CDW Privacy Notice for Job Applicants
Updated: November 2024
CDW is committed to protecting the privacy and security of your personal data. We encourage you to read this privacy notice in its entirety. If you have any questions, you may reach out to the CDW privacy team at [email protected].
As a recruit or job applicant to CDW, we process personal information about you during and after your application. This privacy notice (“Notice”) explains how we may collect, process, store and sometimes transfer personal data to third parties to support your application or recruitment process with CDW and our business operations.
CDW has prepared this Notice for its current and former job applicants and recruits, and it applies to anyone whose personal information CDW may collect in the context of applying to or being recruited to work at CDW.
We may update this Notice from time to time, for example if we start to use new systems or processes that use your personal information. This Notice is not a contract, and does not create any legal rights or obligations, and is not intended to replace other notices or disclosures we may provide to you in connection with your relationship with our organization. If this Notice conflicts with any of those other notices or disclosures, they will take precedence.
More Simply Put:
Because you apply to or are recruited to work for CDW, we have to process some data about you. This Notice is intended to help you understand what data we process and why, and the rights you have. We might update this document now and then.
As used in this Notice, Personal information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual person (like you!). It may not include aggregated or deidentified data that cannot be reasonably linked to you. To the extent that we deidentify information, we will implement reasonable safeguards to ensure that the information remains deidentified unless reidentification is required pursuant to applicable law.
Our Collection & Use of Personal Data
We usually collect personal information directly from you, but sometimes we collect it automatically when you interact with our office, network and systems. We may also collect your personal information from other sources and third parties, such as recruiters and references if authorized or required by applicable law.
Collection of Personal Information
We may collect, store, and use the following categories of personal data about you:
Identification and Contact Information, such as your name, home address, phone number, email address, and work authorization information (if applicable). We may provide this information to service providers, regulators, and or with other third parties as authorized or required by law.
Professional & Employment-Related Information, such as the information on your resume, reference letters, interview notices, academic/professional qualifications, educational background, awards and achievements, professional licenses, and other information relevant to your potential employment or professional working relationship with us. We may provide this information to service providers, or with other third parties as authorized or required by law.
Financial Information, such as your desired salary or hourly pay, bonus, benefits, expenses, stock or equity grants, and other similar information.
Background Check & Drug Screen Information, When permitted by applicable law, we may choose to conduct a background check with information such as criminal history, verification of employment and educational history.
Unless prohibited by local laws, Protected Classification Characteristics, If you choose to provide it, and where we are permitted to collect it, information such as race, ethnicity, national origin, citizenship, sex, gender identity, religion, disability or accommodation request, marital status, veteran status, and similar information (this information will not be used in the hiring decision unless specifically permitted by law). For more information, please see the "Sensitive Personal Information" description below.
Unless prohibited by local laws, Sensitive Personal Information, such as your Social Security information, driver's license or government issued identification number, and certain Protected Classification Characteristics (where permitted by applicable law).
We may provide this information to regulators, or with other third parties, as authorized or required by law. We do not sell or share your Sensitive Personal Information.
When authorized or required, we only use and disclose your Sensitive Personal Information for purposes that do not infer characteristics about you.
Internet and Other Electronic Network Information (in case of online job application), such as your log files, login information, information relating to your usage and activities on CDW websites and information collected from cookies. We may provide this information to service providers or with other third parties as authorized required by law. For more information on how we use cookies, please refer to our Cookie Notice for more information, including how to exercise your rights to opt out of cookies.
Unless prohibited by local laws, Information Subject to Protection Under California Law, such as the Sensitive Personal Information, your signature, and your educational history. We may provide this information to service providers, regulators or with other third parties as authorized or required by law.
Unless prohibited by applicable law, CDW only uses your Sensitive Personal Information to deliver its services, perform certain internal business functions, and as otherwise permitted under applicable law.
To the extent that we collect information of individuals under the age of 16, it will be in their role as your dependent or beneficiary. We do not sell or share that information.
Use of Personal Information
We collect and process personal information for a variety of reasons and only where we have a valid legal basis for doing so. If you accept an offer from us, we may transfer the personal information we collected about you during the recruiting and job application process to your personnel file.
| USE | LEGAL BASES (under GDPR when applicable) | TELL ME MORE |
|---|---|---|
| Talent Management & Recruiting | To take steps prior to entering into a contract | Identifying potential candidates for positions with CDW, marketing job opportunities to candidates, reviewing applications, determining eligibility and suitability for positions, facilitating the recruiting and interview process, communicating with applicants and recruits, making offers, and other related uses. |
| Verification & Source Checking (only if authorized or required by applicable law) | To take steps prior to entering into a contract | Verifying the information provided to us in connection with applications, speaking to references, conducting background checks when applicable, and other related uses. |
| Talent Pool | Your consent | Including you in CDW’s talent pool in the event of unsuccessful job application in order to inform you about new professional opportunities within CDW Group that might interest you. |
| Compliance, Prevention & Detection of Crime | Legitimate interest of CDW in defending its rights and interests | Uses such as monitoring compliance with our obligations and HR policies, doing mandatory and best-practice reporting, conducting internal investigations, preventing and detecting violation, taking actions against breach, managing any dispute or litigation and other related uses. |
| IT Administration | Legitimate interest of CDW in securing its networks | Uses such as providing IT systems, providing communication tools, updating IT systems, providing service and support, ensuring security of technology, and other similar uses. |
| Legal & Regulatory | Legal obligations to which CDW is subject as employer | Meeting our legal obligations as employer, including complying with immigration, work permit, and health and safety obligations, providing a non-discriminatory workplace, getting legal advice, managing your requests when you exercise your rights, complying with other laws & regulations, and other related uses. |
| Health & Safety | Legal obligations to which CDW is subject as employer | Uses such as providing a safe workplace by complying with health and safety laws and best practices, providing security for CDW buildings and spaces, minimizing the risk of disease transmission, and other related uses. |
| Internal Processes & Improvement | Legitimate interest of CDW in improving its recruiting and hiring processes | Uses such as assessing and improving the performance and success of our recruiting and hiring processes, analyzing best recruitment practices, making CDW a great place to work, and other related uses conducting vendor management, fulfilling contractual obligations, collaborating and communicating with other CDW entities, and other similar uses. |
When collected, we do not sell or share Sensitive Personal Information as those terms are defined under California law. However, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about individuals directly through our website for purposes of analyzing and optimizing our site, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a "sale" or "sharing" or personal information under California or other law, please refer to our Cookie Notice for more information, including how to exercise your rights to opt out of cookies.
More Simply Put:
There are lots of reasons why we need to collect and process your personal information as part of the job application or recruiting process. We collect information that we need to manage job applications and conduct hiring, comply with our legal obligations as employer, and to assess and improve our recruiting and hiring processes.
Depending on where you live, certain laws may require us to obtain your consent for the processing of certain personal information. Under these circumstances, the provision of your information is voluntary, failure to provide it will not affect your working relationship with CDW, and you can withdraw your consent to the processing of your personal information at any time by contacting the privacy team at [email protected].
How We May Disclose Your Personal Information
Within our organization, your personal information will be accessed to the CDW employees participating in the recruitment process. We may also disclose your personal information with various third parties in order to process your job application and to protect our legal rights. This section provides more information about the types of third parties we may share your personal information with, but not all types of data from each category of personal information are shared with every third party.
| DISCLOSURE | TELL ME MORE |
|---|---|
| CDW Group Entities | Other corporate entities associated with CDW, such as CDW UK in order to globally manage the recruitment process within the group. |
| Service Providers | Third parties we engage to help us identify potential job applicants and managing the recruitment and hiring processes. It also includes background check providers and IT companies. |
| Successor Businesses | In the event of a corporate businesstransaction, such as a merger,acquisition, joint venture, or financing or sale of company assets. |
| Legal Obligations | We may disclose your personal information where we are legally required to do so in order to comply with applicable law, authority’s requests, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena. |
| For Safety and Security Purposes | We may disclose your information to third parties where we believe it is necessary to; investigate, prevent, or take action regarding potential violations of our internal policies, protect our rights and interests, suspected fraud, situations involving potential threats to the safety of any person, and illegal activities; or as evidence in litigation in which we are involved. |
| With your Consent | We may disclose your personal information to a third party if you have given us specific consent to do so. |
More Simply Put:
We sometimes need to disclose your personal information with others in order to process your application with CDW and support the recruitment process. We tell you the types of third parties we disclose information with and what kind of information we share with them in the charts above.
Choices
Canada and California Privacy Rights
Certain additional rights exist if you are a resident of Canada, California (U.S.). This includes a right to access, correct and erase your information.
You also have the right to lodge a complaint with your local supervisory authority.
EU/EEA and United Kingdom Privacy Rights
If you are a citizen of the EU/EEA or the United Kingdom, you have certain rights with respect to your personal information:
| DISCLOSURE | TELL ME MORE |
|---|---|
| Right to access | You have the right to request (i) the confirmation on whether CDW processes your personal information or not, (ii) a copy of such personal information, and (iii) information on the use of your personal information by CDW (as provided in this Notice). |
| Right to rectification | You have the right to request the rectification of your personal information if your personal information is obsolete, inaccurate or incomplete. |
| Right to delete | Under certain circumstances, you have the right to request the deletion of your personal information. |
| Right to restriction of processing | Under certain circumstances, you have the right to request the restriction of the processing. |
| Right to portability | Under certain circumstances, you have the right to request a copy of your personal information in a structured, commonly used and machine-readable format and also can request their transmission to another data controller where technically feasible. |
| Right to object | Under certain circumstances, you have the right to object to our processing of your personal information. |
| Right to withdraw your consent | You have the right to withdraw your consent when it has been obtained. |
| Automated individual decision-making | You have the right to withdraw your consent when it has been obtained. |
Depending on your country of residence, you may have additional local rights with respect to our processing of your personal information.
If needed, you may also lodge a complaint with your national Data Protection Authority.
Exercising Privacy Rights
You may exercise any of these rights at any time by visiting our Privacy Information Request Form. You may also contact the CDW Data Privacy Team at [email protected]. We will respond to your request in the timeframe required by applicable law. We may request proof of identity from requesters.
If you wish to authorize a third party to make a request on your behalf through an authorized agent, your agent must demonstrate authority to act on your behalf. We may also require you to verify your identity directly with CDW or confirm with us that you have provided the authorized agent permission to submit a request on your behalf.
We will not discriminate or retaliate against you for exercising any of your privacy rights identified in this Notice.
Data Retention
In general, we will retain your information for 12 months for the purpose of processing your application and as otherwise permitted by law. We may also retain your personal information if legally required or to fulfill a legitimate interest or another lawful basis for retaining the information beyond the period which is necessary.
If you accept employment with us, your information will be retained for the duration of your employment and as required by applicable law.
Data Storage & Data Transfers
When we share your personal information with CDW group entities, service providers or any other third parties, your personal information may be transferred to and/or made accessible from countries out of the country where you reside.
In addition, information we collect may be stored in the United States. The United States may not afford the same level of protection as laws in your own country and may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country, state, province in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Notice and by applicable laws.
Information we transfer from the UK and the EEA to the United States will be subject to appropriate safeguards under applicable law. Those safeguards may include standard data protection clauses approved by the European Commission. If you want more information about the potential third countries where your personal information is transferred and obtain a copy of the associated safeguards, please contact the CDW Data Privacy Team at [email protected].
Changes to This Notice
We may update this Notice from time to time. When we make changes to this Notice, we will change the date at the beginning of this Notice to include the "Last Updated" date. If we make material changes to this Notice, we will notify you by email to your registered email address, by prominent posting on our website, or through other appropriate communication channels as required by applicable law. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Questions?
To ask any questions related to this Notice or CDW’s applicant and recruitment privacy practices, or to exercise any legal rights that you have related to your personal information, please contact the CDW Data Privacy Team at [email protected].
