Recruitment Privacy Statement and Notice of Collection of Personal Data
NTT Ltd. and its subsidiaries globally (‘NTT’, ‘us’ and ‘we’) understand the importance of ensuring that we collect, use, store, disclose, share, and dispose of (collectively ‘use’) information about you (‘personal data’, including ‘personal information’ as it may be defined under applicable data protection laws and regulations) in a fair, open, secure, and lawful way. This Recruitment Privacy Statement and Notice of Collection of Personal Data (“Privacy Statement”) describes what personal data relating to you we hold, how we use it, and your choices and rights in relation to your personal data. This Privacy Statement applies to our use of personal data in relation to the NTT careers’ portal (https://careers.hello.global.ntt/global/en), recruitment processes, our global talent community, and other related initiatives.
Please note that any use of NTT’s websites, including any collection of personal data, other than in a recruitment context is subject to NTT’s Privacy Statement for Website located at [https://services.global.ntt/en-us/legal/privacy-statement].
We use your personal data in compliance with applicable data protection laws and regulations and Works Council Agreements (where applicable), based on the country in which you are seeking employment.
2. Legal basis for using your personal data
When we process your personal data in connection with the purposes set out in this 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 urposes of recruitment, 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 the protection of personal data;
- for the purposes of entering into an employment contract with you and/or performance and administration of your employment contract if you are employed by us;
- where this is necessary to comply with a legal obligation placed on us;
- to protect the vital interests of any individual;
- where you have provided your consent.
3. Collection, use, and disclosure of personal data
A. Personal data that we collect
Personal data is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. We will generally collect personal data from you directly when you apply for a position with us. However, we may also collect personal data about you from third parties, including third party recruitment agents, interviewers, prior employers, your identified referees, and employment screening and vetting service providers, as well as publicly available sources (such as LinkedIn), 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 employment laws, and data protection and 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 and your participation in NTT’s global talent community includes:
- your name, email address, telephone or mobile number;
- your CV, resume, or cover letter and any documents in support of your job application;
- details submitted by you through the NTT careers’ portal and by recruiters when searching for jobs, creating a profile, and registering for job alerts with NTT;
- identification information, such as proof of identity;
- current and previous employment information (including salary, bonus, benefits and allowances), where permitted;
- references from your nominated referees and/or your previous employers;
- educational qualifications and achievements;
- results of any pre-employment testing such as skills testing (where required) and psychometric testing (where permitted and required);
- interview notes and video interviews;
- nationality, immigration status, passport, and work permits;
- veteran status;
- job preferences such as willingness to travel and/or relocate;
- information obtained from background checks, where permitted;
- information relating to any previous job applications you have made to us and/or any previous employment with NTT, where this information is retained by NTT;
- authentication information (including username and password) for the NTT careers’ portal;
- contact preferences;
- participation in our global talent community, where you have provided your consent;
- cookie preferences.
We require certain information about you to support our recruitment process (‘mandatory information’). If this information is not provided, our ability to consider you as a candidate may be limited.
B. Sensitive personal data that we collect
We do not usually request or require you to share sensitive or special category personal data regarding your race, gender, sexual orientation, ethnicity, religion, political opinions or beliefs, membership of a trade union or political affiliation, physical or mental healthinformation, information related to criminal convictions or offences (‘sensitive personal data’) in connection with your job application unless required to do so to comply with applicable laws or with your consent. To the extent that you provide us with sensitive personal data, you expressly authorize us to handle such information in accordance with this Privacy Statement.
If you have a disability and would like to disclose your disability as part of requesting any reasonable accommodations should you be employed by NTT, you may provide that information during the recruitment process on a voluntary basis.
Where permitted by applicable laws, we may also ask for information such as race, ethnicity, or gender for the purposes of monitoring equal opportunity and complying with regulatory reporting. However, for the purposes of your application this information is voluntary.
We do not collect or process sensitive personal data for the purpose of inferring characteristics about you. We also do not collect sensitive personal data for any purposes other than those described in this Privacy Statement.
C. How we collect your personal data
We may collect your personal data from you in a variety of ways, including:
- directly from you when you register on the NTT careers’ portal or apply for a role with us;
- publicly available databases;
- social networking sites (such as LinkedIn), including when you include a link to your profile on any social networking site as part of your job application;
- third parties, including recruiters and placement firms, outsourcing providers, nominated references, previous employers; referees, and psychometric and background screening service providers;
- NTT companies where you have previously been employed or applied for a role.
D. Use of your personal data
All personal data may be used for the purposes stated in this Privacy Statement.
We may use your personal data to:
- identify and contact you throughout the recruitment process;
- enable our personnel to search our internal global talent databases to help us identify suitable candidates for new or current job vacancies;
- inform you about current or potential job opportunities offered by us that match your interests, experience, and qualifications and enquire if you would like to apply and be considered for these;
- 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);
- analyze our applicant pool in order to better understand who is applying for roles at NTT and how to attract top talent;
- record online interviews for review by recruiters and hiring managers if you expressly agree to being recorded;
- opt-you-in to our global talent database that you may 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;
- administration, authentication and access management of our NTT career’s portal;
- assist in the administration of our global recruitment program and recruitment campaign planning.
We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.
E. Disclosing 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 or your participation in our global talent community. We may disclose your personal data for any of the purposes set out in this Privacy Statement with:
- authorized NTT personnel including human resources 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 disclose your personal data to us or with whom we are required to disclose your personal data for legitimate reasons;
- agents and professional advisers of NTT;
- authorized third party service providers providing services to NTT, including placement firms, recruiters and other service providers;
- authorized personnel of third parties 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;
- third parties to provide references at your request or with your consent;
- third parties 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;
- a competent authority in accordance with, or as required by any applicable law, regulation or legal process;
- third parties where necessary to comply with judicial proceedings, court orders or government orders;
- third parties to protect the rights, property or safety of NTT, our business partners, you, or others, or as otherwise required by applicable law.
i. Data sold or shared
We do not sell or share personal data about job applicants and candidates as defined by the California Privacy Rights Act.
ii. Data disclosed for a business purpose
We have disclosed the following categories of personal data about job applicants and candidates for a business or commercial purposes:
- personal information and references to verify identity and confirm references.
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.
4. Security of your personal data
We are committed to protecting your personal data from accidental or unlawful destruction, loss, or alteration, and 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.
5. Retaining your personal data
We will retain your personal data for as long as is reasonably necessary and proportionate to fulfil the purpose for which it was collected, processed, or for another disclosed purpose, unless a longer retention period is required to comply with legal obligations, resolve disputes, protect our assets, or enforce our rights. 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 our employee, 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 after your employment ceases (in accordance with country specific privacy laws).
If we don’t employ you, we may retain and use personal data collected during your application in accordance with our retention policies and schedules and applicable country specific laws and regulations:
- to consider you for new and current job opportunities;
- for system administration;
- to perform research and analysis; and
- to invite you to join our global talent community. 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 community.
Thereafter, we retain the minimum amount of your personal data necessary to record your recruiting interactions with us and, where possible, deidentify your personal data so that you can no longer be identified for the purposes of statistical reporting.
In some instances, we may anonymize your information in accordance with our policies and may keep those anonymized records for longer periods.
6. Your privacy rights
Data protection laws and regulations, in certain countries, provide you with specific rights in relation to your personal data. We are committed to upholding the following privacy rights:
- Right to be informed / know: you have a right to know what personal data, including the types of sensitive personal data, we have about you, what we do with it, where we get it from, who we disclose it to and share it with, how long we keep it and why we need it.
- Right of access: you have the right to access your personal data and obtain a copy of your personal data from us.
- Right to correct: you have the right to update inaccurate and/or incomplete personal data about you. We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion of your personal data.
- Right to delete: you have the right to have your personal data erased, deleted or destroyed (i.e. right to be forgotten).
- Right to data portability: you have the right to move, copy or transfer your personal data in a safe and secure way and reuse it for your own purposes.
- Right to withdraw consent: you have the right to withdraw consent at any time regarding the use of your personal data (where applicable) or in relation to direct marketing activities.
- Right to restrict use: you have the right to limit the way we use your personal data.
- Right to object: you have the right to stop or prevent us from using your personal data. In particular, you can object to our use of your personal data for direct marketing or the sale of your personal data.
- Right to challenge automated decisions: you have the right to query and review decisions made about you using purely automated means (i.e. without human involvement or intervention).
- Right to complain: you have the right to make a complaint or raise a concern about how we use your personal data. Complaints may be made directly to us or a relevant Data Protection Authority.
- Right to non-discrimination: you have the right not to be discriminated against for exercising your privacy rights.
You may submit a request to enforce your rights at any time.
You can make a request regarding your privacy rights by contacting us through the following ways:
- Webform: Click here to access our privacy rights webform
- Email Address: email@example.com
- Phone Number: 1-888-914-9661 Access code: 111342
When you submit a request to us, you must provide sufficient information to allow us to verify that you are the person about whom the personal data relates. This information must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.
Once we receive your request, we will begin the process to verify that you are the person that is the subject of the request. This may include matching identifying information provided by you with the information we have about you in our records.
Where permitted under applicable law, we may charge you a reasonable fee to access your personal data; however, we will advise you of any fee in advance.
NTT responds to all requests and complaints in accordance with our Data Subject Rights Policy and will acknowledge any requests within 10 days and respond substantively within 30 days.
We will retain correspondence, documents and information related to any requests or complaints for a period of 24 months or as required by any applicable laws and regulations.
In some situations, we may not be required to enforce these rights under applicable law and where exceptions may apply. We may also have a legitimate business interest to decline a request to action your rights. These exceptions to your rights may include our right to maintain personal data of job applicants and candidates for business purposes and solely internal uses reasonably aligned with the expectations as a job applicant or candidate, as well as to comply with any legal obligations, including maintaining proper records, or maintaining privilege or confidentiality of certain records, in compliance with applicable laws and regulations. We will inform you of our decision to deny or grant your request and of any other action we have taken to respond to your request and enforce your rights.
7. Authorized agent information
You may designate an authorized agent to make a request on your behalf. When your authorized agent makes a request related to your personal data, we will require the agent to provide written permission from you. We may also require that you verify your own identity directly with us at the time such a request is made. You or your authorized agent may contact us with requests, complaints, or questions regarding these rights by contacting us in accordance with the “How to contact us” section, below.
8. How we use automated decision-making
Automated decision-making refers to any time that we apply an algorithm or use artificial intelligence or related technologies to make a decision about you without human intervention.
We do not make any decisions about you using automated means, however, should our position change in this regard, we will update this Privacy Statement and inform you of your rights in accordance with relevant laws and regulations.
9. Cross border transfers
As a global company operating in over 70 countries worldwide, we may transfer your personal data to countries where we do business or to international organizations in connection with the purposes identified above and in accordance with this Privacy Statement.
As a global employer, your personal data may be accessed by authorized NTT personnel, authorized service providers, and recruiters, and other stakeholders as identified in this Privacy Statement, both in the country where the position for which you are applying is based, as well as different countries in which NTT operates in connection with the purposes identified in and in accordance with this Privacy Statement.
When we transfer your personal data outside of the country from where it was originally collected to a third country or international organization, we ensure that appropriate safeguards are in place, in line with applicable law, to ensure that your personal data is protected. You may obtain a copy of these safeguards by contacting us in accordance with the “How to contact us” section below.
10. Cookies and similar technologies
The NTT careers’ portal may request cookies to be set on your device. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to Personally Identifiable Information you submit while on this career site.
11. Links to third party websites and applications
The NTT careers’ portal may contain links to other NTT career sites. Your use of our other NTT career sites is subject to the privacy statements governing those sites.
12. Children’s privacy
We encourage parents and guardians to take an active role in their children’s activities. We do not knowingly collect information about children without appropriate parental or guardian consent. If you believe that we may have collected personal data about someone who is under the applicable age of consent in your country without proper consent, please contact us by sending an email to firstname.lastname@example.org
13.Updates to this Privacy Statement
We may update this Privacy Statement at any time for any reason. If we do, we will update the “Last Updated” information at the top of this Privacy Statement and will notify you of such changes by posting the revised statement on this page.
We encourage you to regularly review this Privacy Statement to stay informed about our privacy practices and whenever you submit personal data to us.
14. How to contact us
If you have any questions about how we use your personal data, have a privacy concern, or wish to make a request or complaint relating to your personal data, you may contact us through the following ways:
Last Updated: 10 May 2023