Updated January 1, 2019
EU – U.S. Privacy Shield
Scout Exchange participates in and has certified its compliance with the EU – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce. Scout Exchange is committed to subjecting all personal information received from EEA countries and the United Kingdom, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. Scout Exchange has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such personal information. To view the standards and procedures under which Scout Exchange collects, uses, and retains personal information from EEA countries and the United Kingdom in accordance with our obligations under the Privacy Shield Framework, please follow the link to Scout Exchange’s Privacy Shield Notice. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov.
The Scout Software
The Scout Exchange software platform is a hosted software product provided and hosted by Scout Exchange (the “Scout Software”) that acts as a venue for our hiring company Clients, on the one hand, and workforce Providers (such as search firms, staffing agencies, managed service providers, and other similar providers)(“Providers”), on the other, to match qualified and interested candidates with unfilled employment positions. The Scout Software may be integrated with and accessed through various third-party Applicant Tracking Systems (“ATS”).
The Scout Exchange Website
The Site and Scout Software Software are not directed to persons under the age of 13. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com. We do not knowingly collect or solicit information from, market to or accept services from children. If we become aware that a child under the age of 13 has provided us with personal information, we take steps to remove such information.
Notice and Information Collected
In the course of conducting our business and to provide the Scout Software, Scout Exchange collects and stores certain personal data, including (i) the personal information of persons whose information has been submitted by an application and/or resume by a Provider (“Candidates”), including Candidate names, home addresses, email addresses, and employment history (this information is collectively referred to as “Candidate Resume Data”); (ii) the personal information and time records of Candidates hired as temporary workers for our clients that enter time worked into the Scout Software; and (iii) contact and billing information of certain business partners, Clients, and Providers, including ATS providers, search firms, staffing agencies, managed service providers, employers, and temporary workers who have permission to use the Scout Software (“you” or, collectively with other individuals and entities who have registered to use the Scout Software, “Users”), including job description data, historical placement data, contact information, time records, EIN/TIN, and bank routing information (collectively referred to as “User Data”).
The personal information we collect may be stored on our servers, and on the servers of third party service providers.
Data Controller and Data Processor
In most instances Scout Exchange does not own, control or direct the use of any of the Candidate Resume Data or User Data stored or processed by a Provider, Candidate, or User via the Scout Software. Accordingly, Scout Exchange is generally not acting in the capacity of data controller under the European Union General Data Protection Regulation or other EU data protection law (collectively “EU Law”) and does not have the associated responsibilities under EU Law.
In circumstances where you provide personal information via the Site (such as name, e-mail address, IP address, company affiliation, or similar personally identifying data), Scout Exchange is the data controller of such personal information. This information may be processed both inside and outside of the United States and in instances where Scout Exchange is the data controller of such information it will comply with all associated responsibilities under EU Law or any other applicable data privacy law.
Scout Exchange is not responsible for the content of the Candidate Resume Data or User Data or other information stored on its servers at the discretion of Providers, Candidates, or Users.
Use of Collected Information
Collected User Data is used to make available and to improve our high standard of reliable services. We use User Data to:
- Respond to inquiries or service requests and monitor such responses
- Provide information about and market our products and services
- Provide our services to Clients and Providers
- Resolve problems
- Manage the Site and assess usage of the Scout Software
Candidate Resume Data supplied by Users is used solely to provide and make available our services to Clients and Providers.
Scout Exchange may also use information we collect for other legitimate purposes, including: (i) compliance with foreign law, law enforcement, court and regulatory requirements; (ii) industry watch-lists and industry self-regulatory schemes; (3) information system, network and cyber security; (iv) employment data processing; (v) general corporate operations and due diligence; and (vi) product development and enhancement.
Onward Transfer and Disclosure of Data
Certain User Data that you provide through the Scout Software, including your name, job posting descriptions, and staffing history, may be viewed by other Users of the Scout Software. In addition, we may disclose personal information to appropriate affiliates of Scout Exchange, including strategic alliance affiliates and third-party service providers, to respond to a request for service or to provide information about available products and services. We are not limited in our use of information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our Users and visitors (such as the number of Users of the Scout Software, the geographic distribution of our Users, the amount of information located and/or removed, etc.).
As an integral part of the Scout Software, information regarding the professional background and contact details of individual Candidates may be shared with Users who may consider utilizing such individuals. Unless a specific Client User requires immediate access to Candidate Resume Data to facilitate Scout Exchange’s provision of services to such Client User, Candidate Resume Data supplied by you is not initially viewable by other Users of the Site in personally identifiable form. Instead, Client Users will see non-personally identifiable extracts of Candidate Resume Data, including the Candidate’s first name and last initial, industry experience and general location. If the Client User expresses interest in such Candidate, that User will automatically be permitted to view full Candidate Resume Data for such Candidate, including all Candidate Resume Data. If you upload or otherwise supply Candidate Resume Data to the Scout Software, you agree and acknowledge that you have read and understand the foregoing and represent that you have obtained all the necessary consents from Candidates to disclose such information. You understand that in providing the Scout Software we must rely on your representation and warranty that you have all the necessary rights to provide the Candidate Resume Data for incorporation, use and, potentially, disclosure, as necessary for Users to make use of the Software.
We may disclose information, including User Data and Candidate Resume Data, that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activities, or to conduct investigations of violations of the terms of any agreement you may have entered into with Scout Exchange with respect to your use of the Scout Software. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s User Data contact information to victims who request it.
Scout Exchange may disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified User or limited group of Users, we’ll make reasonable business efforts to contact the User(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the User(s) in all cases, whether because of a time limit, court order, inability to effectively contact a User, or for any other reason.
Scout Exchange shares information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, services, Scout Software and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect your information and are prohibited from using your personally identifiable User Data or Candidate Resume Data for their marketing purposes.
Deleting or Correcting Personal Information
Upon request Scout Exchange will provide you with information about whether we hold any of your personal information. If you would like to have your personal information removed from Scout Exchange’s database, or would like to correct or delete an error in such information, please contact us at firstname.lastname@example.org. If Scout Exchange is the controller of such information we will use reasonable efforts to comply with your request. Otherwise you should contact the appropriate Provider or User who is the controller of your personal information as described in more detail below. Regardless, we will respond to your request within 30 days.
We will retain your information for as long as your account is active or as needed to provide services to our Candidates, Providers, and Users. We will retain and use your information as necessary to comply with our legal obligations, contractual obligations, resolve disputes, and enforce our agreements.
Choice and Opt-Out
We provide you the opportunity to “opt-out” of having your User Data used for certain purposes when we ask for this information. For example, if you do not wish to receive marketing material from us, you can indicate your preference in the Site’s option area. If you no longer wish to receive our promotional communications, you may opt-out of receiving them by following the unsubscribe instructions included in each communication. We may send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.
Information Related to Data Collected through the Scout Software
Information Related to Data Collected for our Clients
Scout Exchange collects information under the direction of its Clients and Providers and has no direct relationship with the individuals whose personal data it processes. If you are a Candidate whose information has been provided to us for inclusion in the Scout Software and you would like to request not to be contacted by one of our Clients or Providers that use the service or to have your Candidate Resume Data be removed or updated, please contact the recruiter or ATS provider that is responsible for supplying your information. If you are not sure which third party(ies) has supplied your information, please contact us via email at email@example.com and we will attempt to provide you with all the necessary contact information to initiate the removal or update of your information within a reasonable timeframe. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients and Providers.
If you are a User who has provided Candidate Resume Data, such as by using the Scout Software and uploading such Candidate Resume Data, you agree that in the event you are contacted by any Candidate requesting the removal or update of that Candidate’s information, you will promptly take all necessary actions to give effect to such update or removal, including but not limited to notifying Scout Exchange of such request.
Access and Data Integrity Controlled by Our Clients and Providers
Scout Exchange acknowledges that you have the right to access your personal information. You must immediately update your User Data when and if it changes so that we can maintain accurate data about you. Clients and Providers registered to use the Scout Software designate an account administrator responsible for managing their account. You may contact your account administrator to update, correct or delete the content and accuracy of your information. Although you may change your User Data, Scout Exchange may retain in backup or inactive files the uncorrected or outdated User Data. Such User Data may be retained for several reasons, including backups for disaster recovery planning, dispute resolution purposes, troubleshooting, enforcement of agreements, or to comply with our legal obligations. Therefore, you should not expect that all of your historical User Data will be removed from our databases at the time you notify us of changes. Scout Exchange reserves the right to correct personally identifiable User Data to make it current and consistent with data directly provided by you.
Scout Exchange takes reasonable security measures such as password protection, encryption, physical locks, etc. as it deems appropriate to protect the information it collects from loss, misuse, unauthorized access, disclosure, alteration and destruction. Employees authorized to access User Data and Candidate Resume Data are required to take the appropriate safeguards to protect the User Data and Candidate Resume Data. Information gathered on the Site and by the Software is encrypted and protected with transport layer security (TSL) encryption. Only the individual User and Scout Exchange personnel (solely on a need-to-know basis) have access to User Data, (except job posting descriptions or other User Data required for Scout Software to provide its function, which are accessible by other Users). All information collected from Users by Scout Exchange is stored on servers hosted in a physically secure environment. Questions about the security of the Site or Scout Software should be directed to firstname.lastname@example.org. Notwithstanding the foregoing, Users should keep in mind that the Site and Scout Software are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security. Users are required to keep their Scout Exchange passwords confidential. Scout Exchange is not responsible for misuse of passwords. Users should advise Scout Exchange immediately if they believe their passwords have been compromised.
Social Media Widgets
If you choose to use our referral service to tell a friend about our Site, we will ask you for your friend’s name and email address. We will add your friend’s name and address to our database. They will have the option to unsubscribe whenever they receive an email from us.
Your friend may contact us at email@example.com to request that we remove this information from our database.
DATA PROTECTION OFFICER
Scout Exchange has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. We will provide you with the contact information for our Data Protection Officer by contacting us at firstname.lastname@example.org.
501 Boylston Street
Boston, MA 02116