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Candidate Data Privacy Notice

For Candidates in the European Economic Area

Introduction

As part of its recruiting process, Altra Industrial Motion Corp. and its affiliates and subsidiaries (collectively, "Altra") collect and process personal data relating to job applicants. Altra is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. This Data Privacy Notice applies to the processing of personal data that Altra obtains from job applicants located within the European Economic Area ("EEA").

Types of Personal Data Altra Collects

Altra collects the following information about you in connection with the recruiting process:

  • Name, address and contact details, including email address and telephone number;
  • Details of your education, qualifications, skills, experience and employment history;
  • Information about your current level of remuneration, including benefit entitlements; and
  • Such other categories of data as (i) you may voluntarily provide to Altra, (ii) Altra may reasonably require in connection with the purposes set forth below, (iii) permitted by applicable law, or (iv) reasonably required to fulfil a contractual or legal obligation.
This data shall be collectively referred to in this Notice as "Candidate Data."

Special Categories of Data

Altra may process special categories of personal data, such as information concerning nationality or citizenship, race or ethnic origin, criminal history, health or trade union membership. Altra may also collect information about whether or not a candidate is disabled in order to make reasonable adjustments for the candidate’s disability. Altra processes this information in order to carry out its legal obligations and exercise specific rights in relation to employment. Altra does not request or consider information concerning religion, sex life or sexual orientation or political opinions in connection with recruiting.

Sources of Personal Data

Altra may collect Candidate Data in a variety of ways. For example, Candidate Data may be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews, questionnaires or other forms of assessment.

Altra may also collect Candidate Data from third parties, such as recruiters or former employers, subject to your consent as may be required by applicable law. Altra may also collect Candidate Data from a recruiting or other website to the extent permitted by applicable law.

Purposes

Altra processes Candidate Data for the following legitimate human resources and business management purposes: identifying and evaluating candidates for Altra positions, record-keeping relating to hiring processes, analyzing the hiring processes and outcomes, and conducting background checks where permitted by applicable law. In addition, Candidate Data may be used to comply with Altra’s legal, regulatory and corporate governance requirements.

If you are hired, your Candidate Data may be used in connection with your employment, including for purposes of entering into and fulfilling an employment contract with you.

Storage and Retention

Altra stores Candidate Data in a range of places, including on your application record, in HR management systems and on other Altra IT systems (including e-mail).

If your application for employment is unsuccessful, Altra will retain your Candidate Data on file for a period of time after the end of the relevant recruiting process (but for no longer than is permitted by applicable law) in order to consider you for future employment opportunities at Altra for which you may be suited. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. If you do not want to be considered for other positions or would like to have your Candidate Data removed, you may contact Altra as specified under Candidate Rights below.

If your application for employment is successful, your Candidate Data will be transferred to your personnel file (electronic and paper based) and retained during your employment. The period for which your personal data will be held as an employee will be provided to you in a separate privacy notice.

Sharing of Candidate Data

Your Candidate Data may be shared internally for purposes of the recruiting process, including with members of Altra’s HR and recruiting teams, interviewers involved in the recruiting process, managers in the relevant business area, and IT staff if access to the Candidate Data is necessary for performance of their roles.

Altra may transfer your Candidate Data to external third-party providers performing certain services for Altra. Such third-party providers have access to Candidate Data solely for the purposes specified in this Notice, and Altra requires these providers to undertake security measures consistent with the protections specified in this Notice and required by applicable law.

Altra may be required to disclose your Candidate Data to other third parties (a) as may be required by applicable law; (b) to protect Altra’s legal rights to the extent authorized or permitted by law, or (c) in an emergency where the health or safety of an individual may be endangered. In addition, in the event of a reorganization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of Altra’s business, Altra may transfer your Candidate Data to successor entities or parties.

International Data Transfers

Altra is a global organization and, accordingly, your Candidate Data may be transferred to and processed in the United States and other countries that may not be deemed to provide the same level of data protection as your home country. Altra maintains and applies employment data protection standards consistent with those specified in this Notice to its operations globally. In addition, Altra has entered into Standard Contractual Clauses (and, in some cases, certain other agreements) with each of its European affiliates in order to facilitate lawful transfers of personal data from the European Economic Area (EEA) to all third countries, including the United States, while providing sufficient protection for the privacy of individuals located within the EEA.

Security and Confidentiality

Altra employs technical and organizational safeguards designed to protect the integrity, confidentiality, security and availability of your Candidate Data, and to comply with applicable legal requirements for information security. Altra limits access to internal systems that hold your Candidate Data to individuals who need access in order for Altra to fulfill the purposes set forth in this Notice.

Candidate Rights

You may exercise the following rights in relation to your Candidate Data:

  • You may access and obtain a copy of your Candidate Data upon request;
  • You may require Altra to change incorrect or incomplete Candidate Data;
  • You may require Altra to restrict the processing of your Candidate Data;
  • You may require Altra to delete or stop processing your Candidate Data, for example when your Candidate Data is no longer necessary for purposes of processing (except where retention is required by any contractual relationship with Altra, in the context of a legal dispute, or as otherwise required by law);
  • You may object to the processing of your Candidate Data when Altra is relying on a legitimate interest as the legal ground for processing; and
  • You may request the receipt of your Candidate Data in a portable format.
If you wish to exercise any of these rights, or otherwise submit any inquiries or complaints regarding the processing of your Candidate Data, please send a request in writing to:

Altra-ApplicantDataPrivacy@altramotion.com

In addition, if you believe that Altra has not complied with your data protection rights, you have the right to file a complaint with the data protection authority of your home country.

Automated Decisions

Altra generally does not make recruiting or hiring decisions based solely on automated decision-making within the meaning of applicable EU data protection laws. In the event that Altra relies solely on automated decision-making that could have a significant impact on you, Altra will provide you an opportunity to express your views and will provide any other safeguards required by applicable law.

Acknowledgment and Consent

By making available your Candidate Data (as defined below), you confirm that:

  • You have reviewed this Notice and voluntarily and explicitly consent that Altra may process your Candidate Data in accordance with this Notice;
  • You have provided any notices and obtained any consents as may be required by applicable law to provide information concerning third parties (e.g., information about employment references); and
  • You voluntarily and explicitly consent that your Candidate Data may be transferred and processed worldwide, including in the United States and other countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Notice.
Altra will process Candidate Data in accordance with this Notice, unless in conflict with the requirements of applicable law, in which case applicable law will prevail.

Your consent to the provisions of this Notice is required in order to submit or make available Candidate Data. If you do not consent, and decline to submit or make available your Candidate Data, it may affect your ability to apply for or receive an offer of employment.

This Notice does not form a part of any contract for employment offered to candidates hired by Altra.