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About this privacy notice
ICON plc. (“ICON”, “we”, “us”, “our”) is committed to protecting your privacy.
This privacy notice tells you what personal information we collect and how we collect it. It explains what we use your personal information for, why we use it, and how we protect your personal information. This notice also describes certain rights you have in respect of your personal information.
This notice is intended for job applicants.
Who is the data controller of your personal information?
ICON is the "data controller" of your personal information for the purposes set out in this notice. This means we determine how your personal information is used and processed for the purposes described in "How do we use your personal information?
In circumstances where ICON acts on a third party's instructions (this means ICON is acting as a "data processor"), that third party is the data controller of your personal information, and their privacy notice will apply to you instead of this one.
Contact information and your privacy point of contact
You can submit questions or comments to our Global Data Protection Officer at Data_Privacy_Officer@iconplc.com.
You may also contact our Data Protection Officer by writing to us at: Global Data Protection Officer, ICON plc South County Business Park, Leopardstown, Dublin 18, D18 X5R3, Ireland.
To exercise your rights as outlined in the "What are your rights regarding your personal information?", please follow this link and complete the Data Subject Rights form.
What personal information do we collect about you? How do we collect it?
“Personal information” is any information relating to you which allows you to be identified directly or indirectly. Personal information can include a name, an email address, an identification number or any other details that are specific to you.
Depending on the purpose for using your personal information, we collect and process information from you, including:
(a) Basic information – your name, surname (including prefix or title), photo/image, country or location, as well as your preferred language
(b) Contact information – information that enables us to contact you, e.g. your email, mailing address, and telephone number;
(c) Professional information and experience – information related to your education, professional qualifications, work experience, references, and referees;
(d) National identifiers – your national ID/passport, residency and work permit status, social security number, or other taxpayer/government identification number;
(e) Financial information – your salary, retirement account information, company allowances, bonus, benefits, working time records, and taxpayer reference number (eg Tax Identification Number, National Insurance number, Social Security Number). We will also collect your bank details if we reimburse you for expenses during the recruitment process;
(f) Dependents' information – information related to your dependents, e.g. the first and last names, dates of birth, and contact details of your spouse/partner and dependents;
(g) Information collected during interviews and tests – the results of any tests you take, comments noted by our interviewers, and audio/video recordings and images of the interview (in case of recorded interviews);;
(h) Background information – if we want to offer you the job, we may need to complete pre-employment screening. We may then collect information such as credit history, criminal records and occupational health information (if permitted by law). Where permitted by law, we may also collect information such as debarment status, including disqualified, excluded or suspended status from any government/regulatory authority or professional body with respect to the performance of scientific or clinical investigations; and information on criminal records and offences, trade sanctions and/or restrictions as part of the background checks / staff vetting we conduct in order to satisfy regulatory and / or prudential requirements, client requirements and obligations;
(i) Special categories of personal information – information related to your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, veteran status or information about your health, disabilities, or sexual orientation. We use this information to make sure we meet relevant laws. If we offer you employment, we may also ask you for information about your health (physical or mental) so we can give health and insurance benefits to you and your dependents. We will also use this information to discuss with you what reasonable adjustments we can make for you, so we can provide an inclusive workplace.
We collect this information directly from you:
a) when you apply for a job/role with us.
b) when you share your resume or CV with us.
c) when you get in touch to provide information, for support or to provide feedback.
d) as part of meetings, interviews, tests and other recruitment exercises.
We collect and process information from third parties, including:
a) from your referees and prior employers.
b) from third party service providers that carry out employment background / debarment checks (if permitted by law).
c) from recruitment agencies.
d) from publicly available websites, where permitted by law.
You can decide whether to give us special categories of information, if we ask you for them. If you decide not to share these with us, this does not affect your application.
You can choose not to give us certain personal information when we ask you for it. If you decide not to give us your personal information, we may not be able to consider your application or respond to communications from you.
If you provide any personal information relating to another person (such as your referees), you are responsible for ensuring that this person has given you their permission to you sharing their personal information with us.
We will not process personal information (including any of the information in the above list) if the laws of your country prohibit us from doing so.
How do we use your personal information?
We use your personal information:
a) to consider your application, including:
(i) to reply to your application.
(ii) to assess and evaluate your suitability for the job you are applying for.
(iii) to conduct interviews, meetings, tests and evaluations during the recruitment process.
b) to make travel arrangements for you, where needed.
c) to consider you for opportunities we have now, or future ones, with ICON and its affiliates, and to let you know about those opportunities.
d) to keep records in respect of our recruiting and hiring processes.
e) to check your background, references and other information you gave us, to the extent allowed by law.
f) to prepare an offer of employment and other documents we use at this pre-contract stage of our recruitment process.
g) to assess (potential or actual) conflicts of interest.
h) to analyse personal information and aggregate / pseudonymise information to improve our recruitment and hiring processes, enhance our ability to attract successful candidates, and manage internal resourcing.
i) to respond to your queries and requests.
j) to process, manage and respond to any questions or concerns you raise via ICON's EthicsLine.
k) to protect the security of our websites and apps.
l) to comply with our legal obligations.
m) to exercise or defend ICON against potential, threatened or actual litigation.
n) for the purposes of building/creating artificial intelligence/machine learning models for the purposes/processing listed in this section.
o) for the purpose of using artificial intelligence/machine learning models for the purposes/processing listed in this section.
We will not use your personal information for purposes that are incompatible with the above purposes, unless it is required or authorised by law.
How do we share your personal information?
We may disclose personal information we collect about you to other parties. We will only do this for the purposes set out in "How do we use your personal information?". These third parties are:
a) Third party service providers - We may share your personal information with our third party service providers that provide recruitment services, recruitment software systems, pre-employment screening and background check services, web hosting services, cloud storage services, services to help improve our recruitment practices, and travel agencies.
b) To our affiliates and subsidiaries – We may share your personal information within our group of companies for the purposes described above.
c) For legal, security and safety purposes - We may have to share your personal information in response to authorised requests of government authorities or where required by law.
d) In connection with a corporate transaction - As part of any merger, sale, joint venture, transfer, or other disposal of all or any portion of our business (including as part of any bankruptcy or similar proceedings), we may transfer your personal information to other parties involved in these transactions. Under these circumstances, all parties will enter into a confidentiality agreement to protect personal information and must only use personal information for the purpose it was collected for in the first instance.
Will we transfer your personal information outside your home country?
We may need to transfer your personal information internationally. This includes to the USA, Ireland, the country in which your hiring manager is located, and where needed, to other countries too. We will only transfer your personal information for the purposes set out in "How do we use your personal information?"
We implement appropriate measures to protect your personal information when we transfer your personal information outside of your home country, such as data transfer agreements that incorporate standard data protection clauses. The data privacy laws in the countries we transfer it to may not be the same as the laws in your home country.
We will apply appropriate safeguards to such transfers as required by applicable law. For example, transfers from the European Economic Area ("EEA") to non-EEA countries will usually be governed by EU-approved Standard Contractual Clauses and will be subject to other appropriate security measures. If you are in the EEA, you can obtain a copy of these safeguards by emailing us using our contact details in "Contact information and your privacy point of contact" section.
How long do we keep your personal information?
We will keep your personal information only for as long as we need to, so we can complete the recruitment and pre-employment screening activities we have explained in this Privacy Notice. Once these activities are complete, we may need to keep it longer where:
a) this is advisable in light of our legal position (due to statutes of limitations).
b) there is a requirement to keep your personal information for a period required by law.
c) we should keep your personal information in connection with legal action or an investigation involving ICON.
d) you have consented to hear about future opportunities with us.
If you accept an employment offer, we will send our Employee Privacy Notice to you. The Employee Privacy Notice explains what we use your personal information for, why we use it, and how we protect your personal information. This notice also describes certain rights you have in respect of your personal information.
We may collect information that is not personal information or convert personal information into information which can no longer be used to identify you (such as through aggregation or anonymisation). When we do this, we may use and disclose that information for any purpose, as anonymised data is not covered under data protection laws.
How do we protect your personal information?
We use a variety of security measures and technologies to help protect your personal information. We carefully choose our service providers, and check they have security measures and technologies in place to protect your personal information.
However, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of transmissions over the internet, or of our databases. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us using our details at "Contact information and your privacy point of contact" section.
Additional information if you are in the European Economic Area (EEA)
Why are we allowed to collect and use your personal information?
We use your personal information only where required for specific purposes. The table below sets out the purposes for which we use your personal information and our legal reason for using your personal information in this way.
Purpose
| Legal Basis |
To consider your application, including: (i) to reply to your application. (ii) to assess and evaluate your suitability for the job you are applying for. (iii) to conduct interviews, meetings and tests during the recruitment process. | We process your personal information for this purpose on the basis of your consent. |
To make travel arrangements for you, where needed. | This is in our legitimate interests to ensure that you are able to attend in-person interviews, meetings and other exercises, where relevant. If it is necessary to collect special categories of data for this purpose, such as health data, we will obtain your explicit consent where required by law. |
To consider you for opportunities we have now, or future ones, with ICON and its affiliates, and to let you know about those opportunities. | We process your personal information for this purpose on the basis of your consent. |
To keep records in respect of our recruiting and hiring processes. | This is in our legitimate interest, to support the running of our business. |
To check your background (excluding criminal background), references and other information you gave us, to the extent allowed by law. We share your personal information with companies who do these pre-employment screening checks for us. | If required by local law, we will process your personal information for this purpose on the basis of your consent. Where consent is not appropriate, we rely on legitimate interest to ensure we hire qualified and suitable individuals that meet legal requirements and the requirements of our clients. |
To check your criminal record to the extent it is relevant and appropriate to the role you are applying to. | As permitted by local law that provides for appropriate safeguards for your rights and freedoms. |
To prepare an offer of employment and other documents we use at this pre-contract stage of our recruitment process. | This is to take steps before entering an employment contract with you or performing an employment contract with you. |
To assess (potential or actual) conflicts of interest. | This is in our legitimate interest to ensure we comply with our internal compliance policies on managing conflicts of interest. |
To analyse personal information and aggregate / pseudonymise information to improve our recruitment and hiring processes, enhance our ability to attract successful candidates, and manage internal resourcing. | This is in our legitimate interest to manage our business (including to plan for resource allocation, make forecasts and manage supply and demand) and to ensure we can hire talented and qualified individuals. |
To respond to your queries and requests. | This is in our legitimate interest in order to respond to your query or request. |
To process, manage and respond to any questions or concerns you raise via ICON's EthicsLine. | We process your personal information for this purpose in order to comply with our legal obligations. |
To protect the security of our websites and apps. | This is in our legitimate interest in order to protect the security of our websites, apps and IT systems. We also process personal information for this purpose where it is necessary for us to comply with a legal obligation that we are subject to. For example, this includes our legal obligation to ensure we have appropriate security measures in place to protect your personal information. |
To comply with our legal obligations. | We process your personal information for this purpose in order to comply with our legal obligations. For example, we are required by law to keep certain records for specific periods of time, and to process your requests to exercise your rights in respect of your personal information. |
To exercise or defend ICON against potential, threatened or actual litigation | We process your personal information for this purpose for the establishment, exercise or defence of legal claims or proceedings. |
For the purposes of building/creating artificial intelligence/machine learning models for the purposes/processing listed in this section. | We rely on legitimate interests for the purposes/processing listed in this section. |
For the purpose of using artificial intelligence/machine learning models for the purposes/processing listed in this section. | We rely on legitimate interests for the purposes/processing listed in this section. |
What are your rights regarding your personal information?
You have rights in respect of your personal information. The rights available to you depend on our reason for processing your personal information and the local law in your country, and there are exceptions to some rights. Depending on this, you may have:
a) The right to be informed – if we are processing your personal information, we must inform you of various details, including who is processing your personal information, why, how long we will retain it for, and if we are transferring the data to another country.
b) The right to withdraw consent – if we are processing your personal information on the basis of your consent, you can withdraw your consent to that processing at any time. If you withdraw your consent, this will not mean any processing we carried out prior to your withdrawal is invalid.
c) The right of access to your personal information – you can request a copy of the personal information we hold about you.
d) The right to rectification – you have the right to request that we correct any inaccuracies in the personal information we hold about you and complete any personal information where this is incomplete.
e) Right to erase your personal information (right to be forgotten) - you have the right to be forgotten in certain circumstances including, for example, where the personal information is no longer needed for the purpose for which it was collected. However, this right does not apply where, for example, processing is necessary to comply with a legal obligation, or for the establishment, exercise or defence of legal claims.
f) The right to restrict the processing of your personal information - you have the right to ask us to restrict certain processing activities in some circumstances, including, for example, where you challenge the accuracy of the information. Where processing has been restricted, we can only process it for limited purposes such as, for example, the establishment, exercise or defence of legal claims.
g) The right of data portability - you have the right to have your personal information returned to you or to a third party in certain cases.
h) The right to object – you have a right to object to the processing of your personal information in certain cases, for example, when we process your personal information based on our legitimate interest. In such a case we will stop processing your personal information unless we can show there are compelling legitimate grounds which override your interest.
To exercise these rights, please contact us using our contact details in "Contact information and privacy point of contact" section.
We may request proof of identity, so we can verify who you are.
If you feel your data protection rights have been infringed by ICON, you may have the right to complain to your local data protection supervisory authority. A good resource for details on data protection authorities from around the world is kept at List of DPAs | pdpEcho.
Additional information if you are in the United States (US)
You have rights in respect of your personal information. The rights available to you depend on our reason for processing your personal information and the laws in your state, and there are exceptions to some rights. Depending on this, you may have the right to:
- Obtain confirmation that we hold certain personal information relating to you and the corresponding processing activities, and to verify its content, origin, and accuracy;
- Access, review, port, delete or anonymize, or to block or withdraw consent to the processing of certain personal information (without affecting the lawfulness of processing based on consent before withdrawal of your consent);
- Request information about third parties with whom we have shared your personal information;
- Where relevant, request review of decisions based solely on automated data processing;
- Where relevant, object to our use of personal information for direct marketing and in certain other situations at any time.
To exercise these rights, please contact us using our contact details in the "Contact information and privacy point of contact" section. We may request proof of identity, so we can verify who you are.
Please note that we need to retain certain personal information as required or permitted by applicable law.
We do not sell your personal information and will not do so without providing you with notice and an opportunity to opt-out of such sale as required by law. We do not engage in targeted advertising.
Notice to California Residents:
If you reside in California, we are required by California law to provide you with additional information about how we use and disclose your personal information, and you may have additional rights with regard to how we use your personal information. We have included this California-specific information below.
- Categories of Personal Information:
Consistent with What personal information do we collect about you? How do we collect it?, we may collect certain categories and specific pieces of information about California residents that are considered "personal information" under California law ("CA Personal Information").
- Sources of Personal Information:
The sources of your CA Personal Information are outlined in What personal information do we collect about you? How do we collect it?
- Uses of Personal Information:
The purposes for which we collect CA Personal Information are detailed in How do we use your personal information? with additional information below.
- Sharing Personal Information:
The categories of third parties to whom we disclose your CA Personal Information for a business purpose are detailed in How do we share your personal information?
- Retention of CA Personal Information:
We retain your CA Personal Information as detailed in How long do we keep your personal information?
California Consumer Rights:
If you are a California resident, you have rights in respect of your CA Personal Information, and there are exceptions to some rights. Depending on this, if you are a California resident, you may exercise the following rights:
- Right to Know - You have the right to request information about the categories of CA Personal Information we have collected about you, the categories of sources from which we collected the CA Personal Information, the purposes for collecting the CA Personal Information, the categories of third parties with whom we have shared your CA Personal Information, and the purpose for which we shared your CA Personal Information. You may also request information about the specific pieces of CA Personal Information we have collected about you. You also have a right to receive information about the CA Personal Information about you that we have "sold" to or “shared” (as such terms are defined under California law) with third parties within the past 12 months.
- Right to Delete - You have the right to request that we delete CA Personal Information that we have collected from you.
- Right to Correction - You have the right to obtain correction of your CA Personal Information.
- Right to Transfer - You have the right to request a transfer of your CA Personal Information to another entity to the extent technically feasible, in a structured, commonly used, machine-readable format.
- Limit the Use of Sensitive Personal Information - You have the right to limit the use and disclosure of your sensitive CA Personal Information.
- Right to Opt Out - You have the right to opt out of the sale and / or sharing of your CA Personal Information. However, we do not currently sell your CA Personal Information. Should this change at any point in future we will update this Privacy Notice, notify you of any changes, and provide you with the appropriate mechanism to exercise your right to opt-out from the sale of your CA Personal Information. You also have the right to opt-out of being subject to automated decision-making processes, including profiling. However, we do not currently engage in such practices.
You may submit a request to exercise your Californian privacy rights by following this link and completing the Data Subject Rights Form or using our contact details in the "Contact information and privacy point of contact" section or by calling our toll-free number (877-202-0559). We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.
Verification. In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. When making a request, please provide the following information: first and last name; email address; and type of request you are making.
Authorized Agents. If you choose an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.
Timing. We will respond to requests to delete and requests to know within 45 calendar days, unless we need more time. If this is the case, we will notify you and may take up to 90 calendar days in total to respond to your request.
How do we update this privacy notice?
ICON may make changes to this Privacy Notice. For instance, we may need to amend this Privacy Notice if there are changes to relevant laws.
Where we have your contact details, we will notify you of any significant changes.
Revised 06-27-2024