Recruitment Privacy Notice
This privacy notice applies to the processing of personal information that PROS collects from and about job applicants, including contractors, interns and any other potential employee or candidate. From when we receive your application, PROS will need to maintain and process information about you so we can assess and communicate a recruitment decision. This notice outlines the types of personal data we collect, why we collect it and how long we retain it.
Table of Contents
What is Personal Data?
“Personal data” is information that can be used to identify you either directly or indirectly. EU privacy law considers the following personal data to be “sensitive personal data” and is subject to special protection: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; health-related data; data concerning a person’s sexual orientation or sex life; trade union membership; and genetic and biometric data.
What Personal Data do we collect:
- Identification data and contact details: your name and email address and any data that you choose to include in a resume (such as home address or phone number).
- Visa Status and other Identifiers: work eligibility, authorizations, national identifier numbers, visa number, social security number, driver’s license number, passport number or other similar identifiers.
- Audio/Visual data: audio, electronic, visual, or similar information such as, photo if included in your resume, CCTV images and photographs if you attend onsite interviews, and audio/visual recordings where interviews are recorded.
- Employment History: professional or employment-related information (job title, employer, employer location and employment dates, reference contact information).
- Education and Personal Information: information about education history, background, certification, language, skills, hobbies, details of any memberships or professional and private interests, desired salary, and background screening information if relevant.
- Behavioral and Cognitive Information (US only): if you consent to the optional behavioral and cognitive assessments as part of our application process, in addition to contact details, the Predictive Index tool will collect your responses to the behavioral assessment (which consists of adjectives chosen by you) and/or the cognitive assessment (which consists of multiple choice responses chosen by you) and inferences and profiles drawn from those assessments.
- Protected Classifications (US only): as part of PROS diversity and inclusion program, you have the option of reporting your characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information. We use this information to measure and track diversity and inclusion across our company.
This information is usually collected directly from you, whether in your resume, cover letter or during calls or emails with you. We may also obtain the information from your employment references, where we use third parties to carry out background checks (where permitted by applicable law), or through publicly available sources including business, professional or social media sites you use, such as LinkedIn.
Why do we collect this information:
- To Manage our Recruitment Process.
- To schedule and conduct interviews.
- To identify candidates, including by working with external recruiters.
- To verify information provided by you, to conduct pre-employment background checks where applicable, and to otherwise screen or evaluate your qualifications, suitability, and relevant characteristics.
- To make offers, negotiate the terms of offers, and assess salary and compensation matters.
- To contact you about future career opportunities at PROS.
- To analyze and monitor the diversity of our workforce in accordance with applicable laws. This includes, for example, compliance with equal opportunity employment laws.
- To Defend and Protect Our Rights.
- To protect and defend our rights and interests and those of third parties, including to manage and respond to legal claims or disputes, to conduct audits and investigations, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
- Securing our offices, premises, and physical assets, including through the use of electronic access systems and video monitoring.
- To Improve our Recruitment Process.
- To improve our recruitment process and activities, including through any feedback provided by you.
- To comply with Applicable Legal Obligations.
- To comply with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) including under employment and labor laws and regulations, social security and tax laws, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.
What is the Legal Basis for processing your Personal Data:
Under data protection laws, there are six available lawful basis under which an organization may process personal data. They are consent, contractual purposes, legal obligations, vital interests, public task, and legitimate interests. PROS relies on the following legal basis to process your personal data:
- As a result of your consent. When you have consented to us using your personal data for a specific purpose, you can withdraw your consent at any time by contacting us as stated below in the “How to contact us” section.
- To comply with pre-contractual or contractual obligations. We process personal data to perform our obligations prior to entering an employment contract with you.
- Within the scope of our legitimate interests. On occasion, and only after having considered the minimum privacy impact for you, the processing of your personal data may be necessary for PROS’ legitimate interest. This will include our legitimate interest to make recruitment decisions.
To comply with our legal obligations. PROS is subject to legal obligations and regulations and in some cases, the processing of your personal data will be necessary for us to fulfil these obligations. An example of this would be to comply with immigration laws.
| Purpose of processing | Legal Basis |
|---|---|
| To assess your suitability for the role for which you are applying | Legitimate interest |
| To conduct optional behavioral and cognitive assessments (US only) | Consent |
| To schedule and conduct in-person and online interviews, and where you consent, to record online interviews | Legitimate interest Consent (where applicable) |
| Purpose of processing | Legal Basis |
| To communicate with you regarding the recruitment process | Legitimate interest |
| To verify information provided by you, including to complete background checks where applicable and legally permitted | Legitimate interest |
| To manage the pre-hiring process (prepare contractual documents, confirm work status, set-up the arrival (IT, etc..) and prepare the onboarding) | Precontractual measures |
| To perform diversity and inclusion reporting (US only) | Legitimate Interest |
| To retain your contact details and inform you about new open positions that may become available | Legitimate interest Consent (where applicable) |
| To manage your account on Workday, our recruitment portal | Legitimate interest |
| To manage and defend our rights and those of third parties, including to manage and respond to legal claims or disputes. | Legitimate interest |
| To improve our recruitment process | Legitimate interest |
How do we share your Personal Data:
We will only disclose your personal data to those requiring access for the purposes set out in this notice. These may include the following categories of recipients:
- PROS managers and HR team members
- External service providers including Workday, the provider of our recruitment portal, recruitment agencies, agencies involved in background checks and screening, firms involved in our visa and work permit applications, internet service providers, operating systems, and platforms.
- PROS global affiliates and subsidiaries
- Our advisers, agents, courts, regulators, public authorities, and others (as required by law) where required to comply with our legal or regulatory obligations, or to defend against potential litigation.
How do we maintain the security of your Personal Data:
To prevent unauthorized access, maintain data accuracy, and provide for the correct use of information, we have put in place physical, electronic, and managerial procedures designed to safeguard and secure the information we collect about you through Workday, our recruitment portal. We endeavor to secure your personal data in accordance with industry standards and technology. Since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to PROS. There is no guarantee that information may not be accessed, copied, disclosed, altered, or destroyed by breach of any of our physical, electronic, or managerial safeguards. You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of Workday.
International transfers of your Personal Data:
PROS is a global organization, headquartered in the US, with group members and sub-processors located outside the EEA, the UK and Switzerland. PROS uses a cloud-based platform, Workday, to manage our job openings, applications, and interviews. Recruitment data is accessible to all PROS recruiters, in all countries where PROS operates.
Where we transfer your personal data outside of the EEA, the UK or Switzerland, we will ensure your data is protected through:
- Intra-group transfers of Personal Data are governed by the Standard Contractual Clauses approved by the European Commission or competent UK authority (as applicable) with the data importer which guarantee a level of protection for personal data transferred equivalent to that which applies within Europe.
- Transfers of personal data to external service providers may be required for the purposes mentioned above. Such transfers are either made under the Data Privacy Framework (DPF) or are subject to Binding Corporate Rules, or Standard Contractual Clauses, which can be made available to you on request. The service providers have contractually agreed to protect your personal data in accordance with European data protection standards.
Retention of your Personal Data:
We keep your personal data in line with our data retention policy, meaning we only retain it where we have an ongoing legitimate business need to do so. If your application is successful, the information you shared with us during the application procedure will be added to your personal file.
If you have applied for a job with PROS, and are unsuccessful, we will retain your personal data for a period of eighteen months from the date the recruitment application process has been closed.
We may need to retain your information for a longer period where we need the information to comply with local regulation requirements or to respond to queries or complaints.
We may retain your information for a longer period with your consent (when required by law), to inform you of our new open positions.
Your rights over your Personal Data:
You may access, modify, and delete certain of your personal data by directly logging into your PROS Workday account. If you wish to access, modify and delete any data which is not accessible to you via your Workday account, or if you do not have a Workday account, check the section below “How to contact us” for information on how to submit your request.
Depending on where you are located, you may have the following rights over your data:
- Right to access/obtain a report detailing the information held about you: You can ask us to confirm whether or not your personal data is being processed by PROS and if so, what specific personal data is being processed.
- Right to correct personal data: You can have inaccurate information corrected.
- Right to be forgotten: You may request the deletion of some of your personal data.
- Right to restrict the processing of your personal data: You can ask us to restrict the processing of your personal data.
- Right to data portability: You may request the portability of your personal data in a structured, commonly used, and machine-readable format if processing is carried out on the basis of consent or a personal contract.
- Right to object: You may in some cases ask us to stop processing your personal data.
- Right to withdraw your consent: if we have processed your personal data with your consent, you may at any time withdraw that consent by using the contact details below in the “How to contact us” section. Withdrawing your consent will not affect the lawfulness of the processing based on the consent given prior to your withdrawal.
You may also file a complaint with the supervisory authority of your usual place of residence, your place of work or the registered office of any PROS entity. Please reach out to us at the contact details below if you require details of your competent supervisory authority.
How to contact us:
If you have any questions or concerns about our use of your personal data, please contact the PROS Human Resources department (humanresources@pros.com). For further information regarding your rights under the law, or to exercise any of your rights, please contact privacy@pros.com.
Changes to this notice:
The content of this privacy notice may be updated from time to time, so we suggest that you return to the website on a regular basis and carefully read the information provided.
Additional information for California residents:
For the purposes of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), personal data in this notice refer to the definition of personal information under CCPA meaning any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. See detailed descriptions above for:
- What personal information do we collect;
- Purposes for collecting, using, and disclosing personal information; and
- Disclosure of personal information.
Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information about you beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(l) of the CCPA regulations). We only use and disclose sensitive personal information about you as reasonably necessary and proportionate: (i) to perform our obligations as further described in this notice (Why do we collect this information); (ii) to help ensure security and integrity, including to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iii) for compliance with our legal obligations; (iv) to our service providers who perform services on our behalf; and (v) for purposes other than inferring characteristics about you.
Additional Rights. California law grants California consumers certain rights in addition to those listed above (Your rights over your Personal Data), subject to certain limitations and exemptions including:
- to request deletion of personal information.
- to know/access the categories of data that we collect: the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you in the prior 12 months and to have this delivered, free of charge, in an easy to read format either by email or another portable means.
- to request correction of inaccurate personal information we maintain about you.
- to opt-out of the sale and sharing of their personal data. We do not sell or share (as those terms are defined by the CCPA) your personal data.
- to request to limit certain uses and disclosures of sensitive personal data. However, as discussed above, we do not use or disclose your personal data beyond the purpose authorized by the CCPA.
- non-discrimination: not to be subject to discriminatory treatment for exercising your rights under the CCPA.
How to Exercise Your Rights. You may exercise your rights to access, modify and delete certain of your personal data by directly logging in to your PROS Workday account. If you wish to exercise your rights to access, modify and delete your personal data which is not accessible to you via your Workday account, visit our California Individual Rights Page for information on how to submit your request.
We will take steps to verify your request by matching the information provided by you with the information we have in our records. Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative (e., by completing all required fields on our webform if you choose to submit a request in that manner).
- Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.
In some cases, we may request additional information in order to verify your request or where necessary to process your request. Authorized agents may initiate a request on behalf of another individual through one of the above methods; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
You may also contact us at the relevant contact address above (How to contact us).