Ingram Micro Privacy Statement and Notice at Collection For Recruitment and Hiring

Ingram Micro Privacy Statement and Notice at Collection For Recruitment and Hiring

Last Updated: August, 2023

This Ingram Micro Recruitment and Hiring Privacy Statement (this “Recruitment Privacy Statement”) explains how Ingram Micro Inc., a Delaware corporation, and companies that we own or control (“Affiliates”) collect, use, store, process, disclose, and delete your Personal Data that we receive from or about you in the context of employment recruiting and hiring. This Recruitment Privacy Statement also outlines your rights in respect of your Personal Data.

Please note, our general privacy practices are covered in our Privacy Statement. If you would like further information on how we process your Personal Data outside of the recruiting and hiring context, please see our Privacy Statement, available at corp.ingrammicro.com/Privacy-Statement.aspx . If you are hired, Personal Data we collect during your onboarding and employment will be subject to our Notice of Employee Personal Data Processing.

We encourage you to read this entire Recruitment Privacy Statement and our general Privacy Statement in full, to ensure you are fully informed.

If you use Ingram Micro’s online career resources, we collect Personal Data that you submit to the website and use it for recruiting-related purposes. We may also use Cookies and other tracking technology consistent with our general Privacy Statement found at corp.ingrammicro.com/Privacy-Statement.aspx to provide individuals with a personalized online experience, to send relevant information about careers and opportunities at Ingram Micro, and to analyze the effectiveness of our recruitment efforts and resources.

Who is collecting your Personal Data?

When you apply for a job at Ingram Micro or submit your Personal Data to one of our other recruitment tools or databases, Ingram Micro will collect and use Personal Data about you during the recruiting and any hiring process. As described in this Recruitment Privacy Statement, your Personal Data may be retained and used by Ingram Micro for considering your qualifications for employment, as required by law, or as otherwise described below. Please see below for information that Ingram Micro may receive about you from third parties.

“Ingram Micro” ("we", "us", "our") means the specific Ingram Micro affiliates, subsidiaries, and contracted service providers (a list of which is available upon request) who will collect, use, and maintain your Personal Data in connection with your application for employment, our Recruiting processes, our Talent Management processes, and any hiring process if you are extended an offer of employment.

What Personal Data will Ingram Micro collect?

Personal Data collected from you

The types of Personal Data we may, depending on the relevant Ingram Micro country of incorporation, collect and process directly from you when you apply for a role with Ingram Micro and/or if you are hired for the respective role, include (but is not limited to):

Identification data and contact details – including your name, address, email address, phone number and other contact information, gender , date of birth, nationality/ies, national identifiers (such as national ID/passport, social security number(s));
Employment history – such as previous employers and job titles/positions;
Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests which may constitute Sensitive Personal Data), transcripts and employment references;
Details of your nominated references (including their name, contact details, employer and job role);
Recordings of your interviews – in some cases, we may ask for your permission to make an audio and video recording of your interview;
Details of your immigration status;
Previous applications/roles (information relating to previous applications you have made to Ingram Micro and/or any previous employment history with Ingram Micro; and
Other information you voluntarily provide throughout the process, including through assessment centers, exercises, and interviews.

As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life ("Sensitive Personal Data"), unless authorized by law or where necessary to comply with applicable laws.

However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Data for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender, and/or disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Sensitive Personal Data during the recruitment process.

Personal Data collected from other sources

The types of Personal Data we may, depending on the relevant Ingram Micro country of incorporation, collect and process from other sources when you apply for a role with Ingram Micro include (but is not limited to):

Information provided by references;
Information automatically collected by Cookies and other tracking technologies when you interact with our careers webpages or recruiting emails;
Other background information provided or confirmed by academic institutions and training or certification providers;
Criminal records data obtained through criminal records checks;
Information provided by recruitment or executive search agencies; and
Information collected from publicly available sources, including any social media platforms you use or other information available online.

When Personal Data is collected from other sources, it will only be done so where permissible and in accordance with applicable law.

Where permitted by law, Ingram Micro may contract with a third party to perform a pre-employment background screening. The content of background check information varies by country to comply with local requirements, but may include information gathered from publicly available sources, your former employers or colleagues, schools you have attended, credit reporting agencies, and criminal records databases. These types of information will only be collected with your prior consent, and you will receive more information about the nature of such a background check before it begins. Where required by applicable local law, you may be asked to provide certain background check information (which may include Sensitive Personal Data) directly to Ingram Micro.

How will Ingram Micro use your Personal Data?

Ingram Micro will use your Personal Data to:

Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available;
Perform administrative functions (e.g., reimburse you for interview-related expenses);
Perform analysis of our applicant pool to better understand who is applying to positions at Ingram Micro and how to attract top talent;
In some cases, record your online interview for review by additional recruiters and hiring managers. In such cases, we will seek your express consent to be recorded if required under applicable law;
When you apply for a position, subject to and in accordance with your marketing and communications preferences, we will enter you into a database to receive future mailings about Ingram Micro positions and recruiting events;
Transfer your contact information (only) to the Ingram Micro Talent Connection—a tool that we maintain to notify you about new positions that may be of interest to you, in accordance with your communications preferences, which may be by SMS, email, phone, or other mobile device messaging platforms. Your contact information will be used by Ingram Micro Talent Connection to send you invitations to sign up for future position alerts and invitations to Ingram Micro recruiting events, as well as follow-up reminders. Ingram Micro Talent Connection may send out periodic updates about the company and marketing materials. If you join the Ingram Micro Talent Connection, you will have future opportunities to opt-out of receiving messages and alerts if you choose;
To evaluate and improve the recruiting and hiring process;
Verify your identity in relation to any requests you make under this Recruiting Privacy Statement;
Perform any legally-required reporting, and respond to legal process; and
For other lawful purposes for which we obtain your consent.

For clarity, where the processing of your Personal Data by Ingram Micro requires your consent under applicable laws, we will seek your consent prior to any processing taking place.

With whom we share your Personal Data

We may disclose your Personal Data to the following categories of recipients:

Our Affiliates who process Personal Data for purposes that are described in this Recruitment Privacy Statement or notified to you when we collect your Personal Data. A list of our current Affiliates is available upon request.
Authorized personnel at our service providers whose platforms help us operate our recruiting and hiring functions, including:
Workday, which hosts and supports the Ingram Micro Applicant Tracking System;
Workday, which hosts and supports our Human Resources Management System (if your applications is successful and you become an Ingram Micro employee);
LinkedIn and other online recruitment and job websites;
Companies contracted to perform background screenings, where applicable. These companies may be based in another country, and may obtain data from other countries where you have lived, worked or studied, as may be relevant as part of a background check. You will receive more information about any such check before it begins;
Government officials where legal reporting requirements may exist, or law enforcement agencies or private litigants in response to valid law enforcement process (warrant, subpoena, or court order);
As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
Where necessary to protect your vital interests or those of another person;
A successor to Ingram Micro in the event that it sells or divests all or part of its business; and
Where you have provided your consent.

International transfers of Personal Data

In some cases, the sharing described in Section 4 above may result in your Personal Data being transferred internationally, including from the European Economic Area or local jurisdiction to a country outside it. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our Affiliates and third party service providers operate around the world. Both our headquarters and our service provider for the Ingram Micro Applicant Tracking System operate from the United States. This means that when we collect your Personal Data we may process it in this country.

However, we have taken safeguards designed to require that your Personal Data will remain protected in accordance with this Recruitment Privacy Statement. With regard to data originating from the European Economic Area, these include implementing the European Commission’s Standard Contractual Clauses (under Article 46.2 of the General Data Protection Regulation) between our Affiliates and with our third-party providers and data processors.

Your Privacy Rights

Further below in this Section 6, we describe the privacy rights that may be available to you with regard to Personal Data processed in the recruitment and hiring context, based on where you are located. We will respond to requests we receive from individuals wishing to exercise their privacy rights in accordance with applicable privacy laws. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.

You will not to be discriminated against for exercising your privacy rights.

Eligible individuals can request to exercise the below-described privacy rights by any of the following methods:

online by completing our webform
sending an email to privacy@ingrammicro.com
calling 1-888-914-9661 and entering PIN 374445

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Data.

You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent.

United States Privacy Rights

Where provided for by the applicable privacy laws in your state, United States job applicants may be entitled to exercise some or all of the following privacy rights with respect to the Personal Data we process in relation to recruiting and hiring:

Access / Right to Know: You may have the right to confirm whether we process Personal Data about you and to request that we disclose to you the following: (i) the categories of Personal Data that we have collected about you (including Sensitive Personal Data); (ii) the categories of sources from which we have collected Personal Data about you; (iii) the business or commercial purpose for collecting or selling your Personal Data; (iv) the categories of Personal Data that we have sold about you and the categories of outside parties to whom the Personal Data was sold; (v) the categories of Personal Data that we have disclosed about you for our business purposes and the categories of service providers to whom the Personal Data was disclosed; (vi) a portable copy of the specific pieces of Personal Data that we have collected about you; and (vii) information about the logic involved in any automated decision-making processes used by us (if applicable), as well as a description of the likely outcome of the process with respect to you.
Correct or update your Personal Data: You may have the right to request that we correct, update, or modify the Personal Data we maintain about you.
Delete your Personal Data: You may have the right to request that we delete the copies of your Personal Data that we maintain, subject to certain exceptions and limitations.
Do Not Sell My Personal Data or Share my Personal Data for Behavioral Advertising: Where applicable, you may have the right to opt-out of the sale of your Personal Data and the sharing of your Personal Data for cross-context behavioral advertising. However, we do not “sell” or “share” your Personal Data collected in the recruiting and hiring context.
Opt-out of automated decision-making: You may have the right to request to opt-out of any profiling or automated decision-making, to the extent we engage in those processing activities and subject to any limitations under applicable privacy laws.
Limit the use of my Sensitive Personal Data: In relation to the Sensitive Personal Data identified in Section 2 above, you may be able to request that we limit our use and sharing of such data to those purposes specified under applicable privacy laws.

Additional California Privacy Disclosures

For purposes of California privacy law, California residents should note the following:

We collect and use the following categories of Personal Data for our recruiting and hiring purposes described in this Recruitment Privacy Statement: Identifiers and Personal Data categories listed in Cal. Civ. Code § 1798.80(e) (such as name, contact information, date of birth, and government identification numbers); professional information (such as work history, previous employer, job references, qualifications, and certifications); internet and other electronic network activity (such as which areas of our careers pages you visit and for how long, and whether you open and click through our recruiting emails); education information (such as university attended); characteristics of protected classifications under applicable law (such as gender and immigration status); sensitive Personal Data (such as government identification numbers and, in certain circumstances, race/ethnicity, disability status, or information about physical or mental health conditions, consistent with applicable law); and where you have consented to this audio and video information (such as recordings of online interviews). See Section 2 above for more details.
We use the above-described categories of Personal Data for our recruiting and hiring-related purposes described in Section 3 above.
We collect these categories of Personal Data from the following categories of sources, as more fully described in Section 4 above: directly from you; automatically from your devices you use to interact with our careers webpages and our emails; from your job references; from your academic institutions or training certification providers; from recruiting agencies; from publicly available sources (e.g., social media pages); from our Affiliates; and from background check vendors.
We may disclose the foregoing categories of Personal Data to our Affiliates; to our service providers who help us run our business; with government agencies and other entities for legal compliance purposes, and with potential acquirers of parts of our business. See Section 5 above for more details.
We do not “sell” or “share” the Personal Data we collect in the context of recruiting and hiring, and we do not knowingly “sell” or “share” the Personal Data of individuals under 16 years of age.
We do not use or disclose sensitive Personal Data for purposes other than those specified under applicable California privacy regulations.
See Section 7 for information about how long we retain Personal Data.

European Economic Area (EEA), Switzerland, and United Kingdom (UK) data privacy rights

If you are located within the European Economic Area, Switzerland or the United Kingdom, the data controller of your Personal Data described herein is the Ingram Micro Affiliate conducting the job search.

Job applicants in the EEA, Switzerland and UK may request to exercise the following rights available under applicable data protection laws as follows with regard to the Personal Data that is the subject of this Recruitment Privacy Statement:

Access and portability of your Personal Data: You have the right to obtain access to your Personal Data (if we are processing it). You can also obtain a portable copy of your Personal Data.
Rectification of your Personal Data: You can request that we correct, update, or modify the Personal Data we maintain about you.
Erasure of your Personal Data: You can request that we erase the copies of your Personal Data that we maintain, subject to certain exceptions and limitations.
Object to processing: You can object to the processing of your Personal Data where we carry out such processing on the grounds of our legitimate interests.
Restrict processing: You can ask us to restrict processing of your Personal Data or block the further use of your Personal Data. When processing is restricted, we can still store your Personal Data.
Refuse or withdraw consent: If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
Complaints: You have the right to complain to a data protection authority about our collection and use of your Personal Data, including if you are not satisfied with our response to your privacy requests. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area and the UK are available here.)

We respond to all requests we receive from EEA, Swiss and UK data subjects wishing to exercise their data protection rights in accordance with applicable European data protection laws.

Under European data protection law, our legal basis for processing your Personal Data as part of the recruitment process is:

our legitimate interests (where they are not overridden by your data protection interests or fundamental rights and freedoms, particularly taking into consideration the safeguards that we put in place);
to comply with applicable immigration and/or employment laws and regulations;
to take steps prior to entering an employment contract with you, where you are considered for employment;
in circumstances where you have made the data public;
where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time; and
to protect the rights and interests of Ingram Micro, our employees, applicants and others, as required and permitted by applicable law.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.

Other Jurisdiction Privacy Rights

Depending on where you reside or apply from, you may have certain privacy rights available to you with regard to the Personal Data we process in the context of recruiting and hiring, similar to the United States and EEA/Swiss/UK rights described above (such as access/portability of a copy of your Personal Data, correction of your Personal Data, deletion of your Personal Data, objection to processing of your Personal Data, restriction of processing of your Personal Data, withdrawing consent to processing of your Personal Data, limiting the use and sharing of your Sensitive Personal Data, opting out of automated decision-making, and/or opting out the sale or sharing of your Personal Data for cross-context behavioral advertising).

You may submit a request by completing our online webform, sending an email to privacy@ingrammicro.com or calling 1-888-914-9661 and entering PIN 374445. We will respond in accordance with applicable data protection law.

How long will Ingram Micro retain my Personal Data?

Personal Data collected in the recruiting and hiring context will be stored in accordance with applicable laws and kept as needed to carry out the purposes described in this Recruitment Privacy Statement or as otherwise required by applicable law. Generally, this means your Personal Data will be retained:

in accordance with the retention periods set out in any employee privacy notice or other employee policies (where you become our employee);
for applicants in Europe: a period of 1 year after confirmation that your application was unsuccessful, unless you request that we delete your application.
For applicants in the United States: a period of 5 years after confirmation that your application was unsuccessful, unless you request that we delete your application; or
for all other applicants: a period of 2 years after confirmation that your application was unsuccessful, unless you request that we delete your application.

However, for the period of time while your Personal Data is retained, Ingram Micro may use Personal Data collected during the recruitment process to consider you for new positions, and, if appropriate, to refer to an earlier application if you submit a resume or other information to Ingram Micro again in the future, as well as to perform research and analysis, and to invite you to join the Ingram Micro Talent Connection.

How Ingram Micro protects your Personal Data

Ingram Micro employs organizational, technical, and physical security measures designed to protect your Personal Data from loss or misuse. Where we contract with third-party suppliers to provide services that may enable them to access your Personal Data we require them by contract to have similar security controls in place.

Changes

We may update this Recruitment Privacy Statement from time to time in response to changing legal, technical or business developments. When we update this Recruitment Privacy Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws.

You can see when this Recruitment Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Recruitment Privacy Statement.

How to Contact Us

If you have a question, comment, complaint, wish to obtain a copy of Ingram Micro’s General Privacy Statement, or if you choose to exercise any of your data privacy rights, you may contact us by emailing privacy@ingrammicro.com or calling 1-888-914-9661 and entering PIN 374445. Our data protection officer can be contacted at ronald.sarian@ingrammicro.com.