X Corp.Recruitment Privacy Notice

This Recruitment Privacy Notice explains the type of information X Corp. (“X”) will process during the recruitment cycle, why we process it and how that processing may affect you.  Your use of X services, which includes websites, SMS, APIs, emails notifications, applications, buttons, embeds, ads and our other covered services is covered by the X Privacy Policy.  

 
What do we mean by “personal data” and “processing”?

 

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system.  It includes not only facts about you, but also intentions and opinions about you.

Data “processed automatically” includes information held on, or relating to use of a laptop, mobile phone or other device. 

“Processing” means doing anything with the data.  For example, it includes collecting it, keeping it, sharing it and deleting it.

In some jurisdictions, certain data is considered to be “sensitive personal data” or “special category data”.  Depending on the jurisdiction in question, this may include  personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data and in some cases, precise geolocation.  Sensitive personal data is subject to special protection as required in the relevant jurisdiction. 

When this Notice mentions “we,” “us,” or “our,” we’re  referring to X and the X group company that you are applying to. 

 

Your personal data and where it comes from

 

We process your personal data for the purposes of fulfilling our recruitment practices.  Some of the personal data that we process about you comes from you.  For example, you tell us your contact details.  Other personal data about you is generated from references and third party companies such as recruitment agencies and platforms like LinkedIn and also internally during the course of our recruitment process.   We also use website tracking software which allows us to better understand how applicants interact with our website and our recruitment process.  

Your data will be seen internally by managers, recruiters, administrators and HR.

 

How long do we keep your personal data?

 

If you are successful in your application your data will be kept as part of your work record and you will be provided additional information about how it is processed and why.   If you are unsuccessful, your data will be deleted as required under applicable law and in accordance with our retention practices.  

 

Transfers of personal data

 

Your personal data may be collected, used, processed, stored or disclosed by us and our service providers outside your home jurisdiction, including in the U.S., and in some cases, other countries. Although other countries may have data protection laws that are different from the local laws in your country, X only transfers personal data to another country (including between X companies), in accordance with applicable privacy laws, and provided there is adequate protection in place for the data. X relies on the European Commission’s Standard Contractual Clauses for transfers of personal data between the X group companies, which require all group companies to protect personal data they process from the European Economic Area in accordance with EU data protection laws. Our Standard Contractual Clauses can be provided on request.

We will ensure your personal data is treated in accordance with this Privacy Notice, the terms in our applicable Data Protection Agreements and Standard Contractual Clauses or another valid transfer mechanism, if available, wherever we process it.

 

Legal grounds for processing personal data

 

What are the grounds for processing?

Some countries require us to provide information about the various legal grounds we rely on when we process your data.  We have summarized these grounds as “Legal Obligation” and “Legitimate Interest” and we outline what each of those terms mean in this table:

Term

Ground for processing

What it means

Term

Legal Obligation

Ground for processing

Processing necessary to comply with our legal obligations

What it means

Ensuring we perform our legal and regulatory obligations.  For example, we are required to provide a safe place of work and avoid unlawful discrimination.

Term

Legitimate Interests

Ground for processing

Processing necessary for our or a third party’s legitimate interests

What it means

We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.

Term

Consent

Ground for processing

You have given specific express consent to processing your data

What it means

In general, processing of your data in connection with our recruitment process will not be conditional on your consent.  But there may be occasions where we do specific things (such as seek to monitor diversity) and rely on your express consent in doing so.

Processing sensitive personal data

 

If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies.

 

Further information on the data we process and our purposes

 

Examples of the data we process and the grounds on which we process data are set out in the table below.  The examples in the table cannot, of course, be exhaustive:

 

Term

Ground for processing

What it means

Term

Recruitment

Ground for processing

Information concerning your application and our assessment of it, your references, work history and any checks we make to verify information provided or background checks and any information connected with your right to work or suitability for role.

 

Records of our decision making process in relation to your application.

 

Your salary expectation and personal  identifiers and contact details.

 

If relevant and to the extent required or permitted by applicable law, we may also process information concerning your health or any disability in connection with any accommodations to working or interview arrangements.

What it means

Legal obligation

 

Legitimate interests

Term

Contacting you or others on your behalf

Ground for processing

Your address and phone number, emergency contact information and information on your next of kin

What it means

Legitimate interests

Term

Security

Ground for processing

Work records and other information to verify your background, education, work history and to protect against fraud.

What it means

Legal obligation

 

Legitimate interests

Term

Monitoring of diversity and equal opportunities

Ground for processing

To the extent required or permitted by local law, information on your nationality racial and ethnic origin, gender, sexual orientation, religion, disability and age.

What it means

Legitimate interests

 

Consent

Who gets to see your data?

 

Your personal data may be disclosed to managers, HR and administrators for employment, administrative and management purposes as mentioned in this Notice.  We may also disclose your data to other members of our group, background check service providers and other service providers who provide assistance in connection with our recruitment processes.

The California Consumer Privacy Act (CCPA) requires us to provide you with information about any activity relating to the selling or sharing of your personal information (as defined within the CCPA).  We confirm that we do not sell or share personal information about our employees. 

 

Accessing your personal data and other rights 

 

We try to be as open as we reasonably can about the personal data that we process.  If you would like specific information, just ask.

Depending on where you are located, you may have rights in relation to your data.  These may include the right to make a subject access request, the right to have your personal data rectified or erased, the right to object to its processing or to have its processing and/or disclosure restricted as well as the right not to be retaliated against for the exercise of such rights. 

We are unlikely to have relied on consent as a ground for processing.  However, if we do, you may withdraw your consent at any time - though if you do so that will not affect the lawfulness of any processing done before you withdraw consent. 

For more information about these rights or the rights that may apply in your jurisdiction please contact our Data Protection Officer at dpo@X.com.

 

Contact details and complaints

 

If you have a concern related to your rights under the General Data Protection Regulation, please contact the Office of Data Protection here.  Depending on where you are, you may also raise your complaints with the statutory regulator in your jurisdiction. If you are located in the European Union or EFTA States and wish to raise a concern about our use of your information you have the right to do so with your local supervisory authority or Twitter International Company’s lead supervisory authority, the Irish Data Protection Commission. You can find their contact details here.