Last Updated: February 2023
Scope and Overview
Schvey, Inc. d/b/a Axoni and its affiliates (“Axoni”, “we”, or “us”) are committed to protecting the privacy and security of your personal information. This Privacy Notice describes how Axoni collects and processes personal information about you before, during, and after your employment. This Privacy Notice applies to current and former employees, contractors, and candidates in all jurisdictions (“you”).
This Privacy Notice describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information. This Privacy Notice also describes your rights regarding the personal information that we hold. This notice does not form part of any contract of employment or other contract to provide services.
Data collection is limited to what is relevant and needed for legitimate purposes. Information is stored only as long as needed to fulfill necessary business obligations. It is held confidentially and Axoni takes the necessary steps to protect your personal information against unauthorized processing or accidental loss or damage.
We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law.
Types of Personal Information We Collect
Personal information is any identifiable information that can be linked to your person. Anonymous or de-identified personal information will not be held and processed. The data we collect for employees is more extensive than for candidates as listed below.
Disclosure of your personal information is optional. If you do not provide us with this information, we cannot move forward with the hiring process. This information includes but is not limited to:
- Full name, email, phone number
- Social Media accounts (optional)
- Current and Future Sponsorship Status
- Resume /CV
All information provided in the initial candidate profile is retained. In addition, employees are required to disclose further information. Disclosure of some kinds of personal information is optional. However, if such optional information is not provided to us, we may not be able to provide you with the benefits and services corresponding to the requested optional information. Personal information we collect for employees includes, but is not limited to:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Demographic information: date of birth, gender, race, ethnicity, pronouns (optional), and marital and dependent status (only when needed for tax purposes and to administer benefits such as health insurance and retirement plans)
- Beneficiary and emergency contact information
- Government identification numbers and images
- Financial information: bank account details and payroll information, wage and benefit information, and compensation history at Axoni
- Employment information: performance information, insurance enrollment information, start date and end date, job title, and location of employment
- Education and training
- Employment records: work history and proof of work eligibility
- Other information: photograph, background checks, drug tests, and signature
- Background checks
- Drug test
- Clothing size for company swag purposes
- Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to an Axoni office location
- In case of COVID 19 or pandemic related surges, employees may be subjected but not limited to self-check, temperature checks, and other necessary measures
- Doctor’s note if medical leave of absence is requested
Background checks are conducted on every Axoni employee.
U.S. employee background check includes:
- Drug Screening – 4-Panel
- Domestic Watch List Search
- Social Security Number Trace
- Nationwide Criminal Databases Search
- Sex Offender Check
- County Criminal Court Search
- Education Verification
- Employment Verification
U.K. employee background check includes:
- Global Sanction Search
- National ID Verification
- Criminal Record Search (includes Sex Offender Check & Criminal Court Search)
- Education Verification
- Employment Verification
- Right to Work check
Depending on the contracting arrangements we have with your employer or with you directly, we may collect the types of information necessary to administer the arrangement with you or as required by contract or law.
Use of Personal Information
Axoni uses your personal information to serve and support our employment relationship or services contract with you, comply with our obligations under employment laws and related civil rights, health, and safety laws, to protect your vital interests, and to abide by any legal regulations applicable to Axoni. Some but not all of Axoni’s potential uses of your personal information are outlined below.
- Conducting performance reviews and determining performance requirements
- Assessing qualifications for a particular job or task
- Gathering evidence for disciplinary action or termination
- Complying with applicable law
- Providing education, training, and development
- Administering healthcare services
- Complying with health and safety obligations
- Preventing fraud
- Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution
- Supporting internal administration with our affiliated entities
- Sharing information internally for employee social engagement
- Benchmarking compensation and benefits
- Conducting data analytics to review and better understand employee retention and attrition rates
We will not use your personal information for purposes other than that for which it was collected, unless we reasonably consider that this is required, and the reason is compatible with the original purpose. If we need to use it for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. If we need to use your personal information for a reason not listed above, we will give you notice prior to the use and explain the legal basis which allows us to do so. We may use and process your data without your consent when required by law. If your information is being used for Axoni’s legitimate interests, those interests need to be identified prior to use.
We will only disclose your personal information to third parties where required by law and to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the employment relationship with you. Third-party service providers may include, but are not limited to, payroll processors, benefits administration providers, and data storage or hosting providers. These third-party service providers may be located outside of your home jurisdiction.
We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us as your employer. We do not permit our third-party service providers who process your personal information on our behalf to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.
To ensure that your personal data has the same protection as under the GDPR, we have in place an appropriate data transfer agreement with all group entities outside of the UK and EEA with whom we share your personal data.
Your information may be shared internally, including with members of the People and recruitment teams (including payroll), your department manager, managers in the business area in which you work, and IT staff if access to the data is necessary for performance of their roles.
We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you
- As part of our regular reporting activities to other members of our group of companies
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders; when we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances
- To protect the rights and property of Axoni
- During emergency situations or where necessary to protect the safety of persons
- If the personal information is publicly available
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction; in these circumstances, we will limit data sharing to what is necessary, and we will anonymize the data where possible
- Sharing de-identified data for compensation and benefits benchmarking
- For additional purposes with your consent where such consent is required by law
We have implemented appropriate security measures designed to secure your personal information against accidental loss and unauthorized access. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
For How Long Does Axoni Keep Data?
We will only retain your personal information for as long as is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Personal information you submit to us as a candidate is retained for ten years (or longer, if the recruitment process is still ongoing) and then de-identified shortly thereafter.
If you are an Axoni employee or contractor, Axoni will hold your personal data at least for the duration of your employment or services contract. However, to determine the specific appropriate retention period for personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of hazard from unauthorized use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. The retention periods which we have determined are laid out in the Axoni Data Classification and Retention Policy.
Changes to This Privacy Notice
We reserve the right to update this Privacy Notice at any time. If we would like to use your previously collected personal information for purposes other than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose.
EU/EEA and UK Rights
Axoni is committed to being transparent about how it collects and uses personal data and to meeting its data protection obligations in its capacity as a ‘data controller’ in accordance with the Data Protection Act 2018 (DPA), the General Data Protection Regulations (GDPR), and national legislation implementing the GDPR. For EU and UK employees, the following additional sections are applicable to your employment:
Lawful Basis for Processing Personal Data
The processing of your personal data as detailed in the “Use of Personal Information” section above is also subject to the enumerated lawful bases provided in the DPA or GDPR, as applicable to you, principally:
- Processing necessary for the performance of a contract, or to take steps at the request of the data subject prior to entering into a contract (GDPR Article 6.1(b));
- Compliance with a legal obligation (GDPR Article 6.1(c));
- Processing necessary to protect the vital interests of the data subject or of another natural person (GDPR Article 6.1(d));
- Processing necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (GDPR Article 6.1(d)).
Collection and Use of Special Categories of Personal Information
The following special categories of personal information are considered sensitive under the laws of your jurisdiction and may receive special protection:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Data concerning health
- Data concerning sex life or sexual orientation
- Data relating to criminal convictions and offenses
We may collect and process the following special categories of personal information when you voluntarily provide them for the following legitimate business purposes, to carry out our obligations under employment law, for the performance of the employment contract, or as applicable law otherwise permits:
- Trade union membership information for the purpose of paying trade union premiums
- Physical or mental health information or disability status to comply with health and safety obligations in the workplace, to make appropriate workplace accommodations, as part of sickness absence monitoring, and to administer benefits
- Race or ethnic origin, religious affiliation, health information, and sexual orientation to ensure meaningful equal opportunity monitoring and reporting
Very occasionally, we may process special categories of personal data or criminal convictions data where it is needed in relation to legal claims or where it is needed to protect your interests or someone else’s.
Where we have a legitimate need to process special categories of personal information for purposes not identified above, we will do so only after providing you with notice and, if required by law, obtaining your prior, express consent.
Cross-Border Data Transfers
Where permitted by applicable law, we may transfer the personal information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary, for the purposes set out in this Privacy Notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require Axoni to change incorrect or incomplete data;
- require Axoni to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where Axoni is relying on its legitimate interests as the legal ground for processing;
- request that Axoni suspend processing of your data, for example, if you want us to establish its accuracy or provide the reason for processing it; or
- request that we transfer your personal information to another party.
If you believe that Axoni has not complied with your data protection rights, you can complain to the data protection authority in your country. In the UK, you can direct a complaint to the Information Commissioner by contacting the Information Commissioner’s Office directly. Full contact details, including a helpline number, can be found on the Information Commissioner’s Office website (www.ico.org.uk).
If you have any questions about our processing of your personal information or would like to make an access or other request, please contact us at: firstname.lastname@example.org