Brown-Forman
Job Applicant Privacy Policy
Last Updated: 05 February 2024
Brown-Forman Corporation and our affiliates (collectively, “Brown-Forman”, “we” “our” or “us”) values your trust and is committed to the responsible management, use and protection of personal information. This Job Applicant Privacy Policy (“Policy”) describes our practices in connection with all the information that we collect throughout the job application process, including but not limited to: through the Careers section of our website (located at https://brown-forman.jobs/) and our Applicant Tracking System (currently powered by Workday) (together, the “Careers Site”) and offline in connection with your application for a job or internship with Brown-Forman. Personal information submitted elsewhere on Brown-Forman’s websites will be used in accordance with our general online Privacy Policy.
COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION
The following chart details which categories of personal information we collect and process during the application process and including at the point when a job offer is made to you, as well as which categories of personal information we disclose to third parties for our operational business and employment purposes, including within the 12 months preceding the date that this Policy was last updated. See the “Disclosure and Transfer of Information” section below for more information on the listed categories of third parties.
Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes |
|---|---|
Identifiers, such as name, alias, postal address, unique personal identifiers, email address, account name, online identifiers, and government-issued identifiers (e.g., Social Security number in the U.S., driver’s license number) | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Personal information (including as defined in the California customer records law), such as name, contact information, signature, Social Security number, passport number; financial, education and employment information, physical characteristics, or description | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Commercial Information, such as travel information and expenses | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Internet or network activity information, such as regarding our website or online application portal, timestamp information, and access and activity logs | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Geolocation Data, such as approximate location of devices used to access our website or online application portal, derived from IP address | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Audio/Video Data. Audio, electronic, visual, and similar information, such as photographs and call and video recordings | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Education Information where permitted by applicable law (including information subject to the U.S. federal Family Educational Rights and Privacy Act) such as student or degree transcripts, and confirmation of graduation | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Employment Information where permitted by applicable law, Professional or employment-related information, such as work history and prior employer, information from reference checks, work experience, qualifications, training and skills, work authorization, CV, résumé, cover letter, professional and other work-related licenses, permits and certifications held, and publicly accessible information posted on your professional social media accounts | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences, characteristics, predispositions, and abilities | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
Sensitive Personal Information where permitted by applicable law. Personal information that reveals an individual’s social security or national insurance number, driving license, ID card, or passport number; account log-in; racial or ethnic origin, health, sexual orientation, religious or philosophical beliefs, citizenship, immigration status, or union membership. Where relevant and permitted under applicable law, Sensitive Personal Information includes ‘Protected Class Information’, such as characteristics of protected classifications under California or U.S. federal law, such as sex, age, gender, race, disability, medical conditions, citizenship, military/veteran status, gender identity and expression, primary language, political affiliation/activities, and immigration status. | Affiliates, Service Providers, Professional Advisors, Public and Governmental Authorities, Business Partners |
We do not “sell” or “share” your personal information, including your sensitive personal information, as defined under the California Consumer Privacy Act. We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not “sell” or “share” the personal information, including the sensitive personal information, of minors under 16 years of age.
PURPOSES FOR THE COLLECTION, USE, AND DISCLOSURE OF PERSONAL INFORMATION
The information that you submit through the job application and selection process will be used for Brown-Forman’s global personnel recruitment, management and planning purposes, as permitted by applicable law:
To process your application. We will engage in these activities based on our legitimate interests;
To assess your capabilities and qualifications for a job, including to facilitate any tests and assessments on the Careers Site. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
To conduct reference checks. We will engage in these activities to comply with a legal obligation or based on our legitimate interests where permitted by applicable law;
To respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and changes to our terms and policies. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
To comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
To analyse and monitor the diversity of job applicants, in accordance with applicable law. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
To conduct background checks if we offer you a position, in accordance with applicable law. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
To preserve our other legitimate interests, for example, for Brown-Forman’s administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business within Brown-Forman and its affiliates;
To comply with applicable law, respond to requests from public and government authorities, and cooperate with law enforcement. This can include laws and authorities outside your country of residence. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
For other legal reasons, such as to enforce our terms and conditions; and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. We will engage in these activities to comply with a legal obligation or based on our legitimate interests; and
In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
With your consent, the information about you will be added to Brown-Forman’s international candidate database and can be retained and used to consider you for opportunities at Brown-Forman and its affiliates other than the one(s) for which you apply. If you wish to withdraw your consent to being added to our international candidate database, please contact us using the address in the “Contact Us” section below.
If we hire you, personal information we collect in connection with your application can be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes.
Providing personal information to us through the Careers Site is voluntary. However, if you do not provide sufficient information, Brown-Forman may be unable to consider your employment application or, if you are hired, your subsequent promotion, transfer, or relocation.
PURPOSES FOR THE COLLECTION, USE, AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION
We will collect, use, and disclose sensitive personal information only where permitted by applicable law. Otherwise, we ask that you avoid submitting information that may qualify as sensitive information under applicable law, except where such information is legally required.
We collect, use, and disclose sensitive personal information for purposes of: performing services on behalf of our business; performing services and providing goods as requested by you; ensuring the quality or safety of services we control or improving those services; ensuring the security and integrity of our infrastructure and the individuals we interact with; short-term transient use; securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure; preventing, detecting, and investigating security incidents; resisting and responding to fraud or illegal activities; and other collection and processing that is not for the purpose of inferring characteristics about an individual, including to meet our obligations to report diversity-related statistics to government authorities, and to carry out equal opportunity monitoring (in each case, such activities are only carried out an aggregate basis and your characteristics will not be shared internally or externally at an individual level for these purposes). We do not use or disclose sensitive personal information for additional purposes.
DISCLOSURE AND TRANSFER OF INFORMATION
We disclose personal information to the following third parties for our operational business and employment purposes:
Affiliates. Brown-Forman shares personal information with affiliates that are involved in evaluating candidates for a given position. Brown-Forman will remain responsible for personal information that is shared with affiliates. You can consult the list and location of our affiliates here [https://legal.brown-forman.com...]. We will limit access to personal information to personnel with a business need to know the information for the purposes described in this Policy, including personnel in the recruiting, human resources, and information technology departments, and in the department responsible for the position for which you are applying.
Service Providers. Brown-Forman also shares personal information with our third-party service providers to facilitate services they provide to us, including hosting and operating the Careers Site, recruiting assistance, and background check processing, consulting, IT and other services.
Professional Advisors. Brown-Forman shares personal information with our professional advisors, such as lawyers.
Public and Governmental Authorities. Brown-Forman shares personal information with regulatory authorities and law enforcement to respond to requests and comply with applicable law.
Disclosing your personal information can include transferring personal information to other countries, including the United States or any other country in which we or our service providers have operations. The list of our affiliates is available here [https://legal.brown-forman.com...].
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By applying for a vacancy, you understand that your Personal Information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Where this will involve transferring your Personal Information from a jurisdiction that restricts cross-border transfers to a country not considered adequate by that jurisdiction, we will implement safeguards, such as data transfer agreements, to protect your Personal Information.
For example: Where this will involve transferring your Personal Information from within the UK and/or European Economic Area (the “EEA”) to outside the UK and/or EEA, we implement the following safeguards, as applicable:
Adequacy Decisions: Some countries outside of the EEA are recognized by the UK government and the European Commission as providing an adequate level of data protection according to EEA/UK standards. The full list of the EEA’s “specified countries” is available here, and the full list of countries and territories covered by the UK adequacy regulations is available here).
For transfers from the EEA and/or the UK to countries not considered adequate by the European Commission or the UK government (as applicable), we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority, to protect your Personal Information. You may obtain a copy of these measures by contacting us using the address in the “Contact Us” section below.
DATA RETENTION
We will retain personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; and (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).SOURCES OF PERSONAL INFORMATION
We collect most of this personal information from you directly. Any information you submit through the Careers Site must be true, complete, and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights. We also collect personal information from other sources in connection with your application as permitted by applicable law. This includes situations where we obtain publicly accessible information available on your professional social media accounts.
If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
For the purpose of background check report in connection with your application, and as permitted by applicable law, Brown-Forman obtains information about you from other sources:
Your references;
Prior employers;
Educational institutions you attended; and
Background check providers.
PASSIVE INFORMATION COLLECTION: COOKIES AND SIMILAR TECHNOLOGY
We and our service providers use “cookies” and similar technologies on the Careers Site. You can adjust your cookie settings through our Cookie Preferences Tool.
RIGHTS REQUESTS
If you register on the Careers Site, you may access, review, and change your personal information stored therein by logging into the Careers Site and updating your account information. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you have already submitted for consideration for a specific position, please update your profile and resubmit your application for that position. We encourage you to promptly update your personal information if it changes or is inaccurate.
To the extent the right is provided to you by applicable law, you may request:
To review, confirm, access, correct, update, suppress, restrict, delete, or object to or opt out of the processing of your personal information;
To obtain more information about the categories and specific pieces of personal information we collected, used, or disclosed, the sources for such personal information, the business and commercial purposes for which we collect personal information, and the categories of third parties to whom it was disclosed; and
To receive an electronic copy of your personal information, including specific pieces of your personal information, and, where applicable, a copy of your personal information for purposes of transmitting it to another company.
To make a request, please contact us at [email protected]. In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database.
We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request further information prior to responding in full to your request, for example, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your personal information. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.
We will try to comply with your request as soon as reasonably practicable. We will not unlawfully discriminate against you for exercising your rights under applicable law.
When provided by applicable law, you may also lodge a complaint with a data protection authority for your country or region, or in the place of the alleged misconduct; see here for list of EU data protection authorities at https://edpb.europa.eu/about-edpb/board/members_en. In the UK, you can contact the Information Commissioners office (ICO) at https://ico.org.uk/about-the-ico/.
California Residents
If you are a California resident and an agent would like to make a request on your behalf as permitted by applicable law, the agent may contact us as described in the “Rights Requests” section below. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the “Rights Requests” section above or confirm that you provided the agent permission to submit the request.
SECURITY
We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Brown-Forman hereby disclaims, as far as permitted by local laws, any liability for itself and Affiliates, Service Providers and Professional Advisors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered, or destroyed or not timely delivered to our Careers Site.
LINKS TO THIRD-PARTY WEBSITES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Careers Site links. The inclusion of a link on the Careers Site does not imply endorsement of the linked site or service by Brown-Forman or our affiliates.
DIVERSITY
Brown-Forman is an equal opportunity employer, which means we offer equal treatment to all applicants, consistent with applicable law. Brown-Forman does not unlawfully discriminate, either directly or indirectly, based on characteristics protected by applicable law, such as: race, colour, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, or genetic information in any area of recruitment.
LAW APPLICABLE TO JOB APPLICATION
The Careers Site allows you to apply for jobs world-wide, as a benefit of Brown-Forman’s centralized global recruitment function. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the United States and may also be subject to U.S. laws.
If we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.
ABOUT CHILDREN
The Careers Site is not intended for minors under the age of 18.
CURRENT PERSONNEL OF BROWN-FORMAN
If you currently work for Brown-Forman or one of our affiliates, you must be eligible to apply for a different position within Brown-Forman to use the Careers Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.
The Careers Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.
CHANGES TO THE POLICY
We reserve the right to amend this Policy at any time in order to address future developments of Brown-Forman, the Careers Site or changes in industry or legal trends. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Careers Site.
CONTACT US
If you have questions or requests, please feel free to contact us at [email protected].
Because email communications are not always secure, please do not include sensitive information in your emails to us.
Contact our data protection officer in Germany, if applicable, via [email protected].
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