Effective Date: February 22, 2022
Palo Alto Networks is committed to protecting the privacy and security of your personal data. This Privacy Notice (“Candidate Privacy Notice”) describes how Palo Alto Networks, Inc. and its subsidiaries and affiliated entities (collectively, "Palo Alto Networks," "we," or "us") collect and process personal data about you during the application and recruitment process. This Candidate Privacy Notice applies to job applicants only, but supplements and should be read together with the Palo Alto Networks Privacy Notice which applies to all personal data collected on our website(s).
This Candidate Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Candidate Privacy Notice also describes your rights regarding the personal data that we hold about you and how you can request access to, correction of, object to or restrict processing of, portable copies of, and erasure of your personal data.
We will only process your personal data as described in this Candidate Privacy Notice unless otherwise permitted or required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
Depending on your jurisdiction, there may be certain rights applicable to you for which we may provide separate notice informing you of your rights and how to adequately exercise them.
1. Collection of Personal Data
For purposes of this Candidate Privacy Notice, personal data means any information about an identifiable individual collected in connection with the application and recruitment process. Palo Alto may collect personal data directly from you, as a job applicant, 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 a particular individual. We may collect, store, and process the following categories of personal data in connection with our recruiting and interview process:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application.
- Education information including degrees awarded, transcripts, and other information provided in support of the job application.
- Compensation history, but only where permitted by law.
- Information collected during phone screenings and interviews.
- Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
- Reference information and information received from background checks, where applicable, including information provided by third parties such as recruiters.
- Information related to previous applications to Palo Alto Networks or previous employment history with Palo Alto Networks.
- As applicable to work arrangement, immigration-related information, visa status, citizenship, and related family status (e.g., spouse or other family).
- Any additional personal details that you otherwise voluntarily provide to us.
The provision of full and complete information in support of a job application is necessary for selection purposes. Failure to provide any of the data may affect the processing of your application.
2. Use of Personal Data
We only process your personal data as described in this Candidate Privacy Notice or as otherwise required or permitted by applicable law in connection with carrying out our application and recruitment process. We may process your personal data for the following legitimate business purposes:
- Identifying and evaluating job applicants, including assessing skills, qualifications, and interests.
- Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
- Communicating with you about the recruitment process and your application.
- Keeping records related to our hiring processes.
- Creating and submitting reports as required by applicable laws, regulations, or court orders.
- To comply with our legal, regulatory, or other corporate governance requirements.
- Analyzing and improving our application and recruitment process.
- Complying with applicable laws, regulations, legal processes, or enforceable government requests.
- To protect the rights and property of Palo Alto Networks, other job applicants, employees, or the public, as required or permitted by law.
We will store the personal data we collect about you for no longer than necessary for the purposes set out above and in accordance with our legal obligations and legitimate business interests. In addition to using your personal data for the position for which you have applied, we may retain and use your personal data to inform you about and consider you for other positions that may be of interest to you. If you do not want us to consider you for other positions or would like us to remove your personal data, you may contact us at firstname.lastname@example.org. We will only process your personal data for the purposes for which we collected it unless otherwise required by applicable law. If we need to process your personal data for an unrelated 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 where required by applicable law, regulation, or court order.
3. Collection and Use of Sensitive Personal Data
The following categories of personal data may be considered sensitive under the laws of your jurisdiction and may receive special protection:
- Race or ethnic origin.
- Political opinions.
- Religious, philosophical, or moral beliefs.
- Trade union membership.
- Social welfare, gender, sexual life, or sexual orientation.
- Physical or mental health or condition.
- Unlawful or objectionable conduct, criminal charges, or convictions.
- Biometric information.
- Genetic data.
- Financial information.
We may collect and process the following categories of sensitive personal data when you voluntarily provide them or we receive them from a third party with your consent, when relevant for a particular position and as permitted by applicable law:
- Physical or mental health or condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position or for the provision of benefits.
- Family and/or marital status and limited health information required to process an employee's request to apply for supplemental health insurance or other optional benefits for the employee and/or related persons.
- Race or ethnic origin to ensure meaningful equal opportunity monitoring and reporting.
- Unlawful or objectionable conduct, criminal charges, or convictions to evaluate fitness for a particular position. Where we have a legitimate need to process your sensitive personal data for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your consent.
4. Data Sharing
We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the application and recruitment 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. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.
We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data for the following additional purposes, where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Candidate Privacy Notice and as necessary to administer the application and recruitment process.
- If we take part in or are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets through which we may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction.
- In the event of insolvency, bankruptcy, or receivership.
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
- To protect the rights and property of Palo Alto Networks.
- During emergency situations or where necessary to protect the health and safety of persons.
- Where the personal data is publicly available.
- If a business transfer or change in ownership occurs.
- For additional purposes with your consent where required by law.
5. Cross-Border Data Transfers
Where permitted by applicable law, we may transfer the personal data we collect about you to jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Candidate Privacy Notice. We have implemented data transfer agreements/obtained consent to secure the transfer of your personal data to other jurisdictions.
If you are based in the UK or the European Economic Area (EEA), please note that, where necessary, your personal information may be processed by other Palo Alto Networks entities and service providers outside the UK and EEA, such as the United States of America. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, you may contact us at email@example.com.
6. 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 that have a legitimate business need for such access.
All personal data we collect will be stored on secure servers. When we transfer personal information to others, we will ensure that the recipients also implement appropriate technical and organizational security measures to protect your personal data.
7. Data Retention
Except as otherwise permitted or required by applicable law, regulation, or court order, we will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal data so that 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 with Palo Alto Networks, 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 do not become an employee, or, once you are no longer an employee of Palo Alto Networks, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.
8. Rights of Access, Correction, Erasure, and Objection
We use a combination of legitimate interests, performance of a contract (including the intention to enter into a contract) and/or consent as the legal basis to process the personal data that you share with us as part of the application and recruitment process.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the application and recruitment process. By law you may have the right to request access to, correct, or erase the personal data that we hold about you, object to or restrict the processing of your personal data, or request the portability of your personal data, under certain circumstances. If you wish to exercise one of these rights, please contact us at firstname.lastname@example.org. Any such communication must be in writing. Depending on the jurisdiction where you are located, some of these rights may not apply.
We may request specific information from you to help us confirm your identity, verify your rights, and respond to your request, including to provide you with the personal data that we hold about you, if applicable. Applicable law may allow or require us to deny your request, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot respond to your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal data. We may, however, need your consent for some uses of personal data. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it. You will never be obliged to provide consent. Where you have provided your consent to the collection, processing, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at email@example.com.
10. Data Protection Officer
We have appointed a data protection officer to oversee compliance with this Candidate Privacy Notice. If you have any questions about this Candidate Privacy Notice or how we handle your personal data, or you would like to make a request relating to your personal data, please contact the data protection officer at: firstname.lastname@example.org. If you are unsatisfied with our response to any issues that you raise with the data protection officer, you may have the right to make a complaint with the applicable data protection authority in your jurisdiction.
11. Changes to This Candidate Privacy Notice
We reserve the right to update this Candidate Privacy Notice at any time and we will provide you with a new Candidate Privacy Notice when we make any material updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law, regulation, or court order.
12. Contact Us
If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: email@example.com. If you are unsatisfied with our response to any issues that you raise, you may have the right to make a complaint with the data protection authority in your jurisdiction by contacting the data protection authority.