Job Applicant Privacy Notice
Last Updated: June 19th, 2023
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Introduction
MillerKnoll respects the privacy of our job applicants (“Applicants”), and this Applicant Privacy Notice (“Notice”) describes our current privacy practices concerning the collection and use of information about you. It provides you with details about the type of information we collect, why we collect it, to whom we disclose it and how we protect it. In the context of your application for employment/engagement with the relevant local MillerKnoll company (the “Company”, “we”, “us”), the Company, acting as Controller, will Process information about you, in both paper/manual and electronic format. We refer to such information as “Personal Information.” Any capitalized terms not otherwise defined in this document are defined as set forth in relevant Data Protection Laws.
Except in purely local instances, the Company is responsible with other MillerKnoll companies, acting as independent Controllers, for the lawful Processing of your Personal Information. For example, in our global organization not all hiring managers will be based at the same location where you may apply for work. Likewise, our business units are operated across different MillerKnoll companies and countries.
We are required by applicable privacy laws and regulations to give you the information in this Notice. It is important that you read this Notice carefully, together with any other information that we might give you from time to time about how we collect and use your Personal Information.
Whenever you interact with us on behalf of another individual or entity, such as if you provide us with names of other individuals as references in your job application, you must obtain their consent (or have the legal authority without consent) to share their Personal Information with us.
If you interact with our website, purchase our products or services, or otherwise engage with us outside of the job application context, the privacy notice provided in connection with that interaction applies instead, not this Notice.
This Notice does not form part of any contract of employment or other contract to provide services and does not give you any contractual rights.
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Sources of Personal Information
2.1 Directly from you:
The Company generally collects Personal Information directly from you, such as when you complete a paper or online application (including on a dedicated online talent management platform), communicate with us in connection with your application, provide references, or participate in an interview or any aptitude test or assessment (including online). We may also collect your Personal Information when you decide to complete questionnaires, such as a satisfaction survey or a diversity and inclusion questionnaire. You may also provide new, updated, or corrected Personal Information to the Company from time-to-time.
Providing your Personal Information may be mandatory in some situations and optional in others. Unless labeled as optional, any information requested in the application process is mandatory to the application process/your consideration. In these situations, if you do not provide requested Personal Information, we may not be able to process your job application or comply with our legal obligations.
2.2 From technology collected automatically and through tracking:
The Company may automatically collect information or inferences about you, such as through tracking technologies. This may include information about how you use the website(s) where you provide Applicant information.
2.3 From parents, subsidiaries, and affiliates within MillerKnoll.
2.4 From third parties or public sources, such as:
- Colleagues or supervisors
- Service providers, such as:
- Recruiting or staffing firms
- Background checks
- References
- Business partners
- Social media platforms and networks
- Public websites, government entities that maintain public records, or Personal Information that you submit to a public forum
We may combine Personal Information that we receive from the sources described in this Notice, including third party sources and public sources, and use or disclose it for the purposes described below.
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Personal Information We Collect
We collect the following Personal Information about you and how you interact with us.
Personal Information Categories Examples Identification Name, photograph, signature, physical characteristics, and a description of you. Contact Home address, telephone, and email addresses. Professional Qualifications Applicant qualifications, past employment, salary and wage information and history, references, resume/CV, education history, job level, years of experience, education level, professional qualifications, academic certificates and licenses, languages spoken, other relevant skills, and eligibility to work information (only from U.S. Applicants and only if you choose to provide it). We may also collect and process information about you generated during or after interviews and related activities, such as tests or satisfaction surveys. Technology and Security IP address, information about how you use the website(s) where you provide Applicant information, non-precise geolocation data as derived from your IP address, and audio, electronic, visual, or other sensory information, such as photographs, audio, or footage collected in the course of video interviews or security camera footage in the public area of the Company’s facilities (including reception, conference rooms, parking, and other general areas) if you participate in on-site activities, such as a job fair, job interview or aptitude test. Demographics Racial or ethnic origin, gender, and veteran status (only from U.S. Applicants and only if you choose to provide it). Health Information Information about disabilities (only from U.S. Applicants and only if you choose to provide it). Other information you share with us Information you choose to provide, including hobbies, social preferences, and answers to feedback surveys. -
Sensitive Personal Information We Collect From U.S. Applicants
For purposes of U.S. Applicants only, we collect the following information, which may be considered sensitive (“Sensitive Personal Information”), on a purely voluntary basis:
- Racial or ethnic origin information
- Information concerning health (such as information about disabilities)
MillerKnoll does not Share or Sell Sensitive Personal Information of Applicants.
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Our Use of Personal Information
The Company uses the Personal Information identified above for the following purposes:
Why we use your Personal Information Personal Information Categories Legal Basis Hiring.
We process Applicant Personal Information to:- Determine suitability and eligibility for a role.
- Verify qualifications, administer background checks.
- Establish your right to work in a specific jurisdiction.
- Identification
- Contact
- Professional Qualifications
- Technology and Security
- Demographics (from U.S. Applicants only)
- Other information you share with us
- To take steps to enter into an employment contract or another employment arrangement with you.
- Legitimate Interests in considering you for employment.
- Your consent, where appropriate.
- Compliance with legal obligations.
- Performance of rights and obligations in connection with employment, where applicable.
Internal Business Purposes.
We use this information to:- Manage and improve our recruitment process.
- Manage our general operations and assets.
- Prepare accommodations.
- Identification
- Contact
- Professional Qualifications
- Technology and Security
- Health Information (from U.S. Applicants only)
- Other information you share with us
- Legitimate Interests in managing our business.
- Your consent, where appropriate.
Legal, Safety or Security Reasons.
We use this information to:- Comply with laws and regulations (e.g., labor and employment laws, health and safety, tax, anti- discrimination laws).
- Exercise or defend our legal rights.
- Identification
- Contact
- Professional Qualifications
- Technology and Security
- Demographics (from U.S. Applicants only)
- Health Information (from U.S. Applicants only)
- Other information you share with us
- To take steps to enter into an employment contract or another employment arrangement with you.
- Legitimate Interests in complying with our legal obligations and exercising our legal rights.
- Your consent, where appropriate (in limited circumstances).
- Compliance with legal obligations.
- Performance of rights and obligations in connection with employment, where applicable.
Technology and Security.
We use this information to:- Monitor the workplace, and maintain the security of computing resources, assets, and premises.
- Provide you with access to systems, assets, and premises.
- Provide services to you as necessary for your role, and to protect your personal safety.
- Protect our, your, and our customers’, and other individuals’ safety, property or rights; and protect against malicious, deceptive, fraudulent, or illegal activity.
- Identification
- Contact
- Professional Qualifications
- Technology and Security
- Legitimate Interests in managing our business.
- Your consent, where appropriate.
- Compliance with legal obligations.
Diversity, Equity, Inclusion initiatives.
We use this information (in the U.S.) as necessary to:- help us understand the diversity of our workforce, evaluate policies and procedures, and support core business diversity, equity, and inclusion initiatives.
- Identification
- Demographics
- Health Information
- Other information you share with us
Corporate Transactions.
We may use this information for certain corporate transactions:- If we acquire, or some or all our assets are acquired by, another entity.
- Through a sale in connection with bankruptcy.
- Other forms of corporate change.
- Identification
- Contact
- Professional Qualifications
- Technology and Security
- Demographics (from U.S. Applicants only)
- Health Information (from U.S. Applicants only)
- Other information you share with us
- Legitimate Interests in conducting corporate transactions. -
Our Disclosure of Personal Information
Personal Information may be disclosed to other MillerKnoll companies (i.e., intra-group) or to third parties.
Recipients Why We Disclose It 6.1 Intra-Group/Affiliated Companies To enable the business function to which you applied and Human Resources (HR), Technology, Information Security, Finance, Legal and Compliance to perform business services on behalf of you and the Company. 6.2 Service Providers To enable contractors, consultants and other suppliers who assist us as follows: travel services, recruitment, and certification; determining suitability and eligibility for a role; verifying qualifications, administering background checks; establishing your right to work in a specific jurisdiction and other HR assistance; or providing other general services such as information technology and processing services, including from cloud service providers, so that we may operate our business and perform our HR administrative activities. 6.3 Professional Advisors To seek legal and professional advice from, for example, external lawyers, accountants, and management consultants. 6.4 Other Entities Regarding Corporate Changes In connection with the sale, assignment or other transfer of all or part of our business. 6.5 Government Authorities, Law Enforcement, and Other Recipients for Legal, Safety and Security Reasons If we in good faith believe we are compelled or authorized to make disclosures by any applicable law, regulation, legal process, or government authority; or where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies. Supplemental Disclosure Information for California Residents:
California laws require that organizations identify whether categories of Personal Information have been Sold or Shared or disclosed to a third party for a “Business Purpose" (as defined under California law). For a list of the categories of Personal Information that we collect and the third parties to whom it is Sold or Shared or disclosed for Business Purposes, please see Appendix 1.
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Our Use and Disclosure of Sensitive Personal Information
We collect Sensitive Personal Information from US Applicants who choose to provide it. We only use and disclose your Sensitive Personal Information for the following purposes:
- Performing services or providing goods reasonably expected by an average Applicant.
- Detecting security incidents.
- Preventing malicious, deceptive, or illegal actions.
- Ensuring the physical safety of individuals.
- For short-term, transient use.
- Performing or providing internal business services.
- Verifying or maintaining the quality or safety of a service or device.
- Purposes that do not infer characteristics about you.
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Transfer of Personal Information Between Countries
MillerKnoll is a global enterprise based in the United States with operations in countries around the world. An Applicant’s Personal Information may be accessed, used, and collected by authorized MillerKnoll Associates and third parties acting on our behalf in countries that are different from the Applicant’s, and which may have different, including less stringent, Data Protection Laws.
MillerKnoll has implemented global privacy practices for Processing Personal Information to ensure the Personal Information is protected under various Data Protection Laws, including the applicable Data Protection Laws under which the Personal Information was collected. MillerKnoll relies upon EU Standard Contractual Clauses (SCCs) to transfer Personal Information between the countries in which we operate in accordance with the standards and conditions of applicable Data Protection Laws, including standards and conditions related to security, Processing, and acceptable transfer mechanisms. Some third parties with whom MillerKnoll shares Personal Information may be based outside of European Economic Area (EEA). Transfers to these third parties take place using an acceptable data transfer mechanism such as Binding Corporate Rules (BCRs) or SCCs. Where required by law, we will obtain your consent to transfer your Personal Information.
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Security and Retention
MillerKnoll has implemented reasonable technical and organizational measures to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of the applicable Personal Information. These safeguards are designed to protect your Personal Information from loss and unauthorized access, copying, use, modification, or disclosure. However, since the Internet is not a 100% secure environment and no security system or measures are impenetrable, we cannot guarantee the security of any information you transmit to us. We strongly advise you not to communicate any confidential information through email to us or otherwise through any means other than our dedicated online talent management platform.
We retain Personal Information only for as long as necessary to fulfill the stated purposes for which the Personal Information was collected or otherwise Processed and thereafter only for legitimate purposes or legal requirements as outlined above. This includes retaining your Personal Information consistent with the Applicant-related context of our interactions; to ensure the ongoing legality, safety and security of our services and relationships; and for other legitimate business purposes in accordance with our internal retention procedures. In addition, subject to applicable law, we may retain your Personal Information for a limited period after you have applied for a job for which you were not selected to allow you to reapply. If you would like to know more about the retention periods applicable to your Personal Information, you can contact us using details provided in Section 11 below.
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Your Privacy Rights
You may exercise your rights via the Privacy Rights Portal.
Right to Opt-Out or Withdraw Consent:
All Applicants have the right to withdraw consent in cases where consent is used for Processing. You are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any Processing of your Personal Information that occurred prior to the withdrawal of your consent will not be affected.
Right to Deletion:
All Applicants have the right to request that we delete Personal Information about you that we have collected from you, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our legitimate and lawful business purposes.
Right to Access/Know and Portability:
All Applicants have the right to access their Personal Information and to request that we disclose Personal Information that we have about you. You can request that we provide you with the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting, Selling, or Sharing the Personal Information, and to whom we have disclosed your Personal Information and why. You can also request a copy of your Personal Information in a readily usable format.
Right to Correction:
You have the right to request the rectification of inaccurate Personal Information and to have incomplete Personal Information completed.
Right to Restrict Use:
In certain circumstances, you may have the right to restrict or object to the Processing of your Personal Information, including the right to not be subject to automated decision making.
Right to Lodge a Complaint:
You also have the right to lodge a complaint with a supervisory authority, in the place of your residence, place of employment/engagement, or the location where the issue that is the subject of the complaint occurred.
Verification: For residents of California, we may seek certain Personal Information to verify your identity that may include email address, mailing address, and government-issued identification. We may use third party verification companies to help us verify your identity. In some cases, we may request different or additional information including a signed declaration that you are who you say you are, and will inform you if we need such information
Authorized Agents: Authorized agents may exercise rights on behalf of Applicants who are residents of California by submitting a request via email to privacy@millerknoll.com or our webform and indicating that they are submitting the request as an agent. We will require the agent to demonstrate authority to act on behalf of such an Applicant by providing signed permission from Applicant. We may also require Applicant to verify their own identity directly with us or to directly confirm with us that they provided the authorized agent permission to submit the request.
Non-Discrimination:
MillerKnoll will not discriminate against you for exercising your rights. -
Contact Details
If you have any questions about this Notice or wish to obtain more information about data transfer mechanisms and our intra-group data sharing arrangement, please contact our privacy team at privacy@millerknoll.com.
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Changes to Our Notice
The Company will make changes to this Notice from time to time, without prejudice to your rights under applicable Data Protection Laws. The new version will be effective from the date indicated in that updated Notice, ensuring that individuals receive sufficient advance notice and draw their attention to any significant changes.