Applicant Privacy Notice

APPLICANT PRIVACY NOTICE


Jones Day (“we”, “us”, “the Firm”) is committed to protecting your personal data responsibly and in compliance with applicable privacy and data protection laws. This Applicant Privacy Notice (“Notice”) applies to the information that Jones Day collects to facilitate your job application and includes your use of our careers website located at Jones Day Careers (herein after “Careers Website”). 

The Notice describes the types of personal data that Jones Day collects, how we use and share your personal data, and the rights available to you. This Notice also describes the measures Jones Day takes to protect the security of the data and how you can contact Jones Day about our data protection practices. 

It is important for you to review this Notice before submitting your application and personal data to us for consideration for a position with the Firm. By submitting your personal data and by using the Careers Website, your personal data will be processed in connection with your application in accordance with this Notice and applicable laws. 

This Notice is intended to help you better understand the following:
1. General Information 
2. What Personal Data We Collect
3. How We Collect Your Personal Data 
4. Why We Use Your Personal Data 
5. How Long We Retain Your Personal Data
6. Who Has Access to Your Personal Data
7. Cross-Border Data Transfers
8. Security and Integrity of Your Personal Data
9. Law Applicable to Your Application 
10. Your Privacy Rights and How to Submit Privacy and Data Protection Inquiries and Complaints
11. Updating Your Personal Data
12. Legal Effect and Changes to this Notice
13. Other Important Provisions
14. Contact Us


1. GENERAL INFORMATION
When Jones Day collects personal data about you in connection with your application, the local Jones Day office for which you are applying for a position will act as the controller with respect to your personal data. 

2. WHAT PERSONAL DATA WE COLLECT
A. Personal Data 
“Personal Data” means any information relating to an identified or identifiable individual. Depending on the position for which you apply, we may collect the following Personal Data concerning you: 
Your legal name, physical address, email address, phone number;
Your resume, CV, biography (if applicable), cover letter;
Email address for users of the Careers Website; 
Educational background, school transcripts,  writing sample (if applicable);
Current position, job qualifications, professional and other work-related licenses,
honors certifications;
Description of your practice and book of business; 
The position for which you would like to submit an application, details of how you
heard about the position for which you are applying;
Name and contact details of your recruiter (if any); 
Third–party employment references or referrals;
Information collected during in-person, online or phone interviews;
Information relating to any previous applications you may have submitted or your
current/prior work experience with us; 
Your national ID number or work permits to work in the jurisdictions for which you
applied; 
Your photo or image;
Your language skills and proficiency; and 
Any other information you elect to provide.

As a part of the application process, you may be asked questions about your willingness to submit to a background or criminal record check as permitted by applicable law. Information about you also may be collected from third parties, for example, in connection with a background check or employment confirmation, and/or employment references, where permitted by applicable law. 

If you provide us with Personal Data 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. 

B. Sensitive Personal Data 
"Sensitive Personal Data" refers to data that reveals or refers to an individual’s racial or ethnic origin, political opinions, criminal records, religious or philosophical beliefs and affiliations, or professional, trade union or political affiliations, philosophical beliefs, genetic data, biometric data, or data concerning health or data concerning a person’s sex life or sexual orientation.

You are not required to submit this type of data as part of your online resume and application submission. If you decide to transmit this type of data to us during the application process, we reserve the right to delete such information from our databases. 

C. Voluntary Disclosure
Your provision of Personal Data (including Sensitive Personal Data) in connection with a job application is generally voluntary. If the collection of any of your Personal Data is mandatory – for example, to complete an application on the Careers Website – we will let you know this before we collect it, as well as the consequences of failing to provide us with this information (if any).  

Please note that if you decide not to provide your Personal Data, it may affect the consideration of your application and potential employment with Jones Day, unless our receipt of such data is prohibited by applicable law.  

3. HOW WE COLLECT YOUR PERSONAL DATA
We may need to collect your Personal Data when you apply for a position in the following ways:
Online. When you apply online using the Careers Website;
By Email. When you send your resume, CV, job application and other information
 directly to a Jones Day office or department;
Using Social Media. When you link to the Careers Website using your LinkedIn social
media profile; and
From Recruiters or Referrals. Your Personal Data may be shared with us by recruiters
 and third-party referrals. 

4. WHY WE USE YOUR PERSONAL DATA
We need to process your Personal Data in order to potentially enter into an employment contract or relationship with you. We may process your Personal Data in order to: 
Process your application for employment; 
Communicate with you;
Provide you with services and respond to your inquiries, including on the Careers
Website; 
Assess your qualifications for a particular position (including to interview, screen, and
evaluate you);
Verify your identity and employment eligibility; and
Verify employment references and referrals.  
We also process Personal Data where we have a legitimate interest to do so or are legally obligated: 
To manage record-keeping and reporting obligations in connection with the applicant
pool; 
If you are offered a position, to conduct criminal, medical and credit background checks
(if and to the extent necessary with respect to the respective function of the
employee); and 
To comply with applicable laws and regulations. 

5. HOW LONG WE RETAIN YOUR PERSONAL DATA
We retain Personal Data for the period necessary to fulfill the purposes outlined in this Notice, based on customary human resource practices and in accordance with applicable legal and regulatory requirements. 

If you are selected for a position, your Personal Data will at least be retained during the term of your employment (extended by the applicable statute of limitation and applicable statutory data retention obligations, as the case may be).

Even if you are not selected for the position for which you applied or if you did not apply for a specific position, we may retain your Personal Data only for so long as we are permitted to under applicable law.  You may also be asked to consent to the retention of your Personal Data beyond our normal retention period to consider you for other suitable job opportunities.  Otherwise, your Personal Data will be retained during the applicable statute of limitation and in order to comply with applicable statutory data retention obligations, as the case may be, and will be destroyed or de-identified (as applicable) upon the expiry of the relevant retention period.

Contact us using the contact details at Section 14 (“Contact Us”) below to learn more about our retention policies, withdraw your application for employment, and/or withdraw your consent for continued retention of your Personal Data after the end of the recruitment process and to request us to purge your Personal Data. Please note that applicable law may require that we retain your Personal Data for a specific period even if you request that we do not consider your candidacy for employment. 

6. WHO HAS ACCESS TO YOUR PERSONAL DATA 
We only grant access to Personal Data on a need-to-know basis, including to authorized recruiters, interviewing attorneys or their designees, HR personnel responsible for the job openings, and IT staff as may be required to manage the Careers Website. Some of these people may be located in different jurisdictions, and as such, your Personal Data may be shared globally. 
We also may share your Personal Data with selected service providers, such as third-party data processors assisting Jones Day with the operation of the Careers Website. These service providers will be required to use appropriate measures to protect the confidentiality and security of Personal Data, as explained in Section 7 (“Cross-Border Data Transfers”) below. 
We also may need to share your Personal Data with other third parties such as recruiters, references or referrals, agencies that facilitate background checks, or consultants for the following reasons:
When it is necessary to involve a third-party service provider to facilitate or extend
recruitment services, background check processing, and similar services;
When explicitly requested by you;
As required by a court order or any other legal or regulatory requirement, including in
response to requests from public and government authorities outside your country of
residence;
As required in the event of any reorganization, merger, sale, joint venture, assignment,
transfer or other disposition of all or any portion of our business;
To protect our operations or those of any of our affiliates; 
To protect the rights, privacy, safety, or property of the Firm or our affiliates, you, or others;
and 
To comply with or in accordance with applicable law.  
If we hire you, your Personal Data will become part of your employment file, and may be transferred to the relevant Jones Day office.  

We do not collect or compile Personal Data for dissemination or sale to third parties for consumer marketing purposes.

7. CROSS-BORDER DATA TRANSFERS
Jones Day operates worldwide. As such, we may share your Personal Data with other offices in order to fulfill the purposes described in this Notice. This may imply a transfer to countries outside the EU where the local laws do not provide the same level of personal data protection as the country of your residence and/or the country where you are seeking employment. 

Jones Day transfers your Personal Data across country borders and, in particular, from the EU to countries outside the EU in accordance with applicable local laws and regulations. To comply with EU data protection laws, Jones Day has entered into an Intercompany Data Transfer Agreement, under the terms of which all data importers outside the EU must process and protect all Personal Data received from the EU in accordance with standard contractual clauses (the “Clauses”), as approved by the European Commission. 

The transfers of data to third-party service providers are secured by implementing the safeguards required under the applicable data protection law (including via contractual arrangements entered into with a third-party vendor). Third-party service providers are expected to protect the confidentiality and security of Personal Data, and only use Personal Data for the provision of services to the Firm, and in compliance with applicable privacy and data protection laws. 

Contact Jones Day using the contact details provided in Section 14 (“Contact Us”) below to obtain a redacted copy of the Clauses or relevant data transfer agreements (excluding commercial terms).  

8. SECURITY AND INTEGRITY OF YOUR PERSONAL DATA
Jones Day maintains appropriate physical, procedural, administrative, organizational and technical security measures intended to prevent loss, misuse, unauthorized access, disclosure, or modification of your Personal Data under our control. To comply with privacy and data protection laws and our internal policies, we address information security at all appropriate technology infrastructure points. Third-party service providers are expected to protect the confidentiality and security of Personal Data, and only use Personal Data for the provision of services to the Firm and in compliance with applicable laws. 
While we endeavor to protect the security and integrity of the Personal Data we collect, we cannot guarantee or warrant that any information, during transmission through the internet or while stored on our system or otherwise in our care, is 100% secure from intrusion by others. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance Section 14 (“Contact Us”) below.

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

9. LAW APPLICABLE TO YOUR APPLICATION
The Careers Website allows you to benefit from Jones Day’s centralized global recruitment function, while applying for jobs world-wide. The Careers Website is operated from the United States. Accordingly, any Personal Data you submit to the Careers Website will be collected in the United States and will be subject to U.S. laws, notwithstanding the possible additional applicability of laws in your country of residence. 
However, when we share your Personal Data with a Jones Day office located in the country in which you are applying for a position, that office will handle your Personal Data in accordance with this Notice. Any hiring or other employment-related decisions will be made by the office in accordance with the laws of the country where the job will be located.

10. YOUR DATA SUBJECT RIGHTS AND HOW TO SUBMIT PRIVACY AND DATA PROTECTION INQUIRIES AND COMPLAINTS
To the extent required by applicable law, you are entitled to obtain access to information on the processing of your Personal Data, object to the processing of your Personal Data, make use of your right to data portability, have your Personal Data rectified or deleted, or restrict the processing of your Personal Data. You also are entitled to withdraw any consent that you might have given with respect to the processing of your Personal Data at any time with future effect. These are known as “Data Subject Rights.” 
If you would like to exercise your Data Subject Rights or learn more about the processing of your Personal Data, please contact us under Section 14 (“Contact Us”). Jones Day will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time.  
If you are not satisfied with our response or believe that your Personal Data is not being processed in accordance with applicable laws, you also may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law. 

11. UPDATING YOUR PERSONAL DATA
You have an obligation to keep your Personal Data up to date and inform us of any significant changes to your Personal Data. Please contact careers@jonesday.com or the email listed in Section 14 (“Contact Us”) below if there are any changes in your Personal Data.  

12. LEGAL EFFECT AND CHANGES TO THIS NOTICE
This Notice is not, nor is it intended to be, a contract, nor does it otherwise create any legal rights or obligations. Accordingly, Jones Day, in its sole and absolute discretion, may amend, interpret, modify or withdraw any portion of this and related practices, in accordance with applicable law. Any change in this Notice will apply to all Personal Data in our possession regardless of whether such Personal Data was obtained before or after any such Notice change. If you need clarification regarding any aspect of this Notice, please contact us using the information provided in Section 14 (“Contact Us”) below.  


13. OTHER IMPORTANT PROVISIONS
About Children. Except where permitted by local law, the Careers Website is not intended for individuals under the age of 16. 
Jones Day’s Commitment to Diversity. Cultivating a diverse and inclusive work environment is crucial to success. We encourage applicants from all cultures, races, colors, religions, sexes, national or regional origins, ages, disability status, sexual orientation, gender identity, military, protected veteran status or other status protected by law. Jones Day is an equal opportunity employer. 

14. CONTACT US 
If you have any questions or concerns regarding this Notice, our processing of your Personal Data or to make use of your Data Subject Rights, please contact us:
By email: privacy@jonesday.com; or
Toll Free: +1-888-404-1150.
The Data Protection Officer for Jones Day’s offices may be contacted at privacy@jonesday.com. 


Effective Date: August 31, 2022
Version 2