Effective Date: May 2, 2024 Last Modified: May 2, 2024

Scope and Overview

The Humane League ("THL") is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how THL collects and processes personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants only. For individuals interacting with us in a non-professional capacity (i.e., donors and supporters) and information collected automatically through the website for all users, THL's broader Privacy Policy can be found here. Employees or global workers may obtain a copy of applicable privacy policies from their local human resources representative or, if applicable, their employer of record.  

This 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 Privacy Notice also describes your rights regarding the personal data that we hold about you including rights you may have under applicable law to access, correct, and request erasure of your personal data. 

We will only process your personal data in accordance with this Privacy Notice or in a manner consistent with your reasonable expectations.  We are committed to ensuring that the personal data that we collect about you is adequate, relevant, not excessive, and processed in compliance with the purpose limitations outlined under applicable data protection law.

Controller—Who We Are

A “controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which, any Personal Data is, or is likely to be, processed. The data controller with respect to your personal data under this Privacy Notice is THL, whose address is as follows:

The Humane League P.O. Box 10476 Rockville, MD 20849

THL’s Legal and IT departments oversee compliance with data protection within the organization. If you have any questions about this Privacy Notice, please contact our Legal Department via email at legal@thehumaneleague.org.

Collection of Personal Data

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process, including information that may identify an individual indirectly in combination with other information. THL 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), or other third-party data providers that may collect your information from publicly available sources or other third parties. Personal data excludes anonymous or de-identified data that is not associated or capable of being reasonably associated with a particular individual. We may collect, store, and process the following categories of data, in connection with our recruiting activities:

• Identifiers and personal contact details such as name, name pronunciation, preferred pronouns, title, address and location, telephone number, and email address. 
• Employment history and other relevant professional experience, including information contained in your resume, CV, cover letter, or job application, such as your employment history, qualifications, and/or professional memberships. 
• Education information including degrees awarded, transcripts, and other information provided in support of the job application.
• Information collected during phone screenings, interviews, and other hiring-related assessments, such as details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
• If disclosed, any special needs or health condition and information relating to accommodations that you may request during the recruiting process.
• Reference information and information received from background checks, where applicable, including information provided by third parties.
• Information related to previous applications to THL or previous employment history with THL.
• Information necessary to confirm and/or demonstrate your ability to work in a particular jurisdiction.
• Information that you make publicly available such as contact information, your education, and work experience information (e.g. when you share information via job search and career networking sites as far as it is relevant to consider you for career opportunities).
• Other information that you provide and/or that we may need to collect during the recruiting and/or during any on-boarding process prior to employment.

Note: We collect some information because we are required to collect it under applicable law, or need it to move forward with your application. We'll tell you if the information is required when we ask you to provide it. Refusal to provide or allow us to process mandatory personal data may hinder our ability to engage with, consider, and/or hire you.

Use of Personal Data

We primarily rely upon legitimate interest as the basis for collecting and processing your personal data. We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data about job applicants allows us to manage the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a position. We may also collect, use, and process your personal data where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, or with your consent if applicable law requires consent. 

We process your personal data for the following legitimate business purposes:

• Processing and reviewing your job application, including any cover letter, resume, and/or references.
• Evaluating job applicants, including assessing skills, qualifications, and interests for a particular position, and in certain cases, for other opportunities at THL.
• Scheduling and/or conducting interviews with job applicants.
• Verifying your information and carrying out employment, background, and reference checks, where applicable, and subject to your consent where required by applicable law.
• Communicating with you about the recruitment process and your application.
• Assessing and determining appropriate compensation packages, if applicable.
• Managing any on-boarding processes or procedures, if applicable, such as to make the application process easier and more efficient.
• Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
• To comply with our legal, regulatory, or other corporate governance requirements.
• Analyzing and improving our application and recruitment process.
• To detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity, or violations of THL's policies or the law; for fraud and crime prevention; and for information protection and cybersecurity.

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 appropriate for you with your consent. If you want us to consider you for other positions, you may contact us as specified below under Contact Us and we will retain your personal data for that purpose. We may subsequently contact you for refreshed consent to continue retaining your personal data for consideration for future employment depending upon the length of time that has passed. We may process your personal data without your knowledge or consent only where required or permitted by applicable law or regulation.

Collection and Use of Special Categories of Personal Data

THL does not intend to collect any of the following special categories of personal data that are considered sensitive 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.
• Data relating to criminal convictions or offenses.

Please refrain from providing any of this information to THL. Note, however, that there may be instances where we incidentally collect and process certain special categories of personal data, such as when you voluntarily provide them (as in the case of reasonably necessary work accommodations) or when they are received from a third party (such as data relating to criminal convictions or offenses that may appear in a background check, with your consent where required by law). 

Although we do not intend to collect any special categories of data, we may process such personal data (i) where necessary for the purposes of complying with obligations or exercising specific rights in the field of employment and social security and social protection law, (ii) where necessary to protect your vital interests, (iii) where the information has been made publicly available by you, or (iv) where otherwise permitted or required by law. Otherwise, we will obtain your consent where required by law.

Data Sharing

We will only disclose your personal data to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf, or to other third parties where required by law. This list may change from time to time, but we review this list periodically to ensure it is up-to-date. Our third party vendors and service providers include, but are not necessarily limited to:

• Recruitment service providers and partners (Greenhouse)
• Employers of record (if applicable)
• Vendors facilitating interviews and tests (generally conducted through Greenhouse and using Google)
• Data storage vendors (including Greenhouse and Google)
• Reporting and analytics service providers (including Google)

The following are generally and likely inapplicable to candidates, and we will notify you of any relevant providers that constitute the following:

• Vendors facilitating interview travel booking and expenses
• Vendors facilitating relocation
• Immigration advisors including lawyers and consultants
• Pre-employment screening services 
• Vendors assisting us with the implementation of health and safety measures

We may also disclose your information to various other third parties in the following circumstances:

• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders, if we have a good-faith belief that the law requires us to do so. 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.
• When we have a good-faith belief it is necessary to detect, prevent and address fraud, unauthorized use of our systems or products; violates our terms or policies or other harmful or illegal activity; to protect ourselves (including our rights, property and products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
• If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
• When we are under a legal obligation to do so, we may provide your personal data to law enforcement or a government regulator or entity.
• For other purposes where the information is publicly available or the disclosure is otherwise permitted by applicable law, subject to your consent where required.

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 do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions. However, if you are hired and will be employed through an employer of record, then THL will provide limited information to the employer of record (such as your name and contact information), and the employer of record will be acting as a controller with regard with your personal information in order to onboard you as their employee and manage your employment.

Cross-Border Data Transfers

We are headquartered in the United States. THL and its 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, including a jurisdiction that your country of residence may consider to be lacking adequate protection for personal data in the absence of additional protection mechanisms, such as the United States (“third countries”). Your information will be transferred pursuant to the EU-US Data Protection Framework (DPF) and/or Standard Contractual Clauses (SCCs) under GDPR. For example, the personal data about you that we collect, process, and/or use is controlled by THL, and is stored on servers located in the United States or other third countries. If you are applying from outside the United States, be aware that your personal data will be transferred to, stored, and processed in the United States or other third countries where our servers are located, and our central database is located. By submitting an application, you consent to any transfer of this personal data to the United States or other third countries.

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. Although we use appropriate security measures once we have received your personal data, the transmission of information over the internet is never completely secure.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or for a longer period as required to satisfy any legal, accounting, or reporting requirements; as necessary to resolve disputes; or defend or assert claims against or on behalf of THL. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.

Under some circumstances we may anonymize or de-identify your personal data so that it can no longer reasonably 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 THL, 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. In that circumstance, we will generally retain your personal data for four years following the termination of your employment unless the information is required to be retained for a longer period to assert or defend THL’s rights, or as required by law or legal process. If you do not become an employee, THL will generally hold your personal data for one year after the end of the relevant recruitment period, unless there is a statutory reason to keep your information, or you have asked us to keep your information on file for future job opportunities. If you have asked us to keep your information on file for future positions, we may contact you every year thereafter to obtain renewed consent and ensure that you are still interested in future job opportunities.

Data Privacy Rights for EU Residents and Similar Jurisdictions

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 recruitment process. 

Please note that you may not be entitled to all the consumer rights listed below depending upon your country of residence.  If you reside within the European Economic Area ("EEA"), United Kingdom ("UK"), or another jurisdiction with similar privacy rights, you may have the right to: 

• Request access to your personal data
  • You may have the right to confirm that THL processes your personal data and obtain access to your personal data in THL's possession.
• Request correction of your personal data
  • You may have the right to have factually inaccurate personal data rectified, to the extent THL has any such inaccurate personal data.
• Request erasure of your personal data
  • You may have the right to have your personal data erased if:
    • Your personal data is no longer necessary for the purpose for which THL originally collected or processed it;
    • You decide to withdraw your consent and there is no other legal basis for processing your personal data;
    • You object to THL's processing of your personal data, and THL has no overriding legitimate interest or other valid basis to continue the processing of your personal data;
    • THL has processed your personal data unlawfully; or
    • Where THL must erase your personal data to comply with a legal obligation.
• Object to processing of your personal data
  • You may have the right to object to certain types of processing of your personal data, which include:
    • Processing for direct marketing purposes (including profiling); and
    • Processing for purposes of scientific/historical research and statistics.
• Request restrict processing of your personal data
  • You may have the right to limit the way THL uses your personal data in certain circumstances:
    • You contest, in good faith, the accuracy of your personal data in THL's possession and THL is verifying the accuracy of such information;
    • THL has unlawfully processed your personal data and you oppose erasure and request restriction instead;
    • Your personal data is subject to destruction under THL's data retention policy, but you need THL to keep it in order to establish, exercise, or defend a legal claim; or
    • You have objected, in good faith, to THL processing your personal data, after which THL may lawfully consider whether it has legitimate grounds to continue processing your personal data.
• Request transfer of your Personal Data (also known as the right of data portability)
  • Under limited circumstances, you may have the right to obtain from THL and reuse your personal data for your own purposes. This right allows you to move, copy, or transfer your personal data easily, without hindrance to usability. If you request it, THL may transmit your personal data directly to another organization if this is technically feasible.
• Withdraw your consent
  • In the limited circumstances where you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our Legal Department. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose you originally agreed to, unless we have another legal basis for processing.

If you would like to enforce any of these rights, please contact our Legal Department at legal@thehumaneleague.org. We will not discriminate against you for choosing to exercise your rights.

Responses to Data Privacy Rights Requests

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, THL may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. If a fee applies, THL will notify you of the fee upon receiving your request. Alternatively, we may refuse to comply with your request in these circumstances. We may also refuse to provide you with access to some or all of the Personal Data that we hold about you (or to exercise any of the other rights) if (a) applicable laws allow or require us to or (b) in accordance with our Retention Policy, we have destroyed, erased, or anonymized your Personal Data. If we cannot provide you with access to Personal Data about you, we will inform you of the reasons why (subject to any legal or regulatory restrictions).

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or anonymized your personal data in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Complain to a Supervisory Authority

You may raise your concerns with your local data protection authority directly. We would, however, encourage you to contact us first at legal@thehumaneleague.org as we aim to promptly, efficiently, and satisfactorily resolve any concerns or complaints you may have in relation to our processing of your personal data. If you are based in the UK or EEA and believe that we have not complied with data protection laws, you can complain to the UK ICO (www.ico.org) or your local EEA supervisory authority. The European Data Protection Board (EDPB) makes a list of EEA data protection authorities available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Changes to This Privacy Notice

THL reserves the right to update this Privacy Notice at any time. If THL would like to use your previously collected personal data for different, incompatible purposes than those provided in this Privacy Notice, THL will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. THL may process your personal data without your knowledge or consent only where required or permitted by applicable law or regulation.

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: legal@thehumaneleague.org.