NEWELL BRANDS

PRIVACY STATEMENT FOR JOB APPLICANTS

Last modification: April 16, 2024 (v.3.0)

TOPICS:

  1. Introduction 
  2. Personal Information We Collect About You 
  3. How We Use Your Personal Information 
  4. Who Has Access to Your Personal Data 
  5. International Data Transfers 
  6. Personal Data Retention 
  7. Accessing & Correcting Your Personal Data 
  8. Cookies, Web Beacons & Other Tracking Technologies 
  9. For California Residents Only 
  10. Security of Your Personal Data 
  11. Data Controller & Data Protection Contact Information 
  12. Changes to this Applicant Privacy Statement 
  13. Updates to Policy

1. Introduction 

This Privacy Statement for Job Applicants is published by Newell Brands, Inc., or any of its affiliates (collectively “Newell Brands”, “we” or “us”) when acting as a Data Controller under relevant data protection rules and regulations. This Privacy Statement describes our privacy practices as required by the EU General Data Protection Regulation (“GDPR”), UK General Data Protection Regulation (“UK GDPR”), California Consumer Privacy Act (“CCPA”) and other applicable data protection laws (collectively “Privacy Laws”).  

By submitting your application or your resume, you acknowledge having read and understood this Privacy Statement. If you do not wish your information to be used as follows, please do not submit your application, your resume, or any personal data. 

This Privacy Statement sets out: 

  • which personal data we process in the course of the application and recruiting process; 
  • how we use your personal data; 
  • who has access to your personal data; 
  • whether we transfer your personal data to third countries; 
  • how long we keep your personal data; 
  • how you can access and modify the personal data we collect about you; 
  • how we secure your personal data; and 
  • how you can submit questions and remarks. 

      2. Personal Information We Collect About You 

      This Privacy Statement relates to all personal data that we receive from you and that we collect and process about you in the context of your application and the resulting recruitment process, including inclusion in our applicant database. 

      • To the extent permitted by applicable law, we may collect the following types of personal data: Name, address, email address, telephone number, and other contact information; 
      • Resume, CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information we request or that applicants provide to us in support of an application and/or the application and recruitment process; 
      • Information from interviews applicants may have with us, if any; 
      • Details of the type of employment applicants are looking for, current and/or desired salary and other terms relating to compensation and benefits packages, and job preferences; 
      • Details of how applicants heard about the position they are applying for; 
      • Any sensitive and/or demographic information obtained during the hiring process such as gender, information about citizenship and/or nationality, medical or health information, and/or racial or ethnic origin (express consent may be required for the collection and use of these types of personal data.  Newell Brands will obtain this consent as required by applicable law) 
      • Reference information and/or information received from background checks (as applicable), including information provided by third parties; 
      • Information relating to any previous applications applicants may have submitted to us and/or any previous employment history with us; 
      • Information about educational and professional background from publicly available sources (e.g., a LinkedIn profile) that we believe is relevant to an application; and 
      • Information collected automatically when applicants use our websites or our owned or licensed platforms through cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage. Please see the section Cookies and Similar Technologies for additional information. 
      • Information regarding your interest in receiving information about other job opportunities. You can activate additional recruiting emails by selectingHear More About Career Opportunitieswithin your candidate profile. By checking this box, you acknowledge you’ve read and accept the terms of our privacy statement  

          We may obtain personal data about applicants from various third-party and public sources, and we may combine that data with other information. For example, we may collect: 

          • information from recruiters or recruiting platform providers (such as LinkedIn, Phenom People, Inc., Oracle Corporation, Salesforce. Inc.); 
          • information from former employers regarding your past employment (including performance information); 
          • information from government agencies regarding your citizenship or eligibility to work in the country where an applicant would be employed; 
          • credit history and/or criminal record if applicants consent to a credit check or background check; 
          • information relating to your qualifications to work with us from your references; 
          • if permitted by law and relevant to the position you are applying for, we may request your drug test results from the third-party service provider we use to conduct applicant drug screening; and 
          • information from cookies and similar technologies, some of which may be considered personal data. For more information on our use of cookies and similar technologies, please review the “Cookies, web beacons and other tracking technologies” section. 

            If at any time you desire to exercise your applicable rights, please complete a Data Subject Access Request.

            3. How We Use Your Personal Information 

            Your personal data will be used in the context of your application and recruitment process, including for: 

            • To Manage the Application Process - We use applicant personal data to process job applications, to verify the information provided in applications, to communicate with applicants regarding their application, to answer applicant questions regarding the application process and to confirm eligibility for a position.  We may also save applicant personal data for future job openings as described below in our retention policy. 
            • To Manage the Hiring Process - We may use applicant personal data in the hiring process to conduct interviews.  If an applicant is offered a position, we may also use applicant personal data to perform background and reference checks with the applicant’s consent.  
            • To Communicate with You - We may use an applicant’s personal data to provide information to that applicant or to respond to that applicant’s questions.  
            • Recruiting - We may use applicant personal data to communicate with an applicant regarding the recruiting process, to learn where an applicant heard about us, and to evaluate and improve our recruiting process. 
            • For Performance Management - We use applicant personal data for internal performance improvement and to respond to complaints.  
            • Law Enforcement and Courts - We may disclose applicant personal data in response to a subpoena, a search warrant or other legally valid process. We may use applicant personal data to cooperate with law enforcement or other government entities if applicants are suspected of having violated applicable laws.   
            • Record Keeping - We may use applicant personal data to comply with applicable legally required or industry standard business and applicant record keeping requirements and to respond to governmental requests for information. 
            • Health and Safety - We may use applicant personal data to protect your health and safety, or the health and safety of others. We may use applicant personal data to protect our facilities and personal property. 
            • Protect Our Legal Rights - We may use applicant personal data to protect our legal rights, to defend a claim or lawsuit, and to investigate or prevent actual or suspected loss or harm to persons or property.   We may use applicant personal data to seek legal, accounting or other professional advice. We may use applicant personal data when reasonably necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of us, or any other party.   
            • Security - We may use applicant personal data to monitor the use of our information systems and electronic resources, to conduct internal audits or investigations and for safety and security of our employees, visitors and facilities.  We also may use such information to protect us against illegal activity and misconduct such as fraud, deceptive practices and data security incidents.  

                              We use personal data as described above and as stated or agreed to at the point of collection (or is obvious by the context and nature of the collection). To the extent required under applicable data protection laws, we only process personal data where we have a legal basis for doing so. Our legal bases for processing in relation to the purposes listed above may include consent, necessity for the performance of a contract, necessity for compliance with a legal obligation, or legitimate interest, as applicable and appropriate.  

                              If at any time you desire to exercise your applicable rights, please complete a Data Subject Access Request.

                              4. Who Has Access to Your Personal Data 

                              Your personal data is collected and processed by or on behalf of Newell Brands, in its capacity as a Data Controller. 

                              Newell Brands may make use of external service providers or third parties for any of the purposes described above (e.g., recruitment websites, agencies conducting background checks or talent management system providers). These processors may also include companies within the Newell Brands group that provide services on our behalf (e.g., IT services).  In such cases, processing of your personal data will be limited to the purposes described in this Privacy Statement, and in accordance with the requirements of the applicable data protection legislation. 

                              We also share your personal data with the following recipients, which act as independent controllers: 

                              • Newell Europe Sàrl, Chemin de Blandonnet 8 Vernier, 1214 Switzerland, and Newell Poland Services SP. Z O.O. Plac Andersa 7 Poznan, 61-894 Poland (both Newell Brands Group companies) in the context of centralized recruitment services. Within these two entities only specific staff members within the HR department have access to your personal data as well as technical staff members as far as this is necessary to ensure the proper functioning of their technical systems. 
                              • External consultants (e.g., lawyers and accountants); 
                              • Authorities; 
                              • Courts; and 
                              • Others as far as we are obliged to transfer your personal data or we received your respective consent. 

                              We may also use and disclose personal data in connection with the evaluation of a change of control of a Newell entity, such as in the event of a merger, acquisition, or sale of assets.  We may provide personal data both in connection with a due diligence process or it could be transferred as part of the change of control to subsequent owner(s).  If any of our entities (or our assets) are acquired or go out of business, enter bankruptcy, or go through some other change of control or reorganization, personal data and other information could be one of the assets transferred to or acquired by a third party, or reviewed as part of the due diligence process. 

                              If at any time you desire to exercise your applicable rights, please complete a Data Subject Access Request.

                              5. International Data Transfers 

                              We may transfer your personal data to third countries (countries outside the European Economic Area), for instance to our affiliate Newell Europe Sàrl located in Switzerland. Please note that the European Commission has affirmed an adequate level of data protection for Switzerland.  

                              In the event of transfer of your personal data to a country outside of the European Economic Area, Newell Brands systematically ensures the application of an adequate level of protection of such personal data by approved means (e.g., standard contractual clauses). You can request more information about such measures (including copies where relevant) by contacting us. 

                              6. Personal Data Retention 

                              The retention period of your personal data depends on the outcome of the application process. 

                              If your application is successful, your personal data obtained in the context of the application and recruitment procedure will be included in your personnel file. You will then be informed separately of how Newell Brands processes personal data of employees. 

                              If your application is unsuccessful, we will retain your personal data for a minimum of 4 weeks or for a maximum of 6 months, to be considered for other openings (as to Canada, APAC, EMEA and LATAM regions) or 2 years (as to US) after we have informed you about the rejection of your application. If you set up an applicant profile but did not apply for any jobs, we will retain your personal data for a minimum of 4 weeks or for a maximum of 6 months, to be considered for other openings (as to Canada, APAC, EMEA and LATAM) or 2 years (as to US) after you set up the profile. Depending on local laws, we may also retain your personal data through the application process plus any legally mandated period of time thereafter to respond to potential application-related inquiries or legal matters. Until such deletion, we will restrict the use of this data to the purpose of litigation management. In the event of any legal dispute, we will be obliged to store your personal data for the duration of the legal proceedings and afterwards in accordance with statutory retention periods up to 10 years or such shorter or longer period as is prescribed by local law. 

                              If you consent to your personal data being stored for a longer period so that we may contact you in relation to future suitable vacancies, we will store your personal data until we receive notice of your withdrawal of your consent or, in any case, for the maximum period of 6 months. If you would not like to be considered further for other positions, please let the relevant HR recruitment officer know. 

                              7. Accessing & Correcting Your Personal Data 

                              Depending on the jurisdiction in which you reside and the Privacy Laws applicable to your personal data, you may have the following rights, which may require a verified request to exercise: 

                              • Information and Access - You may request to access your personal data, receive supplemental information about your personal data, receive information on the public and private entities to whom your personal data has been provided, and/or be provided with a copy of your personal data. 
                              • Rectification - You may request to rectify and/or update your inaccurate or out-of-date personal data. 
                              • Erasure - You may have the right to have your personal data erased. 
                              • Restriction - You may have the right to restrict the processing of your personal data. 
                              • Object to Processing - You may have the right to object to specific types of processing of your personal data. 
                              • Data Portability - You may have the right to request a portable copy of your personal data. For example, Data Portability does not apply to paper records, and must not prejudice the rights of others, or sensitive company information. 
                              • Right not to be subject to decisions based solely Automated Decision Making - You may have the right not to be subject to decisions based solely on automated processing (i.e., without human intervention). 
                              • Right to lodge a complaint - You may have the right to lodge a complaint with a supervisory authority in the country where you reside, where you work, or where the potential infringement took place.   
                              • Right to Revoke ConsentYou may have the right to revoke previously provided consent related to your personal data 

                                  Newell Brands may charge a reasonable fee or reject your request if your request is not valid under applicable law, repetitive or excessive. We may also request information from you in order to verify your identity before you receive a response. Newell Brands may reject your request if your identity can’t be validated.  

                                  If you have any questions about your rights as it pertains to Newell Brands please contact us at: Data Privacy Enquiry or by using the contact information provided below.

                                  If at any time you desire to exercise your applicable rights, please complete a Data Subject Access Request.

                                  This Privacy Statement does not create, extend or modify any EU Data Subject rights, UK Data Subject rights, consumer rights under any US State law, or any other Newell Brands obligations, except as provided by applicable Privacy Law. 

                                  8. Cookies, Web Beacons & Other Tracking Technologies 

                                  Our websites, including those used in the application process, may use cookies and other similar technologies in accordance with applicable Privacy Laws. For additional information on our use of cookies, please see this Privacy Statement. 

                                  9. For California Residents Only  

                                  This section applies to our collection and use of applicant personal information of residents of California, as required by the California Consumer Privacy Act and its implementing regulations (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), where “personal information” has the definition set forth in the CCPA. This section describes (1) the categories of applicant personal information, collected and disclosed by us, subject to CCPA, (2) applicant privacy rights under CCPA, and (3) how to exercise such rights.  “Personal information” in this section has the definition set forth in the CCPA. 

                                  THIS SECTION ONLY APPLIES TO APPLICANTS WHO ARE RESIDENTS OF CALIFORNIA 

                                  In the event of a conflict between this section and the remainder of the Notice, this section shall control for California residents. 

                                  To receive a copy of this section in an alternate format (e.g., printable) or language, please contact us using the information provided below. 

                                  We Do Not Sell or Share Personal Information - In the last 12 months we do not believe that we have Sold or Shared applicant personal information and we do not believe we currently Sell or Share applicant personal information. “Sold” and “Shared” have the definitions set forth in the CCPA. 

                                  Use of Sensitive Personal Information - We do not believe we use or disclose sensitive personal information for purposes other than specified in the CCPA regulations, Section 7027, subsection (m).   

                                  Personal Information Collected - We make the following disclosures regarding the applicant personal information we have collected within the last 12 months: 

                                  We collect and process the personal information in each of these categories to facilitate our business purposes listed in the Section above titled “How We Use Your Personal Information”. 

                                  Category of Personal Information 

                                  Description or Explanation 

                                  Source Categories of Personal Information 

                                  Retention Period 

                                  Identifiers 

                                  Information that could identify a consumer or household, such as real name, IP addresses, or email address. 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA).  

                                  Internet or network activity 

                                  For example, information on interactions with websites, apps, or advertisement. 

                                  Applicant, cookies and related technologies 

                                  Varies depending on the type of cookie or technology collecting this Personal Information and logging requirements but no more than 2 years. 

                                  Professional/ employment-related information 

                                  For example, job applicants’ past job history. 

                                  Applicant, background check providers, former employers, recruiters, and your references. 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA). 

                                  Education information  

                                  Education information that is not publicly available identifiable information. 

                                  Applicant, background check providers, recruiters, and your references. 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA). 

                                  Geolocation data  

                                  Such as device location data.   

                                  Applicant, cookies and related technologies 

                                  Varies depending on the type of cookie or technology collecting this Personal Information and logging requirements but no more than 2 years. 

                                  Profile based on inferences from other categories  

                                  For example, a profile regarding characteristics or aptitude. 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA). 

                                  Protected Classification Characteristics 

                                  This information may be revealed in other collected data. 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA). 

                                  Personal Information  

                                  This category includes items described in Cal. Civ. Code § 1798.80(e), some of which overlap with other categories, such as a name or address 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA). 

                                  Sensitive Personal Information Collected - We make the following disclosures regarding the sensitive personal information we have collected within the last 12 months: 

                                  We collect and process the sensitive personal information in each of these categories to facilitate our business purposes listed in the Section above titled “How We Use Your Personal Information”. 

                                  Category of Personal Information 

                                  Description or Explanation 

                                  Source Categories of Personal Information 

                                  Retention Period 

                                  Sensitive identifiers  

                                  Such as a government issued id or number; social security number, passport number, state identification card number, or driver’s license number. 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA).  

                                  Sensitive associations or characteristics 

                                  Racial or ethnic origin, religious or philosophical beliefs, or union membership. 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA).  

                                  Health information 

                                  Personal information collected and analysed concerning an applicant’s health. 

                                  Applicant 

                                  Duration of application process plus 4 weeks for applicants in Canada, APAC, EMEA and LATAM regions or 2 years for applicants in the US. 

                                  If applicant chooses to be considered for future roles; duration of application process plus 6 months.  

                                  If the applicant is hired, the length of employment plus 7 years (6 years in EMEA).  

                                  We collect and process the sensitive personal information in each of these categories to facilitate our business purposes listed in the Section above titled “How We Use Your Personal Information”. 

                                  California Privacy Rights - Subject to certain exceptions as permitted under CCPA, California residents may have the following rights under the CCPA: 

                                  • Notice – You may have the right to be notified of what categories of personal information will be collected at or before the point of collection and the purposes for which they will be used and shared. 
                                  • Access – You may have the right to request the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You may also have the right to request the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information. 
                                  • Data Portability – You may have the right to receive the personal information you have previously provided to us. 
                                  • Erasure – You may have the right to have your personal information deleted. 
                                  • To Opt Out of Sale or Sharing – You may have the right to opt out of the sale or sharing of your personal information, but since we do not sell or share your personal information, this right does not apply to the personal information covered by this Privacy Statement. 
                                  • Limit use of Sensitive Personal Information - The right to limit the use of your sensitive personal information for any purpose other than what is specified in CCPA Regulations section 7027(m). 
                                  • Non-Discrimination - Businesses cannot deny goods or services, charge a different price, or provide a different level or quality of goods or services to those exercising their rights under the CCPA. However, if you refuse to provide your personal information to a business or ask it to delete or stop selling your personal information, and that personal information or sale is necessary for the business to provide you with goods or services, the business may not be able to complete that transaction. 

                                  If you are a resident of California and you would like to exercise rights you may have listed above, please send (or have your authorized agent send) contact us through the  Data Subject Access Request form or email at data.privacy@newellco.com or call the HR Service Delivery Team toll free at 1-877-467-4772. We will not discriminate against you in any way for your exercise of any CCPA rights. 

                                  We may need to verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification. We may deny certain requests, or only fulfil some in part, as permitted or required by law. For example, if you request to delete your personal information, we may retain such personal information that we need to retain for legal purposes (e.g., tax accounting).  

                                  The CCPA gives California residents the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276. 

                                  If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact using the Data Privacy Enquiry form.  

                                  10. Security of Your Personal Data 

                                  We have implemented appropriate and commercially reasonable organizational, technical and administrative safeguards to protect your personal data. You are responsible for maintaining the secrecy of any credentials that can be used to access any account or service with Newell Brands. If you should suspect any unauthorized activity, please report this to us immediately. You can report suspicious activity or other concerns by contacting us at:  1-877-467-4772. 

                                  11. Data Controller & Data Protection Contact Information 

                                  You can find a list and contact details of Newell Brands Data Controller entities and more information related to Supervisory Authorities, on the following page: Newell Brands Data Controllers and EU Supervisory Authorities. 

                                  Where the Newell Brands Data Controller is located outside of the EU/EEA/UK, the Controller's EU/UK Representative is specified on the Newell Brands Data Controllers and EU Supervisory Authorities page. 

                                  Newell's Data Protection Director may be contacted at: 

                                  Data Privacy Enquiry 

                                  Attn: Data Protection Director 
                                  6655 Peachtree Dunwoody Road 
                                  Atlanta, Georgia 30328 

                                  For more information on the full extent of your rights or to exercise your rights, please contact our Data Protection Director using the contact information above or the Data Privacy Enquiry form, or the lead supervisory authority for Newell Brands in the EU, namely The Director of the Personal Data Protection Office UODO of ul. Stawki 2, 00-193 Warsaw, Poland, www.uodo.gov.pl. 

                                  If at any time you desire to exercise your applicable rights, please complete a Data Subject Access Request.

                                  12. Changes to this Applicant Privacy Statement 

                                  This Applicant Privacy Statement may be updated on a regular basis. The most recent version is always available on this webpage. The date on which the current version was published, is included at the top of the document. Please check on a regular basis whether a new version has been published, as any changes will apply to your personal data as from the date of their publication.  We will notify you in advance of any material changes to this Applicant Privacy Statement. 

                                  13. Updates to Policy

                                  • April 16, 2024 – Clarified the minimum and maximum retention periods for EMEA, APAC, and LATAM