be used by VSP for the purposes of carrying out its application and recruitment process which includes:

• Assessing your skills, qualifications and interests against our career opportunities;
• Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at VSP;
• Creating and/or submitting reports as required under any jurisdictional laws and/or regulations, where applicable;
• Where requested by you, assisting you with obtaining an immigration visa or work permit where required;
• Making improvements to VSP’s application and/or recruitment process including improving diversity in recruitment practices; and/or
• Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or
• Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

We will also use your information to protect the rights and property of VSP, our users, applicants, candidates, employees or the public as required or permitted by law.

If you are offered and accept employment with VSP, the information collected during the application and recruitment process will become part of your employment record and will be processed in accordance with the VSP Vision employee privacy policy.

Our legal basis for processing your information
We collect and process your information where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you or otherwise extending a contingent offer to you.

We may also seek your consent to process your personal information in specific cases (e.g., should we wish to keep your information on file for future positions), or process it where necessary to comply with a legal obligation, or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates; however, we will use anonymized data where possible or otherwise minimize the use of your information to what is absolutely required for this purpose.

Who may have access to your information
Your information may be shared with our affiliates or subsidiaries in the US and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at VSP by a current VSP employee, with your consent, we may inform that employee about the progress of your application and let the VSP employee know the outcome of the process.

VSP may also use service providers acting on VSP’s behalf to perform some of the services described above, including for the purposes of the verification / background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.

VSP may sometimes be required to disclose your information to external third parties such as to local labor or tax authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.

VSP operates globally, which means your information may be stored and processed in the United State (US) where the company is headquartered. When we share your information with VSP in the U.S., we rely on standard contractual clauses (“model clauses”) adopted by the European Commission to offer appropriate safeguards to protect your information when it is being transferred outside the European Economic Area. Should you wish to obtain a copy of the model clauses, you may contact us at gdpr@vsp.com. VSP reserves the right to share with you a redacted version of the model clauses.

Our retention of your information
If you apply for a job at VSP and your application is unsuccessful (or you withdraw from the process or decline our offer), VSP will retain your information for a limited period after your application submittal. We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision, to consider you for other current or future jobs at VSP, and to help us better understand, analyze and improve our recruitment processes.

If you do not want VSP to retain your information for consideration for other roles, or want VSP to update it, please contact our support team here. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

Your rights in respect of your information
In certain countries, you may have certain rights under data protection law. This may include the right to request access or to update your information, request that it be deleted, or object to VSP using it for certain purposes.

If you wish to exercise a right of access, please contact our support team here. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request.

If you are in the European Union and if you can’t find the answer to your question in this notice, you can contact VSP’s Data Protection Officer at: gdpr@vsp.com. Depending on your country of residence, you may also raise any questions or concerns you have regarding your personal information with your local data protection authority.

Changes to this Notice
We may change this notice from time to time. We will post any changes to this notice on this page. Each version of this notice is identified at the top of the page by its effective date.

Created, May 25, 2021