Kognitiv Candidate Privacy Notice

Kognitiv Candidate Privacy Notice

Effective Date: September 2025

Kognitiv is committed to protecting the privacy and information including personal information detailed below relating to job applicants and candidates (Personal Data). This Global Candidate Privacy Notice (Notice) is intended to explain how your Personal Data will be handled by Kognitiv and sets out the Personal Data that will be collected and processed by Kognitiv and/or on its behalf by its third-party service providers in the context of your seeking employment or engagement opportunities with us, including where:

  • You participate in a Kognitiv recruitment initiative;
  • You have voluntarily submit your CV to us on an ad hoc basis;
  • You apply for an advertised job within Kognitiv (whether as an employee, contractor or other type of worker of Kognitiv); or
  • A recruiter provides your CV to us and we arrange a job interview with you.

IMPORTANT:

when we receive your CV via a recruiter with whom you have engaged with, we encourage you to read the relevant recruiter's privacy notice to understand how your Personal Data is processed by such a recruiter who is a controller of your Personal Data independently of Kognitiv.

1. Application of This Notice

This Notice applies to all applicants and candidates applying for positions with us in any of our global locations (each of whom is referred to as an applicant). It sets out how Kognitiv processes Personal Data collected during the recruitment process.

If you commence employment or an engagement with us, the way we process your Personal Data will no longer be dealt with under this Notice. It will instead be governed by our applicable personnel privacy notice (which will be made available to you when you commence your employment with us).

2. Who We Are

The controller of your Personal Data is Kognitiv, a global professional services firm specializing in Workday services. Depending on your relationship with us, references to Kognitiv in this Notice mean:

  • Kognitiv Inc, 1340 Centre St 208 Newton, MA 02459, US;
  • Kognitiv Inc, 161 Bay Street, Office 2610, Suite 2700, Toronto, ON M5J 2S1, Canada
  • Kogtech Ireland Limited, Fifth Floor, Block D, Iveagh Court, Harcourt Road, Dublin 2, D02 VH94, Ireland; or
  • any other entities in the Kognitiv group from time to time.

We are required to provide you with the information in this Notice which explains how your Personal Data will be processed by Kognitiv and your data protection rights under: (1) the General Data Protection Regulation (GDPR); (2) the Personal Information Protection and Electronic Documents Act (PIPEDA); (3) the California Consumer Privacy Act (CCPA) and (3) any other state, federal or applicable laws (together, Applicable Data Protection Laws). Where required, local addenda may supplement this Notice.

Please be aware that some rights and protections under the Applicable Data Protection Laws may only apply to individuals resident in Europe (i.e. the European Union).

If you have any questions about how we use your Personal Data or to exercise your data protection rights contact.

3. What Personal Data Do We Collect About You

IMPORTANT:

Please note that the below list of Personal Data we collect about you, is intended to be as complete and accurate as reasonably possible but it, may be updated from time to time in accordance with section 10 of this Notice.

We collect and process some or all of the following Personal Data about you:

Category of Personal Data Details
Identification & Contact Data Full name, address, telephone number, email address, date of birth, social security number (e.g. PPSN), and limited background checks including ID Verification, Employment Verification, Reference Check, Criminal Check, Public Records Check.
Application Data Resume/CV details, cover letter, employment history, education history, professional qualifications, skills, references and referee details, interview notes, interview results, feedback from recruiters or hiring managers, compensation expectations, working location preferences.

4. Sources of Your Personal Data

Personal Data will be collected and processed during the course of your relationship with us as an applicant and for a period after such relationship ends. During the course of your relationship with us as an applicant, we will collect Personal Data:

From you: for example, through job applications, CVs/resumes, interviews, or communications with our recruitment team, including via your candidate home account in Workday, or information you otherwise provide directly to us; and

From third parties about you: including information from recruitment agencies, job boards and professional networking sites (e.g., LinkedIn, Indeed), employment references from your referees and previous employers, referral information from current employees, information from statutory and regulatory authorities, and occasionally some additional sources (e.g. background check providers), and other publicly available sources containing information relevant to your application.

5. How and Why We Process Your Personal Data

The following table details the key context for which (Legal Basis) we collect your Personal Data. It also explains how (Nature of Processing) and why (Purposes) we obtain and otherwise process your Personal Data. We will only use your Personal Data for the purposes for which we collect it (as outlined in this section 5), unless we reasonably consider that we need to use it for another reason and that reason is incompatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the Legal Basis which allows us to do so.

Legal Basis Nature of Processing and Purposes Category(ies) of Personal Data
Legitimate interests
Personal Data based on our legitimate interests, including make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data where our interests are overridden by your interests or fundamental rights and freedoms (unless required or permitted by law).		 We will obtain, collect, retain and process your Personal Data where it is necessary for the purpose of the recruitment process, including:
- To process your job application;
- To contact you in relation to interviews to assess your candidature profile;
- To assess your candidate profile against vacancies which we think may be suitable for you;
- To verify details you have provided to us using third party sources;
- To request information from third parties such as qualifications and references;
- To carry out limited background checks;
- To retain your information (should you be unsuccessful) in order to contact you within Kognitiv that may be of interest.		 Identification & Contact Data
You have a right to object at any time to the processing of your Personal Data on the basis of our legitimate interests (see section 9 of this Notice, Your Data Protection Rights). To maximise the number of potential candidates who are informed about job opportunities;
- To collect feedback on and evaluate the recruitment process;
- To promote internal and external vacancies;
- To comply with non-European laws to which we may be subject (in Canada, the UK and the US);
- To establish, defend and exercise any actual or potential legal claims.		 Identification & Contact Data
Obligations with Legal Compliance
It is necessary to process your Personal Data in order to comply with legal obligations imposed on us as an applicable Irish and European Union laws.		 We obtain, collect and process your Personal Data:
- To comply with applicable Irish / European Union employment, equality and health & safety laws;
- To comply with other applicable Irish and European Union laws.		 Identification & Contact Data
Application Data

6. Who We Share Your Personal Data With

Depending on Kognitiv's reasons for processing your Personal Data, we may share your Personal Data with some or all of the following recipients (Recipients):

Recipients Details
Kognitiv business units / Our support staff / Our Board of Directors
  • Internal business units such as human resources, IT, finance/payroll, managers, system administrators and support staff who have advertised a vacancy within their unit or who will interview you and legal.
  • Our Board of Directors
  • Any other group companies which form part of Kognitiv from time to time.
Third Party Service Providers
  • Your previous employers where you identify them as references.
  • Recruitment agencies and platforms.
  • Background check providers.
  • Outsourced service providers who assist us with recruitment initiatives and campaigns.
Third Party Advisors / Professionals
  • Service providers who provide support services or require use of (e.g. IT systems and business-related applications).
  • External advisors e.g. tax or legal advisors, consultants and auditors (as legal advisors, consultants and auditors (as necessary to protect our legitimate and legal interests).
Legal / Regulatory Bodies
  • Regulatory authorities and law enforcement agencies (where we are under a duty to disclose or share your Personal Data in order to comply with legal or regulatory obligation or request) such as government authorities and bodies or law enforcement, courts and out-of-court administrative bodies.

7. International Data Transfers

As a global company, our operations will be carried out within Europe and outside Europe (including Canada, the United States and India). If you are resident in Europe, we may share or transfer your Personal Data to Recipients in, or store your Personal Data in, countries with laws and practices which may not have equivalent data protection and privacy rules to those that apply under Applicable Data Protection Laws in Europe. Where these transfers occur, we ensure that a transfer mechanism is in place and appropriate safeguards protect your Personal Data:

  • For transfers (including, onwards transfers) of your Personal Data to Recipients within Kognitiv, we rely on the EU Standard Contractual Clauses (SCCs) (e.g. United States).
  • For transfers (including, onward transfers) of your Personal Data to other Recipients, we rely on the SCCs, adequacy decisions of the European Commission (e.g. for transfers to Canada) or other transfer mechanisms under the GDPR.

8. Retention of Your Personal Data

Successful Candidates: Where you are a successful job applicant, the Personal Data generated by us and provided by you over the course of the job application/recruitment process will be retained by us for the purpose of your contract of employment/for services. Such Personal Data will be retained in accordance with our applicable personnel privacy notice (which will be available to you when you commence employment).

Unsuccessful Candidates: Where you are an unsuccessful job applicant, we will retain your Personal Data for a period of up to 3 years after you attend an interview or submit a job application for the purposes of both contacting you in relation to future vacancies within Kognitiv which we think may be of interest to you and, for the purpose of defending potential claims which you may bring against us (e.g. employment equality claims in Europe).

Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that applicable laws or a relevant regulator may reasonably, in our view, expect or require us to retain your Personal Data.

9. Your Data Protection Rights

Depending on Applicable Data Protection Laws in your country of residence, you may have a number of rights in relation to Personal Data, some of which are set out below for personnel in Europe. In particular, these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that these rights are not absolute.

We will aim to respond to any data subject rights request within one month of receiving it. We may be required to extend the timeline of our response by 2 further months if necessary, however, we will contact you if this need arises. Please also note that we may need to verify your identity when you exercise your data protection rights.

To exercise these rights or ask questions, please contact.

Right to Information You have a right to be provided with clear, transparent and easily understandable information about how we process your Personal Data. We give effect to this right by making this Notice available to you.
Right to Object You have a right to object to our processing of your Personal Data. You may request that we stop processing your Personal Data, unless we can demonstrate compelling legitimate grounds to continue processing your Personal Data or if we need your Personal Data in connection with any legal claims.
Right of Access If you exercise this right, you will receive confirmation about whether we process your Personal Data and, if so, a copy/copies of your Personal Data.
Right to Rectification If the Personal Data we hold about you is inaccurate or incomplete, you have the right to correct the Personal Data or process about you.
Right to Erasure You have a right to request, in certain circumstances, the deletion of your Personal Data - for example if you exercise the right to object and we do not have an overriding reason to continue processing your Personal Data or if we no longer need to process your Personal Data.
Right to Restriction You have the right, in certain circumstances, to restrict our processing of your Personal Data - for example, if you contest the accuracy of the Personal Data we hold about you or you object to us processing your Personal Data.
Right to Lodge a Complaint You have the right to lodge a complaint with the Data Protection Commission (DPC) or another applicable data protection authority about our processing of your Personal Data. To do so with the DPC, use the DPC's "Raise a Concern" form. We encourage you to contact us before raising a concern with the DPC to see if we can resolve any concerns you have about our processing of your Personal Data. Contact details for other data protection authorities in the EU are available here: link. We encourage you to engage with us before any concerns or complaints - we seek to amicably resolve your specific complaint.

10. Changes to This Notice

We may review, revise and update this Notice periodically as necessary in response to changing legal, technical or business developments. Updated versions will be posted on our Trust Portal.

If we amend this Notice, in whole or in part, at our sole discretion, any changes will be effective immediately upon making the revised Notice available to you.

11. Contact Us

For any data protection-related inquiries or concerns about the way your Personal Data are being used or processed by Kognitiv, please contact:

Email: privacy@kognitivinc.com

By submitting your application, you acknowledge that you have read and understood this Notice. For region-specific details, please review the applicable addenda or contact us.