Employee Privacy Notice

Effective Date: July 23, 2021

Introduction

iCIMS, Inc. and its subsidiaries, iCIMS International, LLC, Jibe, Inc., TextRecruit, Inc., Opening HR Limited, EasyRecrue S.A.S., and Altru Labs, Inc. (collectively, “iCIMS,” “we,” or “us”), respects the privacy of its employees (collectively, “employee(s) or “you”), and we are committed to protecting their respective personal data. To that end, we have put together this Employee Privacy Notice (“Employee Privacy Notice”) to give you a better understanding of who we are and our practices with respect to the collection, use, disclosure, and retention of personal data obtained in connection with employment at iCIMS.

To see information about iCIMS’ collection of job applicants’ personal data, please visit the iCIMS’ Job Applicant Privacy Notice.
For purposes of this Privacy Notice:

• The term “employee” refers to all current and former employees, directors, officers, and Board members of iCIMS. For the purposes of this Employee Privacy Notice, it also refers to independent contractors engaged by iCIMS, even though they are not otherwise employees.
• The term “personal data” means any information which relates to an identified or identifiable, living individual that directly or indirectly references one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity. Personal data excludes anonymous data.
• The term “sensitive personal data” means personal data of children, or personal data that reveals information about a living individual’s physical or mental health, racial or ethnic origin, political or religious views, trade union membership, sexual orientation, genetic information, biometric information, commission or alleged commission of crime or related proceedings, and, in some countries, financial information.

Please take the time to read this Employee Privacy Notice and the related statements in their entirety to ensure you are fully informed. If you have any questions or concerns about our processing of your personal data, please contact us by using the contact details under the “Contact Information” heading below.

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Compliance with Local Laws

This Employee Privacy Notice is a general guide on how iCIMS processes its employees’ personal data. As such, employees should be aware that data protection and privacy laws can vary in different jurisdictions where iCIMS operates and has employees. iCIMS’ policy is to comply with applicable laws, including requirements in certain countries that iCIMS notify its employees in that country of its personal data practices, and in some cases, obtain consent to those practices.

Where applicable laws are stricter than the practices described in this Employee Privacy Notice, iCIMS has adopted specific privacy practices in those locations to satisfy those stricter requirements.

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How We Obtain Your Personal Data

As further described below, we collect several types of personal data from employees, such as the following:

• Identification data. Such as your name, gender, photograph, date of birth, employee identification number, driver’s license, and languages.
• Contact details. Such as home address, telephone, email addresses, and emergency contact details.
• Employment details. Such as job title, position, office location, hire dates, employment contracts, performance and disciplinary records, grievance procedures, and sickness and holiday records.
• Educational and professional background data. Such as academic and professional qualifications, education records, CV/résumé, reference letters, interview notes, and criminal records data (for vetting purposes, where permissible and in accordance with applicable law).
• National identifiers. Such as national ID, passport, immigration status and documentation, visas, social security numbers (for US only), and national insurance numbers.
• Spouse, beneficiary, and dependents information, and marital status.
• Financial data. Such as banking details, tax information, payroll information, withholdings, salary, bonus, benefits, expenses, and company allowances.
• Health data. Such as information about short- or long-term disabilities or illnesses that you might share with your HRBP or manager, particularly in relation to any leave of absence you may need to take.
• IT data. Such as information required to provide and monitor access to iCIMS’ IT systems and networks, specifically including IP addresses, log files, login information, and software and hardware inventories (for further information about how we process IT information, see our “Monitoring” section below).
• Other data you may choose to share with us, such as hobbies, social preferences, or survey data.

We may also collect certain demographic data that qualifies as sensitive personal data, such as race, ethnicity, sexual orientation, and disability to help us understand the diversity of our workforce. When collected, this sensitive personal data is generally done so on a voluntary consensual basis.

Most often, the personal data we collect from employees is collected from them directly. In some cases, we may collect personal data about employees from third parties; for example, when we perform background screening checks that are necessary for the role to be performed by the employee. In most circumstances, we will get your permission before we collect personal data about you from a third party.

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect it. If we ask you to provide personal data that we consider to be mandatory for us to administer your employment relationship, we will inform you of such at the time of collection. In addition, we will also inform you of the consequences for not providing us with the mandatory personal data.
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How We Use Your Personal Data

iCIMS uses employees’ personal data that it collects primarily for the purposes of managing its employment relationship with its employees, along with other legitimate, business purposes. Such uses include:

• Determining eligibility for hiring, including the verification of references, qualifications, and criminal records checks data (for certain vetting purposes, where permissible and in accordance with applicable law);
• Administering payroll and benefits, processing employee work-related claims (e.g., worker compensation, insurance claims, etc.), and processing leave of absence requests;
• Establishing training and/or development requirements;
• Reviewing work performance and determining performance requirements;
• Enforcing disciplinary actions or termination;
• Establishing emergency contacts and responding to emergencies;
• Complying with applicable laws (e.g., labor and employment, health and safety, tax, and anti-discrimination laws), judicial requests from courts of competent jurisdiction, or exercising or defending legal rights;
• Compiling internal directories, such as employee directories;
• Preventing and detecting fraud or other types of wrongdoing;

• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred;

• Implementing and administering IT security;
• Fulfilling the purpose for which you provide it; and
• For other lawful or legitimate purposes, which may be reasonably required for day-to-day operations, such as accounting, financial reporting, and business planning.

If we need to process your personal data for an incompatible purpose not discussed in this Employee Privacy Notice, 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 only where required by applicable law. Lastly, iCIMS does not subject its employees to automated decision-making.

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How We Share Your Personal Data

iiCIMS takes care to allow your personal data to be accessed only by those who need such access to perform their tasks and duties, and to third parties who have a legitimate purpose for processing or accessing it. As such, we may share your personal data as described in this Employee Privacy Notice to the following categories of recipients:

• To other employees.
• To our subsidiaries, affiliates, or their or our successors or assigns.
• To our private equity investor, Vista Equity Partners, and its affiliates, contractors, service providers, and other third parties, including Vista Consulting Group, which will process the personal data on the basis of its legitimate interests in overseeing the administration, research, and business operations of iCIMS.
• To our contractors, business partners, service providers, and other third parties who require the data to assist us in establishing, managing, or terminating your employment with us, including third parties that provide products or services to us and, by extension, to our employees.
• To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case, personal data held by us about you will be among the assets transferred to the buyer or acquirer.
• To a third party under the following circumstances where we, in good faith,: (i) believe we are compelled by applicable law or regulation, judicial request from a court of competent jurisdiction, or another legal process or government authority; (ii) find it necessary to exercise, establish or defend our legal rights; (iii) seek to protect iCIMS’ rights or property; (iv) seek to protect iCIMS, our other customers, or the public from harm or illegal activities; (v) seek to respond to an emergency which we believe, in good faith requires us to disclose data to prevent harm; and (vi) rely on your consent.

Please note that we do not sell (as defined in applicable data protection and privacy laws) your personal data (and will not sell it without providing any required notices and/or opt-in/opt-out rights).

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Legal Basis for Processing Personal Data

If you are an employee in the European Economic Area (“EEA”) or United Kingdom (“UK”), our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the context in which we collect it. However, we will normally collect personal data from you only where we need the personal data to carry out our employment contract with you, where we need the personal data to comply with our legal obligations or exercise rights in the field of employment, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some limited cases, we may need the personal data to protect your vital interests or those of another person; for example, we may need to share your personal data with third parties for security reasons (when we believe in good faith that disclosure is necessary to protect our rights, protect your or others’ safety, to investigate fraud, or respond to a related government request).

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your personal data is mandatory or not (as well as the possible consequences if you do not provide it). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of a third party) that are not listed above, we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in the “Contact Information” section below.

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Monitoring

iCIMS physically and electronically monitors its offices, information technology systems, and corporate network for specific, lawful purposes. Where permitted by applicable law, iCIMS may monitor or record activities that involve employee personal data. For example, we may monitor employees’ activity and presence in our offices with badge readers, sign-in technology, and surveillance cameras, or we may monitor or record employees’ activity on our information technology systems and corporate network, such as internet traffic, website filtering, email communications, or systems accessed. We generally conduct monitoring to protect our employees, authorized visitors, and property, and to prevent unauthorized access to our offices.

In addition, iCIMS may carry out monitoring for other purposes such as:

• Validating business transactions;
• Training and evaluation of employee performance;
• Protecting confidential information, intellectual property, and other business interests;
• Investigating breaches of iCIMS policies and procedures, or other unlawful or improper acts;
• Complying with legal obligations; or
• Any other legitimate purpose permitted by applicable law.

iCIMS’ monitoring activities will be done in a manner that is proportionate to the underlying purpose and only as required or permitted by applicable law.

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