Cincinnati Bell Applicant Privacy Notice

Job Description:

SCOPE AND OVERVIEW

Cincinnati Bell, Inc. and its subsidiary and affiliate entities (“Cincinnati Bell” or the “Company”) value your trust and is committed to the responsible management, use and protection of personal information.
This Applicant Privacy Notice (“Privacy Notice”) describes how Cincinnati Bell collects and process personal information about you during the application and recruitment process including through the Career section on its websites (collectively, the “Career Site”).
This Privacy Notice applies to job applicants only.

INFORMATION WE COLLECT

Information You Provide
For purposes of this Privacy Notice, personal information means any information about an identifiable individual collected in connection with the recruitment process. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal information, some of which we require in connection with our recruiting activities:

● Contact information such as name, address, telephone number, and e-mail address;
● Identity information such as a signature, username and password, your name, address, telephone number and email address. Some information in this category may overlap with other categories;
● Professional and education information including information that may be included in your CV, resume, or cover letter such as previous and current work experience, education information, skills, professional and other work-related licenses, permits and certifications held, and personal and professional references;
● Information collected during application related tests, assessments, interviews and phone screenings
● Information you choose to share voluntarily as part of the application process, such as ethnicity and race or memberships in professional societies;
● Any personal information required to be collected by law;
● Education information including degrees awarded, transcripts, and other information provided in support of the job application.
Information collected during phone screenings and interviews.
● Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
● Information collected during application related tests, assessments, interviews and phone screenings

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
If you do not provide sufficient information, we will be unable to consider your employment application.

Information from Other Sources
We may obtain information about you from your references or from a background check report in connection with your application, as permitted by applicable law and with your express written consent where required. We may also obtain information that is already in our possession related to previous applications you have submitted to Cincinnati Bell or, if applicable, your previous employment history with Cincinnati Bell.

USE OF INFORMATION
We only process your personal information where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, or, if applicable law requires it, with your consent.

We may process your personal information for the Company’s global personnel recruitment, management and planning purposes, as permitted by local law, including:

• To process your application;
• To assess your capabilities and qualifications for a job;
• To respond to your inquiries and communicate with you about your application, and to send you information regarding the Career Site and changes to our terms and policies;
• Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
• Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
• Creating and submitting reports as required by applicable laws or regulations.
• To comply with our legal, regulatory, or other corporate governance requirements.
• Analyzing and improving our application and recruitment process.

The information about you will be added to the Company’s database, subject to our data retention policy. In addition to using your personal information for the position for which you have applied, we may retain and use your personal inform to inform you about and consider you for other positions that may be appropriate for you with your consent. If you want us to consider you for other positions, you may contact us as specified below under Contact Us and we will retain your personal information for that purpose.

If we hire you, personal information we collect in connection with your application may be incorporated into our human resources system and may become part of your employee file and may be used for other employment-related purposes.

We will only process your personal information for the purposes we collected it for or for compatible purposes. If we need to process your personal information for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal information without your knowledge or consent only where required or permitted by applicable law or regulation.

The Company may also use the information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence or the laws of the country where you are located; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; (h) to prevent fraud; and (i) to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

DISCLOSURE OF PERSONAL INFORMATION
The Company may share personal information with subsidiaries and affiliates for the purposes set out in this Privacy Notice and as part of our regular reporting activities to other members of our group of companies. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.

The Company may share personal information with our third-party service providers who provide services such as hosting and operating our Career Site.

The Company also may share personal information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; (h) if a business transfer or change in ownership occurs; and (i) for other additional purposes with your consent where such consent is required by law. .

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 for the purposes set out in this Privacy Notice. When your information is transferred to or accessed from countries outside your home country we implement appropriate safeguards as well as any legally required administrative contractual requirements to protect your information.

DATA RETENTION
We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you (such as an application process); as required by a legal obligation to which we are subject to; or as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

We may also retain your information for the purpose of considering whether your skills are suitable for other opportunities. If you do not wish us to do this, please contact recruiting@cinbell.com. We may remove personal information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, the Company may delete personal information about you (including your CV/résumé) from our database at any time and without providing any reason. Therefore, please retain your own copy of the personal information provided to us.

YOUR RIGHTS AND CHOICES
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.

• Opting Out of Receiving Job Posting Notices. If you do not want us to contact you about jobs you may be interested in, you can opt-out by checking the relevant box located on the form where we collect your contact information or, if presented with the option to opt-in, do not opt-in. You may also opt-out job notices by following the opt-out links on that message.
• Accessing, Updating and Deleting Your Information. If you register on the Career Site, you may access, review, and change your personal information stored therein by logging into the Career Site and updating your account information. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you have already submitted for consideration for a specific position, please update your profile and resubmit your application for that position. We encourage you to promptly update your personal information if it changes or is inaccurate.
• Cookies and Automatic Data Collection Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
• Persons located in the EU, EEA or United Kingdom. If you are located the EU, European Economic Area, United Kingdom, or are otherwise subject to the General Data Protection Regulation, you may have more rights and choices with regard to your personal information. Please see our European Privacy Rights section below for more information.
• California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your personal information. Please see Your California Privacy Rights for more information.
• Nevada Residents. If you are a Nevada resident, you may have additional personal rights and choices with regard to your personal information. Please see our Nevada Privacy Rights section below for more information.

SECURITY
We seek to use appropriate physical, organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at recruiting@cinbell.com.

Do not send sensitive information to us via email. It is your sole responsibility to use the appropriate level of care whenever you communicate with us.

The Company hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Career Site.

LINKS TO THIRD-PARTY WEBSITES
The Career Site may contain links to other websites. This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Career Site links. The inclusion of a link on the Career Site does not imply endorsement of the linked site or service by the Company or our affiliates. We encourage you to read the legal notices posted on those sites, including their privacy policies.

EUROPEAN PRIVACY RIGHTS
If you are in the European Economic Area, United Kingdom, or are otherwise subject to the General Data Protection Regulation, then this section of our Privacy Policy applies to you.

Collection and Use of Special Categories of Personal Information
The following special categories of personal information may be 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 or offences.

We may collect and process the following special categories of personal information when you voluntarily provide them, or we receive them from a third party with your consent, when relevant for a particular position to carry out our obligations under employment law, or as applicable law otherwise permits:

• Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.
• Race or ethnic origin to comply with statutory obligations.
• Previous criminal charges or convictions where relevant for the position.

Where we have a legitimate need to process special categories of personal information about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Automated Data Processing
You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

Rights of Access, Correction, Erasure, and Objection
Apart from updating information contained in your profile as described above, by law you may have the right to request (i) access to personal information we collect, (ii) its modification or suppression, (iii) that we restrict its processing, (iv) that we cease using it (objection right); and/or (v) that we transfer personal information to you or another organization in a structured, commonly used and machine-readable format (right to data portability).

Please email us at recruiting@cinbell.com with any such requests. In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to request additional information to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent
Where you have provided your consent to the collection, processing, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at recruiting@cinbell.com.

YOUR CALIFORNIA PRIVACY RIGHTS
Cincinnati Bell may collect the following categories of personal information for the purposes disclosed in this Privacy Notice:

Category	Examples	Collected
A. Identifiers.	A name, postal address, online identifiers, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, national origin, disability, citizenship, immigration status, or medical information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.		NO
E. Biometric information.		NO
F. Internet or other similar network activity.	Browsing history, search history, information about interactions with our website, application, or advertisements.	YES
G. Geolocation data.		NO
H. Sensory data.		NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.	YES
K. Inferences drawn from other personal information.		NO

 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. At this time, we do not engage in this type of disclosure.

We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.

NEVADA PRIVACY RIGHTS
Nevada residents have the right to opt out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not sell covered information.

ABOUT CHILDREN
The Career Site is not intended for minors under the age of 18, except for certain employers solely in the US.

CURRENT PERSONNEL OF COMPANY
If you currently work for the Company or one of our affiliates, you must be eligible to apply for a different position within the Company to use the Career Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

The Career Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.

CHANGES TO THE STATEMENT
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal information for different purposes 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.

If you do not agree with the updated terms of this Privacy Notice, in whole or part, you can choose to not continue to use the Career Site and if you already have given information to the Company through the Career Site, you can request the suppression of such information by emailing us at recruiting@cinbell.com.

CONTACT US
The controller of your applicant personal information is Cincinnati Bell, Inc., including its subsidiary companies and affiliates. If you have questions or requests, please feel free to contact us at recruiting@cinbell.com. As part of our commitment to you, we will try to resolve any questions or concerns that you may have.