SMART Technologies Recruitment Privacy Policy
Purpose
This Recruitment Privacy Policy (the “Policy”) explains how SMART Technologies ULC (“SMART”, “us,” or “we”), and its subsidiaries, including but not limited to SMART Technologies Corporation, SMART Technologies (Seattle) Inc., SMART Technologies (Germany) GmbH, SMART Technologies (France) SAS, SMART Technologies (GB) Limited, SMART Technologies (Middle East) FZE, SMART Technologies (China) Co., Ltd., SMART Technologies (Singapore) Private Limited, SMART Technologies (APAC) Inc., SMART Technologies (EMEA) Inc., and SMART Technologies (LATAM) Inc., collect, use, process, store and protect your personal data in connection with SMART’s recruitment and employment processes.
“Personal Data” means individually identifiable information that identifies a natural person (not a corporation) or may, with reasonable effort, be used to identify a natural person.
This Policy is applicable to job applicants, potential candidates, and those who participate in our recruitment programs and events.
By submitting your data to us, you acknowledge and agree that:
- You have read, understood, and agree to this Policy;
- You are not obligated to share any requested information or may redact details you prefer not to disclose;
- All representations made by you are true and correct to the best of your knowledge, and you have not knowingly omitted any relevant information; and
- This Policy is not an offer of employment and does not form part of any contract of employment offered to candidates hired by SMART.
Personal data we collect
We collect personal data directly from you when you apply for a role through our online application process, such as your name, address, contact information, work and educational history, achievements, identification documents, transcripts, and any information that may be required due to legal requirements (e.g. residence or work permits).
We may collect photographs or videos during events, or as part of the recruitment process. If you receive an offer from us, we will conduct a background check and, to the extent permitted by applicable law, we may collect data related to criminal offences and proceedings. Additionally, we may collect similar personal data about you from third parties, credit agencies, law enforcement, recruitment firms, your references, previous employers, SMART employees involved in your hiring process, and employment background check providers. We may also collect publicly available information about you from social media platforms.
In limited circumstances and as permitted by applicable law, we may collect information relating to health and medical characteristics in order to fulfill public health and workplace safety obligations and provide reasonable accommodations during the interview process.
Use of your personal data
We collect and use your personal data for legitimate human resources and business management reasons, including:
- identifying and assessing candidates for current and future employment opportunities;
- maintaining recruitment and hiring records;
- ensuring compliance with legal obligations;
- verifying your information, carrying out reference checks and/or conducting background checks (where applicable);
- protecting our legal rights to the extent authorized or permitted by law;
- communicating with you about the recruitment process and/or your application(s); and
- enhancing SMART’s recruitment process.
Legal basis for processing your personal data
Our processing of your personal data for the purposes mentioned above is based in one or several of the following legal grounds:
- our legitimate business interests in evaluating your application, and improving our hiring process;
- fulfilling contractual and precontractual measures relating to your potential employment; and
- to comply with applicable law with legal and regulatory requirements, including those related to public health and workplace safety.
Background screening
If you receive a job offer from us, we will conduct a background check, either ourselves or through a third party. If a background check is required, a third-party provider may contact you to ask for your permission to access your information. At that time, you’ll receive more details about the process and what personal data will be involved.
Data recipients and International data transfers
We use third-party service providers for our recruitment software and to help us find and evaluate candidates, conduct pre-employment checks, and improve our hiring process. These providers only use your data for SMART-related purposes and are not allowed to use it for anything else. We do not sell your personal data to third parties. A list of the third parties we share data with to provide our recruitment services to you are detailed below.
Your personal data may be accessed by recruiters and interviewers in the country where the job you’re applying for is located, as well as by recruiters and interviewers in other countries within the SMART global organization. Upon hire, administrative staff and IT personnel at SMART may also access your data. We have measures in place to ensure your data is protected when it’s processed by SMART subsidiaries, affiliates, employees, or service providers.
It’s your responsibility to get consent from your referees before sharing their personal information with SMART.
No matter where your data is processed, we apply the same protections described in this policy and follow legal frameworks for data transfers.
Automated sorting of applications
We use data analytics and algorithms to help us in prioritizing applications and sorting candidates based on the skills and strengths needed for the role.
The results are combined with other information about the candidate, and decisions are made based on human judgment. Each candidate is evaluated on their own merits and artificial intelligence does not do that for us.
For some roles, specific prerequisites or skills may be required (e.g., fluency in a language, professional qualifications, certifications, or a certain number of years of experience). Applications that do not meet these requirements may be automatically rejected.
Data retention
If you accept a job offer from us, the personal data collected during the recruitment process will become part of your employee records. This data will be retained according to the specific legal requirements of the country and the policy applicable to SMART employees, which will be shared with you during onboarding.
If we do not employ you, and unless you object by following the process described in the Section “Your Rights” below, we may nevertheless continue to retain and use your personal data for up to two (2) years for system administration purposes, and to consider you for potential future roles. Thereafter, we shall delete all of your information.
We may want to remain in contact with you and consider you for future employment opportunities. In such an event, we will seek your consent to include you in one of our recruitment programs that provides you ways to further learn about and stay in touch SMART, either prior to or after you formally apply for a job opportunity. Participation in these recruitment programs is entirely optional.
You may request the deletion of your data at any time by e-mailing privacy@smarttech.com.
Security
We use widely accepted technical and operational security measures to protect your personal data. Only authorized SMART personnel and third-party service providers listed below are allowed to access this data, and they are required to treat it as confidential.
However, no security measures can guarantee complete protection against loss, misuse, or alteration of personal information. SMART is not responsible for any damages or liabilities resulting from such security failures. By using our services, you acknowledge that data and communications, including emails and other electronic communications, may be accessed by unauthorized third parties when transmitted over the Internet. This disclaimer does not affect any liabilities that cannot be excluded or limited under law.
Your rights
Subject to applicable law, including exceptions, you have the following rights with regard to the personal data that we collect about you:
- right to ask what personal data we have about you and how we use;
- right to request a copy of the personal data that we hold about you;
- right to request that we correct or amend your personal data;
- right to request deletion of your personal data; and
- right to ask us to stop or limit how we process your personal data.
To protect your privacy and security, we may need to verify your identity before acting on certain requests, to the extent permitted by law. If someone is making the request on your behalf (like an authorized agent) and they don’t provide proof of authority (such as a power of attorney), we may ask for additional evidence, like written authorization, or contact you directly to confirm the request.
If you would like to exercise your rights regarding your personal data, you can do so by:
- emailing your request to us at: privacy@smarttech.com
- contacting us by postal mail at:
+1.403.245.0333
Notification of Breach
If we become aware of a personal data breach, we will without undue delay, and where feasible, no later than 72 hours after having become aware of it, notify you of said breach, unless the data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Our communication of a breach shall be in clear and plain language and contain a minimum of:
- Contact details of the Data Protection Officer or other contact person,
- A description of the nature of the breach,
- Likely consequences of the breach,
- Advice on steps data subjects can take to protect themselves, and
- The measures SMART has taken or proposes to take to address the breach
Cookies
To enhance your experience, our web pages and Services use "cookies". Cookies are small text files that are placed on your computer or device. Most web browsers allow some control over cookies through the browser settings. You may accept cookies and then delete them at a later date or upon exiting your browser.
Additionally, some of our online recruitment activities are hosted by third parties. When you access sites operated by these third parties, they may to the extent permitted by applicable law, place their own Cookies or other tracking technologies on your device. We encourage you to read the Privacy Statements of these websites before transmitting any Personal Information to third parties.
Changes to this policy
We may update this Privacy Policy from time to time to reflect changes to our operations, or to meet new legal and regulatory requirements. The updated policy will be posted on our website SMART Tech Privacy Policies.
Data collected and processed
This section outlines what data is collected and processed from you and who handles the data.
| Sub-Processor | Country Data is Processed/Stored | Purpose | Data Collected/Processed |
|---|---|---|---|
| Certn Holdings Inc. | Canada |
Required for background checks. |
|
| Dayforce, Inc. | USA |
Required to manage candidate information, streamline the recruitment process, and facilitate onboarding for successful applicants. |
|
| Microsoft, Inc. | Canada |
We use Microsoft Office tools (e.g., Outlook, Word, Excel, Teams, OneDrive) to support communication, collaboration, and document management during the recruitment process. |
|
| Mitratech Holdings, Inc. (Trakstar) | USA |
Used to manage job applications, track candidate progress, and evaluate applicants during the recruitment process. |
|
Contacts
If you have any questions about this Policy or if you would like to communicate with any our Privacy Team, please contact us at privacy@smarttech.com.
+1.403.245.0333