Application Privacy Notice
Applicant Privacy Notice
Effective Date: September 11, 2023
This Applicant Privacy Notice (“Notice”) applies to Millennium Print Group, 10900 World Trade Blvd. Raleigh, NC 27617, USA (MPG), and describes how MPG collects, processes, and discloses personal data from you through the MPG Careers website (“Site”) and/or through other means during your application process or while attending one of our recruiting events.
This Notice does not form part of any offer of employment or any contract of employment and does not provide any contractual right on you or place a contractual obligation on MPG. This Notice also does not cover use of personal data collected about you in the course of your employment with MPG, if you ultimately accept employment with MPG. To learn more about MPG’s data collection practices that cover MPG’s collection and use of your personal data as an employee of MPG, please contact Human Resources for a copy of the Employee Privacy Notice.
Collection of Personal Data
For purposes of this Notice, “personal data” or “personal information” means any information about an identifiable individual collected in connection with the recruitment process and the Site. MPG may collect personal data directly from you, as you apply for a job opening, or may receive personal data from third parties—for example, in connection with a background, employment, or reference check—subject to your consent where required by law. Personal data excludes anonymous or de-identified data that is not associated with or reasonably linkable to a particular individual. We may collect, store, and process the following categories of personal data, some of which we require in connection with our recruiting activities:
- Contact Details and Identifiers: such as name, title, addresses, telephone numbers, and personal email addresses.
 - Internet or other electronic network activity information: such as internet protocol (IP) address, online identifier(s), browsing history, search history, and information regarding yours interaction with an internet website, social media site or application
 - Visual and Audio: such as photos and security video recordings.
 - Demographic Data: may include date of birth, gender, marital status, military or veteran status, spouse and dependents, and certain sensitive data categories as described in the “Collection and Use of Special Categories of Personal Data” section below.
 - Professional and Educational Background: such as your educational details and records, work history, certifications, language capabilities, credit and criminal history background checks, and other relevant experience, qualifications, and recommendations, including information contained in a resume, CV, cover letter, or job application.
 - Work Eligibility Status: such as immigration, residency, official government documents, and related information.
 - Benefits Information: such as information for determining benefits and cost estimation (which may require personal data similar to that in “Demographic Data” above).
 - Social Media: such as public profiles, posts, likes, and replies.
 - Information related to previous applications to MPG or previous employment history with us.
 - Other Information: such information as is necessary for a legitimate human resources, business, security, or safety-related purpose.
 - Inferences: inferences drawn from information in other categories.
 
Failure to provide or allow us to process some of the personal data may affect our ability to accomplish the purposes stated in this Notice.
We utilize a third-party applicant tracking system that collects your information when you visit their site to submit your application to us. For more information, please see their privacy policy (https://www.greenhouse.com/privacy-policy).
Collection and Use of Special Categories of Personal Data
The following special categories of personal data may be considered sensitive under the laws of your jurisdiction and may receive special protection: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health; data concerning sex life or sexual orientation; and data relating to criminal convictions or offenses.
We may collect and process the following special categories of personal data when you voluntarily provide them, or when we receive them from a third party with your consent, when relevant for a particular job position to carry out our obligations under employment law, or as applicable law otherwise permits:
- Physical or mental health condition or disability status to determine appropriate accommodations and evaluate fitness for a particular job position.
 - Race or ethnic origin to comply with statutory obligations.
 - Previous criminal charges or convictions where relevant for the job position.
 
Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will do so only after providing you with notice and, if required by law, obtaining your prior, express consent. We will always treat special categories of data as confidential and such information will only be shared where there is a specific and legitimate purpose to do so and will be subject to appropriate physical, technical, and organizational security measures.
Sources of Personal Data
MPG primarily collects your personal data directly from you. However, MPG may also collect personal data from a variety of third-party sources, including as follows:
- Service providers (e.g., hiring, recruiting service providers, aptitude testing, and applicant tracking systems)
 - Automatically collected electronic information (e.g., information such as IP address, device ID, and browsing activity when you visit the Site).
 - Insurance and benefits providers
 - Background check services
 - Online sources including social networks (e.g., LinkedIn, Facebook, twitter, etc.)
 - Open government databases and other public sources
 
Use of Personal Data and the Legal Bases
We process your personal data only where applicable law permits or requires it in connection with carrying out our application, recruitment, and hiring process, including for human resource purposes; and for purposes related to operations and business, security, and safety; and to take steps necessary to enter into an employment contract with you. We may process your personal data for the following legitimate business purposes under the legal basis to do so.
Entering Into a Contract with You:
- Contact Details and Identifiers; Demographic Data; Professional and Educational Background; Work Eligibility Status; Benefits Information; Social Media; Previous Applications; Other Information; Inferences: used for identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the job position you have applied for or other job positions you may be considered for.
 - Contact Details and Identifiers; Demographic Data; Professional and Educational Background; Work Eligibility Status; Benefits Information; Social Media; Previous Applications; Other Information; Inferences: used for verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
 - Contact Details and Identifiers: used for communicating with you about the recruitment process and your application.
 - Contact Details and Identifiers; Other Information: used for reimbursement of costs made by you for which you are eligible to receive reimbursement.
 - Contact Details and Identifiers; Demographic Data; Work Eligibility Status: used for assisting you with obtaining an immigration visa or work permit where required.
 
Legitimate Interests:
- Contact Details and Identifiers; Professional and Educational Background; Benefits Information; Previous Applications; Demographic Data; Inferences: used as permitted by applicable law, verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job position.
 - Contact Details and Identifiers: used to send you job opening alerts informing you of other potential career opportunities at MPG, newsletters, and information regarding upcoming events that we believe will be of interest to you. As part of these communications, we will include an unsubscribe link that you can use if you don’t want us to send messages in the future.
 - Contact Details and Identifiers; Social Media: used to register you for MPG recruitment events (if applicable).
 - Professional and Background; Benefits Information; Previous Applications; Inferences: used for keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
 - Other Information: used for creating and submitting reports as required by applicable laws or regulations.
 - Demographic Data; Internet Activity, Other Information; Inferences: used for analyzing and improving our application and recruitment process.
 - Contact Details and Identifiers; Internet Activity; Professional Background; Visual and Audio; Other Information; Inferences: used to prevent fraud.
 - Internet Activity; Other Information; Inferences: used to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
 - Contact Details and Identifiers; Visual and Audio; Inferences: used to manage monitor, protect and improve office space, facilities, catering, including monitoring and administering building occupancy, physical security systems such as CCTV, guest logs; exit and entry times and emergency services notification.
 
Compliance with Legal Obligations:
- Professional and Background; Demographic Data; Visual and Audio; Benefits Information; Inferences: used to comply with our legal, regulatory, or other corporate governance requirements.
 
We will process your personal data only for the purposes we collected it for, or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
Sharing of Personal Data
We will disclose your personal data to third parties only as described in this Notice or where required by law, or to our employees, subsidiaries, affiliated companies, contractors, designated agents, or third-party service providers who require such information to assist us with administering our application, recruitment, and hiring process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including but not limited to: obtaining employment verification and background checks, assisting with travel arrangements, reimbursement of interview expenses, conducting audits, data storage or hosting, and other similar human resources functions. These third-party service providers may be located outside of the country in which you live or the country where the job position you have applied for is located.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
- Compelled Disclosures: MPG may be required to release personal information in response to a legal obligation or legal process. Such obligations may include lawful requests by public authorities, including to meet national security and law enforcement requirements. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we disclose only the minimum personal data necessary for the specific purpose and circumstances to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders.
 - We will also access, transfer, disclose, and preserve personal data when we believe that doing so is necessary to:
 - operate and maintain the security of our computer systems and networks, including to prevent or stop an attack on our computer systems or networks;
 - protect the rights and property of MPG; and
 - act in urgent or emergency circumstances such as protecting the health or safety of a candidate, employee, agent, customer, or member of the public.
 - Where the personal data is publicly available.
 - Analytical Purposes: in aggregate form and/or a form that does not identify an individual; for example, demographic profiling or industry analysis.
 - If a business transfer, corporate transaction, change in ownership, or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or transfer, divestiture, or sale of business or assets occurs and the disclosure is a part of the transaction.
 - For additional purposes with your consent, where such consent is required by law.
 
Cross-Border Data Transfers
Personal data as described in this Notice may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries that are part of the European Economic Area (EEA) or the United Kingdom (UK).
MPG will only transfer your personal information outside of the EEA, UK, and Switzerland to a country lacking adequate protection for your personal information under applicable data protection law by using a variety of legal mechanisms, including contracts and standard contractual clauses / model clauses, so that your rights and protections travel with your data. The standard contractual clauses approved by the European Union (EU) Commission are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
Data Security
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties who have a legitimate business need for such access.
Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will retain your personal data only as long as necessary to fulfill the purposes we collected it for (between 1 and 3 years depending on jurisdiction), as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. Please contact us using the details below if you require further information.
We have the right to delete application information at any time, and you may want to retain copies of any information, including resumes/CVs that you provide to us during the application process.
Under some circumstances, we may anonymize your personal data so it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If you are offered and accept employment: The personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies.
If you are not offered employment and do not become an employee: The personal data collected during the application and/or recruitment process will be retained to consider you for other jobs. Additionally, MPG may refer back to personal data collected earlier in the event you submit a new application in the future. MPG will retain your personal data as documented in our corporate data retention schedule unless otherwise required by law.
For United Kingdom (UK), European Economic Area (EEA), or Switzerland Applicants - Your Choices and Rights
If you are a UK, EEA or Swiss data subject, you have the following rights:
- A right to be informed of the ways in which we use your information.
 - A right to request from MPG access to personal data, including (i) the categories and specific pieces of information we have collected about you, (ii) the categories of sources collected, (iii) the purpose for collecting or using the information, and (iv) the third parties with whom we share your personal information; and rectification or deletion/erasure of personal information under certain circumstances and subject to a number of exceptions; and certain rights to data portability.
 - A right to object to the processing of your personal data or to obtain a restriction of such processing under certain circumstances.
 - A right to not be subject to a decision based solely on automated processing.
 - A right to have your personal data transferred to another organization should it be technically feasible for MPG to do so.
 - If the processing of personal data is based on your consent, a right to withdraw consent at any time (without affecting the lawfulness of processing before its withdrawal).
 - A right to bring your complaint to a regulator. If you are based in the EEA and believe that we have not complied with data protection laws, you can complain to our regulator, the UK Information Commissioner’s Office, or your local supervisory authority; however, regardless of where you are based, we would appreciate it if you would give MPG the chance to deal with your concerns directly by contacting us.
 
There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, we will provide that explanation. To make any of the requests in this section, please contact MPG using the information in the “Contact Us” section below.
If you submit a request, we will require you to verify your identity either by making the request through an existing account and/or by providing a form of governmental identification, where, if feasible, we may match your identification information with personal data we have about you, depending on the type of request made and verification measures proportional to the risk of the personal data involved with the request(s). There is no reasonable method by which we can verify your identity to the degree of certainty required by law for certain pieces of personal data, for example: unique identifiers such as cookie IDs, device ID, and IP address (where that information is not held by us in connection with directly identifiable information). MPG will use reasonable efforts to fulfill your request within the response times of the applicable laws.
For California-Resident Applicants - Your Choices and Rights
This section provides supplemental information to California-resident Applicants.
We collect, use, and disclose the following categories of personal data as described above. This includes: identifiers; personal records (such as education); characteristics of protected classifications (e.g., marital status, gender identity); internet or other electronic network activity information (e.g., browsing history, search history, and information regarding your interactions with our websites or applications); audio, electronic, visual, or similar information (e.g., CCTV, audio and video recording of job interviews); professional or employment-related information; and inferences drawn from your personal information.
We do not:
- sell your personal information (for monetary or non-monetary value);
 - share or disclose your personal information for cross-context behavioral advertising;
 - collect your “sensitive personal information” for the purposes of inferring characteristics about you, and as such, we treat any such information as “personal information” consistent with applicable provisions of the CCPA; or
 - have any knowledge that we “sell” or “share” personal information collected from you pertaining to individuals under 16 years of age (such as your dependents) as those terms are defined under the CCPA.
 
We collect and use your personal information for the following business or commercial purposes, consistent with and only as permitted by applicable law:
- Considering job applicants for current and potential future employment opportunities and assess their skills, qualifications, and interests against our career opportunities.
 - Evaluating a job applicant’s employment application, corroborating the information contained in the application and any supporting documents, and (where applicable) conducting employment related screening and background checks. (Please note, we only use background information as permitted by applicable law.)
 - Scheduling job applicants for interviews and communicate with them about their application and employment opportunities.
 - Aggregating data for MPG diversity, equity, and inclusion objectives.
 - Complying with state and federal laws and regulations governing the employment process and maintaining records pursuant to such laws and regulations.
 - Communicating with job applicants about their candidacy.
 - Keeping records of our interactions and communications with job applicants.
 - Protecting our operations, rights, privacy, safety or property, or that of our affiliates, job applicants, or other parties.
 - For any other purposes that we disclose to you at the time of collection.
 
During the 12-month period prior to the effective date of this Notice, we have collected some or all of the categories of personal information described above in this Notice, and have disclosed these categories of personal information to the following categories of entities for a business or commercial purpose:
- MPG companies and affiliates.
 - Service providers, such as IT operating system and platform vendors, Human capital SaaS solutions (such as Greenhouse), security vendors, data analytics providers, insurance vendors, company banks, payroll processors, auditors, law firms, accountants, and other benefits providers.
 - Public or governmental authorities, such as regulatory authorities or other third parties in response to legal process or other legal reporting requirements.
 
If you are a resident of California, you have the right to submit certain requests relating to your personal data. To exercise any of these rights, please submit a request by contacting us using the information in the “Contact Us” section below or call us at 1-844-928-0193. Please note that, depending on your privacy request, you may be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the same contact information.
You have the following consumer rights under the CCPA:
- Right to Request Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past twelve (12) months, including:
- The categories of personal data we collected about you;
 - The categories of sources from which the personal data was collected
 - Our business or commercial purposes for collecting or disclosing personal data
 - The categories of third parties to which we disclose personal data
 - The specific pieces of personal information we collected about you; and
 - If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party You have the right to request that we delete personal data we collected from you, subject to certain exceptions.
 
 - Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.
 - Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
 - Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
 - Right to Opt-Out of Sale or Sharing. You have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). Because we do not “sell” or “share” personal information, these rights are not available.
 
You will not receive discriminatory treatment by us, including retaliation against you as an applicant, if you exercise any of your rights.
Changes to This Notice
We reserve the right to update this Notice at any time. We will review this Notice at least annually and update it when appropriate. If you want to see changes made to this Notice from time to time, we invite you to access this Notice to see the changes. If we make material changes or changes that will have an impact on you (e.g., when we start processing your personal data for purposes other than set out above), we will contact you prior to commencing that processing.
Contact Us
If you have questions or comments about our data practices or this Notice, you can contact us or our data protection officer at:
Millennium Print Group
Attn.: Data Protection Officer—Job Applicant Privacy Notice
| 
 10900 World Trade Blvd  | 
joinmpg@mprintgroup.com, with “Job Applicant Privacy Notice” in the subject line
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