EF / Candidate Privacy Notice

Our Commitment to Your Privacy

Education First (“EF”) is committed to protecting the privacy of its potential employees. The EF candidate privacy notice (the “Candidate Privacy Notice”) describes how EF handles and protects your Personal Data (as defined below) in connection with EF’s recruiting processes and programs.

The Candidate Privacy Notice only applies to the Personal Data of job applicants, potential candidates for employment, and any recruiting programs and events. It does not apply to our employees, contractors or clients, or other Personal Data that EF collects for other purposes. This Candidate Privacy Notice does not form part of any contract of employment offered to candidates hired by EF.

If you cannot, or will not, provide us with the Personal Data we require, we will be unable to receive and process your application.

EF Invest International AG, Zurich, Switzerland, is the controller for the processing of your Personal Data (as defined below). Being the controller means that this company is responsible for ensuring that your Personal Data is processed in compliance with applicable privacy and data protection legislation.


PERSONAL DATA

As used in this Candidate Privacy Notice, “Personal Data” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., via external recruitment firms).


PERSONAL DATA WE COLLECT

The ways how we process Personal Data that we collect from you are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of Personal Data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located. Furthermore, we request Personal Data from you for statistical purposes or to conduct internal surveys on our candidate pool (e.g., information relating to gender or age). 

This policy covers the information you share with us and/or which may be acquired or produced by EF, its subsidiaries and its affiliates during the application or recruitment process, including: 

  • Your name, address, email address, telephone number and other contact information; 

  • Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process; 

  • Information from interviews and phone-screenings you may have, if any; 

  • Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences; 

  • Details of how you heard about the position you are applying for; 

  • Any sensitive and/or demographic information processed during the application or recruitment process such as gender, information about your citizenship and/or nationality, or eligibility to work in a country, medical or health information and/or your racial or ethnic origin; 

  • Reference information and/or information received from background checks (where applicable), including information provided by third parties; 

  • Information relating to any previous applications you may have made to EF and/or any previous employment history with EF; 

  • Your information from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile); and/or 

  • Information related to any assessment you may take as part of the interview screening process. 

We usually collect Personal Data directly from you when you apply for a job with us. We may also collect Personal Data about you from third parties, such as professional recruiting firms, your references, prior employers, EF employees that know you or with whom you have interviewed, and employment background check providers, or from publicly available sources to the extent this is permitted by applicable law. 

Sensitive Personal Data is a subset of Personal Data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as prescribed by law. We do not generally seek to obtain and will not collect such data about a candidate unless permitted to do so by applicable laws or if you have specifically consented to provide us such information. 

We may also collect Personal Data through cookies. Cookies allow a web server to transfer data to a computer or device for record keeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookie Policy available online under www.ef.com/legal/cookie-policy. 


USE OF YOUR PERSONAL DATA

We collect and use your Personal Data for the purposes of carrying out our application and recruitment process which includes: 

  • identifying and evaluating candidates for potential employment, as well as for future/other roles that are or may become available; 

  • recordkeeping in relation to recruiting and hiring; 

  • ensuring compliance with legal requirements, including requests from unemployment authorities or diversity and inclusion requirements and practices; 

  • conducting criminal history checks as permitted by applicable law; 

  • protecting our legal rights to the extent permitted by law; or 

  • emergency situations where the health or safety of one or more individuals may be endangered. 

  • communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at EF; 

  • where requested by you, assisting you with obtaining an immigration visa or work permit where required; 

  • making improvements to EF’s application and/or recruitment process; 

  • proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us; 

  • we may process information regarding your demographics as described above where we are required to do so to meet our legal and contractual obligations, such as reporting obligations to authorities and third parties and other similar requirements, or when we have obtained your consent.  

  • we may request Personal Data from you for statistical purposes or to conduct internal surveys on our candidate pool (e.g., information relating to gender or age). 

  • Communications to you about EF as a workplace and culture 

We may also analyze your Personal Data or aggregated/pseudonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates.  


HOW DO WE SHARE PERSONAL DATA?

We share your Personal Data with EF’s corporate affiliates, business partners and service providers:  

  • Your Personal Data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the EF Group. Individuals performing administrative functions and IT personnel within EF may also have a limited access to your Personal Data to perform their jobs. 

 

  • We use third party service providers to provide a recruiting database and related software systems. We also share your Personal Data with other third party service providers that may assist us in recruiting, administering and evaluating pre-employment screening and testing, and improving our recruiting practices. 

 

  • In addition, we may disclose or transfer your Personal Data within the EF Group in the event of an internal re-organization, merger, sale, joint venture, assignment, or other internal transfer or disposition of all or any portion of our business. 

If you refer a person to be contacted by EF for a position, or if you provide us with a reference for a position you are seeking, it is your responsibility to obtain consent from that person before providing their personal information to EF.  

We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. 


INTERNATIONAL DATA TRANSFERS

EF operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected, including in the United States or India. In some of these countries, you may have fewer rights in respect of your information than you do in your country of residence. Regardless of where your information is processed, we apply the same protections described in this policy. We comply with certain legal frameworks relating to the transfer of data, such as the frameworks described below. 

  • Adequacy Decisions: The European Commission has determined that certain countries outside of the European Economic Area (EEA) adequately protect personal data, which means that data can be transferred from the European Union (EU) and Norway, Liechtenstein, and Iceland to those countries. The United Kingdom (UK) and Switzerland have adopted similar adequacy mechanisms. We rely on the following adequacy mechanisms: 

  • Standard contractual clauses. The European Commission has approved the use of standard contractual clauses (SCCs) as a means of ensuring adequate protection when transferring data outside of the EEA. Such clauses have also been approved for transfers of data to countries outside the UK and Switzerland. By incorporating SCCs into a contract established between the parties transferring data, personal data is considered protected when transferred outside the EEA, Switzerland or the UK to countries which are not covered by an adequacy decision. We rely on SCCs for our data transfers where required and in instances where the transfers are not covered by an adequacy decision, or when the recipient is not self-certified under the EU-U.S. and Swiss-U.S. Data Privacy Frameworks. For more information on standard data protection clauses in place, please see the contact section below.  


LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

If EU, Swiss or UK data protection law applies to the processing of your data, our legal basis for processing your data

We collect and process your Personal Data where it is necessary in order to take steps, at your request, prior to potentially entering into a contract of employment with you. 

We may also seek your consent to process your Personal Data in specific circumstances, or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates. 

Where we process special categories of data such as health information, or racial or ethnic origin, we will only do so where necessary for the establishment, exercise or defence of legal claims, with your consent, or where otherwise required by applicable local law, including our obligations under employment and social security and social protection law. 

If other data protection laws apply to the processing of your data, our legal basis for processing your data

We base our right to collect and use your Personal Data on your consent.  


SECURITY

We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorized or unlawful processing and the accidental loss, destruction or damage of the Personal Data. 

HOW LONG DO WE STORE PERSONAL DATA?

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated. 

If you accept an offer of employment by us, any relevant Personal Data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements. If we do not employ you, we may nevertheless continue to retain and use your Personal Data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research. Thereafter, we retain a minimum amount of your Personal Data to record your recruiting activity with us. 

If you elect to join our talent community, we may retain your Personal Data to consider you for future employment opportunities and for a period of time specific to that talent community, unless you decide to opt-out prior to such time.  

If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact [email protected]. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims. 


UPDATES TO THIS CANDIDATE PRIVACY NOTICE

Our Candidate Privacy Notice may change from time to time. We will post any Candidate Privacy Notice changes on this page and, prior to implementing significant changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.  


YOUR RIGHTS

In some countries, you may have certain rights under data protection laws, including a right to request access or to update or review your Personal Data, request that it be deleted or anonymized, or object to or restrict EF using it for certain purposes. You may also have a right to receive your Personal Data in a machine readable format and you have a right to transfer your personal to another data controller and to withdraw your consent. 

AUTOMATED DECISION MAKING

If you have given your consent to marketing, EF may collect Personal Data for the purpose of profiling in order to serve promotional information tailored to your interests, for example to analyse or predict aspects concerning your economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. This type of profiling does not produce legal or other significant effects on you. 

We may also use a machine learning powered tool to record and transcribe interviews or calls with you, in order to assist in the evaluation of your application. A human always remains in the loop and this type of processing does not produce any legal or other significant effects on you. 

To efficiently process applications, we apply an automated, rules based screening that checks whether certain mandatory requirements are met. If specific values provided in your application—such as expected salary, eligibility to work in the country, or required experience—fall outside the defined parameters, the application will more likely be rejected. This screening does not evaluate personal characteristics or make predictions about performance. This process is based on objective criteria set in advance and does not involve artificial intelligence. A human always reviews a screening and takes the final decision to reject a candidate. 

Applicants may contact us if they believe their application was rejected in error.  

U.S. STATE LAW REQUIREMENTS

Some U.S. state privacy laws, such as the California Consumer Privacy Act (CCPA), require specific disclosures for state residents. 

This policy is designed to help you understand how EF handles your information. In the sections below, we explain: (1) the categories of information we collect and the sources of that information; (2) how we use information; (3) when we may disclose information; and (4) how we retain information. EF does not sell your personal information. EF also does not “share” your personal information as that term is defined in the CCPA. 

State laws like the CCPA also provide the right to request information about how EF collects, uses, and discloses your information. They may also give you the right to access and correct your information, and to request that EF delete that information. Finally, the CCPA provides the right to not be discriminated against for exercising these privacy rights. 

If you have questions or concerns related to your rights under CCPA, or would like to exercise your rights, you (or your authorized agent) can contact us at [email protected]. We’ll validate your request by verifying your interactions with us, and may require that you provide us with additional information, such as any names, phone numbers or email addresses you have used when communicating with us. 

The CCPA also requires a description of data practices using specific categories:  

Categories of information we collect

Identifiers and similar information, such as your name, phone number, and address; username and password; and unique identifiers tied to the browser, application, or device you’re using. 

Demographic information, such as your age, gender, and language(s) spoken and authorization to work in the country. If you choose, you may also provide additional information, like your race . 

Financial information, such as your current and/or desired salary and other terms relating to compensation and benefits packages. 

Geolocation data, including as determined by IP address, depending in part on your device and account settings. 

Audio, electronic, visual, and similar information, such as information transmitted in connection with interviews or phone-screenings you may have, if any. 

Communications data, such as emails that you may send or receive in connection with the application or recruitment process. 

Health information, if you choose to provide it, in connection with the application or recruitment process, such as data you may provide in connection with an accommodations request. 

Professional, employment, and education information, such as information you provide in connection with the application and recruitment process, as well as information EF may otherwise collect through reference checks, criminal and financial background checks (where applicable) and information from publicly available sources, including online, that may be relevant. 

Other information you create or provide, such as the content you create, upload, or otherwise provide in connection with the application and recruitment process. 

Inferences  drawn from the information above. 

Business purposes for which information may be used or disclosed

Administrative purposes: EF uses and may disclose information for purposes related to carrying out its application and recruitment process, including for assessing candidates; verifying information and conducting reference checks and criminal and financial background checks (where applicable); communicating with you about a specific position or future/other positions; responding to requests for assistance with obtaining an immigration visa or work permit (where required); and other related activities. 

Protecting against security threats, abuse, illegal activity, and violations: EF uses and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, EF may receive or disclose information about IP addresses that malicious actors have compromised. 

Research and development: EF uses information to improve our application and recruitment process. 

Use of service providers: EF shares information with service providers to perform services on our behalf, in compliance with this privacy policy and other appropriate confidentiality and security measures. For example, we may rely on service providers to help perform criminal and financial background checks (where applicable). 

Legal reasons: EF also uses information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement. 
Business purposes for which information may be used or disclosed
Other people with whom you choose to share your information, such as the content you create, upload, or otherwise provide in connection with the application and recruitment process. 

Third parties with your consent, for example if you have given us permission to contact your references. 

Service providers, trusted businesses or persons that process information on EF’s behalf, based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures. 

Law enforcement or other third parties, in response to legal process or enforceable government requests, and as necessary to identify, report on and investigate violations of applicable laws and regulations. 

CONTACT US

If you would like to have a copy of the information EF holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at the address EF Invest International AG, att: DPO, Selnaustrasse 30, 8001 Zurich, Switzerland or the email address: [email protected]. If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.