Recruitment privacy statement

1. Introduction

NTT Ltd and its direct and indirect affiliates and subsidiaries (collectively “NTT Ltd” “us” and “we”) understand the importance of protecting your personal data i.e. any information that identifies you as an individual or relates to you as an identifiable individual.

This Recruitment Privacy Statement describes how NTT Ltd collects and uses your personal data in connection with NTT Ltd.’s recruitment processes and programmes, and your choices and rights in relation to your personal data.

2. Personal data that we collect

We will generally collect personal data from you directly when you apply for a position with us or with our affiliate or subsidiary companies via us. However, we may also collect personal data about you from third parties, including third party recruiters, interviewers, prior employers, your referees, and employment background check providers, as well as from publicly available sources, to the extent permitted by applicable law.

The types of personal data that we collect about you and how that personal data is collected and accessed will depend on the privacy laws of the country in which the position you apply for is located.

Personal data that we may collect either directly or indirectly during the recruitment process includes:

• your name, email address, telephone number and postal address;
• your CV/resume/cover letter and any documents in support of your job application, or as part of the recruitment process;
• details submitted by you through our websites (including the websites of our affiliate and/or subsidiary companies), or job searches and recruiter websites (the “Sites”), for example, when you search for jobs, create a profile, or register for job alerts;
• current and previous employment information (including salary, bonus and benefits);
• information obtained from your referees and/or your previous employers;
• educational qualifications and achievements;
• results of any pre-employment testing such as psychometric testing;
• information obtained from any interviews with you;
• immigration status and work permits;
• job preferences such as willingness to travel and/or to relocate;
• information obtained from background checks;
• information relating to any previous job applications you have made to NTT Ltd and/or any previous employment with NTT Ltd;
• information obtained from our affiliate or subsidiary companies that you have applied to and/or which you may have been previously employed by;
• information obtained from third parties, including third party placement firms or recruiters.

We will not collect or process sensitive personal data about you such as ethnicity, health information, trade union membership, philosophical beliefs or sexual orientation, unless required to do so to comply with applicable laws or with your explicit consent.

You are not required to provide any information that we request to us, but if you do not do so and this is necessary to continue with your application for employment, we may be unable to do so.

3. How we collect your personal data

We may collect your personal data from you in a variety of ways, including:

• directly from you;
• when your personal data is submitted through the Sites;
• from publicly available databases;
• from social networking sites, including when you include a link to your profile on any social networking site as part of your job application;
• from third parties, including recruiters and background checking providers.

When you use the Sites, we may, and third parties we engage may automatically collect data, including personal data through use of cookies and similar technologies. For more information, see the "Cookies and Similar Technologies" section below.

4. Legal basis for processing your personal data

When we process your personal data in connection with the purposes set out in this Recruitment Privacy Statement, we may rely on one or more of the following legal bases, depending on the purpose for which the processing activity is undertaken:

• our legitimate interests as a global employer, or those of a third party, including for the purposes of human resources management, managing our interactions with you, and record keeping in relation to recruiting and hiring; except where our interests are overridden by your interests or fundamental rights or freedoms which require protection of personal data;
• for the performance of your employment contract if you are employed by us;
• where this is necessary to comply with a legal obligation on us;
• to protect the vital interests of any individual;
• where you have consented.

5. Use of your personal data

We may use your personal data to:

• identify and contact you throughout the recruitment process;
• enable our personnel to search our internal databases to help us fill job vacancies;
• inform you about current or potential job opportunities offered by us if you request this information;
• determine your suitability for current job opportunities with us;
• process your job application, and if successful, your details of your employment with us;
• check information provided by you, or third parties including qualifications and references;
• perform administrative functions (e.g. keeping records in relation to recruiting and hiring);
• analyse our applicant pool in order to better understand who is applying for roles at NTT Ltd and how to attract top talent;
• record online interviews for review by recruiters and hiring managers if you expressly agree to being recorded;
• enter you into our database to receive future alerts about our job vacancies and events where you have registered to do so.
• comply with applicable laws and regulations;
• conduct or defend legal proceedings;
• improve our recruitment and hiring processes;
• assist in the administration of our global recruitment program and recruitment campaign planning.

If you are employed by NTT Ltd, we may use your personal data to:

• verify your identity and details, right to work, employment history, academic qualifications and professional skills;
• carry out background checks, including criminal record checks (where permitted by law),
• process your employment details;
• assist you with obtaining work visas and permits.

6. Sharing your personal data

As a global employer, people in different countries may be involved in the processing of your personal data as part of the recruitment process. We may share your personal data for any of the purposes set out in this Recruitment Privacy Statement (as applicable) with:

• authorized NTT Ltd personnel including HR personnel such as hiring managers, other interviewers, and IT and administrative support staff;
• authorized personnel of our affiliate and/or subsidiary companies who are required to share your personal data with us or with whom we are required to share your personal data for legitimate reasons;
• agents and professional advisers of NTT Ltd;
• third party service providers providing services to NTT Ltd, including placement firms and recruiters;
• authorized personnel of third party suppliers including companies who perform background checks. These companies may be based in another country to where your personal data is collected, and may obtain data from other countries where you have lived, worked or studied;
• auditors and investigators in connection with internal and external audits and investigations;
• our affiliates and subsidiaries. NTT Ltd is the party responsible for the management of jointly used personal data.
• to third parties to provide references at your request or with your consent, where you consent to the sharing of your personal data;
• in connection with any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;
• in response to a request for information by a competent authority in accordance with, or required by any applicable law, regulation or legal process;
• where necessary to comply with judicial proceedings, court orders or government orders;
• to protect the rights, property or safety of NTT Ltd, its business partners, you, or others, or as otherwise required by applicable law.

Any third parties who process personal data on our behalf are contractually required to implement appropriate data protection and security measures to protect personal data and are not permitted to use personal data for any purpose other than the purpose for which they are provided with or given access to personal data.

7. Security of your personal data

NTT Ltd is committed to protecting your personal data from accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring that third parties to whom we disclose your personal data do the same.

8. Cross border transfers

As a global employer, your personal data may be accessed by authorized NTT Ltd personnel, recruiters and interviewers both in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within NTT Ltd in connection with the purposes identified above and in accordance with this Recruitment Privacy Statement. As mentioned above, your personal data may also be accessed by authorized personnel of NTT Ltd.’s affiliate and/or subsidiary companies, in connection with the purposes identified above, and in accordance with this Recruitment Privacy Statement or that affiliate or subsidiary’s recruitment privacy statement.

For individuals in the European Economic Area (the "EEA") or Switzerland - where we transfer your personal data from a location within the EEA or Switzerland to a country outside the EEA or Switzerland and that country does not provide a level of protection for personal data which the European Commission (“Commission”) deems adequate, we use and adhere to the standard contractual clauses (“SCCs”) approved by the Commission, to legitimately transfer personal data. You may obtain a copy of these measures by contacting us in accordance with the “How to contact us” section below.

9. Your rights under data protection laws in the EEA

NTT Ltd adheres to applicable data protection laws in the EEA, which provide you with certain rights relating to your personal data (if you are an EU individual), subject to any legal exceptions. Your rights include:

• the right to access personal data that we hold about you;
• the right to rectify inaccurate personal data we hold about you without undue delay, and taking into account the purposes of the processing, to have incomplete personal data about you completed;
• the right to ask us to erase your personal data (the right to be forgotten) without undue delay in certain circumstances;
• the right to restrict the processing of your personal data in certain circumstances;
• the right to receive your personal data from us in a structured, commonly used and machine readable format and to transmit your personal data to a third party without obstruction (right to data portability) in certain circumstances; where we process personal data based on your consent, you have the right to withdraw your consent at any time for future processing;
• where we process your personal data based upon our legitimate interests or those of a third party, you have the right to object to the processing of your personal data at any time (including to any profiling);
• where we process your personal data for direct marketing purposes, you have the right to object to processing of your personal data at any time, including profiling to the extent that it is related to such direct marketing;
• the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You may lodge a complaint with a data protection supervisory authority if you believe that your data protection rights relating to your personal data have been breached by NTT Ltd or that your personal data has been compromised in some way. A list of data protection authorities is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

You may contact us with requests, complaints or questions regarding these rights as set forth in the “How to contact us” section, below.

Similarly, individuals in countries outside of the EEA and Switzerland may exercise their rights under any applicable data protection laws by contacting us in accordance with the “How to contact us” section, below.

10. Cookies and Similar Technologies

When you access NTT Ltd.’s websites, we use cookies (small text files containing a unique ID number which are placed on your PC or device) and similar technologies including scripts, embedded web links, web beacons, Local Shared Objects (flash cookies) and Local Storage (HTML 5). We use cookies to assist us with:

• enabling you to sign in to our websites;
• authenticating you;
• keeping track of information you have provided to us;
• improving your browsing experience;
• customizing our interactions with you;
• storing and managing your preferences and settings;
• compiling statistical data;
• analysing the performance and usability of our Sites;
• measuring Site traffic patterns; and
• determining which areas of our Sites have been visited.

These technologies collect information that your browser sends to our Sites including your browser type, information about your IP address (a unique identifier assigned to your computer or device which allows your PC or device to communicate over the Internet), together with the date, time and duration of your visit, the pages you view and the links you click.

Our Sites may also contain web beacons or similar technologies from third party analytics providers, through which they collect information about your online activities across our sites to help us compile aggregated statistics.

For more information on how we use cookies and other technologies, please see our cookies policy which you can find on our website.

11. Links to third party websites and applications

Our Sites may contain links to our affiliate or subsidiary websites or third party websites and applications. We are not responsible for and make no representations or warranties in relation to the privacy practices or content of any such websites and applications. Your use of such sites and applications is subject to the party privacy statement governing that site or application and your use is at your own risk.

12. Retaining your personal data

We will retain your personal data for as long as is necessary to fulfil the purpose for which it was collected unless a longer retention period is required to comply with legal obligations, resolve disputes, protect our assets, or enforce agreements. The criteria we use to determine retention periods include whether:

• we are under a legal, contractual or other obligation to retain personal data, or as part of an investigation or for litigation purposes;
• personal data is needed to maintain accurate business and financial records;
• there are automated means to enable you to access and delete your personal data at any time;
• the personal data is sensitive personal data in which event we will generally retain this for a shorter period of time;
• you have consented to us retaining your personal data for a longer retention period, in which case, we will retain personal data in line with your consent.

If you become an employee of NTT Ltd, personal data collected during the recruitment process will become part of your employee record, which we will retain during your employment and for a period (in accordance with country specific privacy laws) after your employment with NTT Ltd ceases.

If we don’t employ you, we may retain and use personal data collected during your application for a period of 12 months from the last communication to you (or some other period as prescribed by country specific privacy laws):

• to consider you for new positions;
• for system administration;
• to perform research and analysis; and
• to invite you to join NTT Ltd.’s talent network. If you choose not to, we will record that fact and will only retain the minimum personal data necessary to ensure that we do not contact you again about the talent network.

Thereafter, we retain the minimum amount of your personal data necessary to record your recruiting interactions with us.

13. Updates to this Recruitment Privacy Statement

We may update this Recruitment Privacy Statement at any time. If we do, we will update the “last modified” section at the bottom of this Recruitment Privacy Statement.

We encourage you to regularly review this Recruitment Privacy Statement to stay informed about our privacy practices.

14. How to contact us

If you have any questions about how your personal data is handled by NTT Ltd, you have a privacy concern or you wish to make a request or a complaint relating to your personal data, please contact the Group Legal Department by using the following email address: privacyoffice@global.ntt

Last modified: 21 November 2022