Hilton
Applicant Privacy Notice
Last Updated: July 2021
Hilton Worldwide Holdings Inc. and its direct and indirect subsidiaries ("Hilton", “we”, “our” or “us”) value the trust of individuals submitting job applications on the Hilton Careers Site (“you” or “Applicant”) and are committed to the responsible management, use and protection of personal information. This Applicant Privacy Notice (this "Notice") applies to all the information collected by Hilton to facilitate your job application and includes your use of our Careers Site. This Notice explains how Hilton processes the personal information that we collect through the job application process (“personal information”). Please note that this Notice applies only to Hilton’s processing of your personal information on the Careers Site and if you are applying for a Hilton corporate position, or a position at a property that is managed by Hilton. You may be applying for a position at a franchised property in which case, the franchised property will process your personal data in accordance with its own policies and procedures, which may be provided to you via a separate privacy policy.
Personal information submitted to other Hilton web sites will be used in accordance with our Global Privacy Statement.
The Careers Site is operated by Hilton, 7930 Jones Branch Drive, McLean, Virginia, USA 22102, in order to support the recruitment functions of Hilton and Hilton properties. The Careers Site is not intended for distribution or use in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.
Where local laws impose greater obligations or restrictions on the use of personal information, or require additional information to be provided to you, this Notice may be supplemented by local policies or procedures that are specific to a particular region, country or entity. In particular, Appendix A to this Notice includes additional information applicable to Applicants residing in countries that have enacted privacy laws giving certain additional rights to residents of those countries. These countries include, but are not limited to, those in the European Economic Area, the United Kingdom and Switzerland (collectively, the “EEA”), Argentina, Australia, Brazil, Canada, China, Israel, Japan, Kenya, Nigeria, and Turkey. Where additional consent, consultation or other rights exist under local laws, Hilton’s processing of personal information will be subject to the exercise of those rights.
In some locations around the world, Hilton manages hotel properties on behalf of a third party owner. At many of those properties, the Hotel owner (and not Hilton) is the actual employer, and Hilton performs recruiting and hiring functions on behalf of the owner. You understand and agree that, by applying through this site, you may be applying for a position with a company other than Hilton, where Hilton is serving as the recruiter, but will not be your employer of record.
If you accept a position with Hilton or the Hotel owner, you will be considered a Hilton “Team Member” and a separate notice will govern our use of your personal information.
Some positions listed on the Hilton Careers Site are for positions with a franchised property. For these positions, the franchise management company or property owner (and not Hilton) is the actual employer. By providing access to the Hilton Careers site, Hilton does not perform or exercise any direction, oversight or control over any recruiting or hiring functions on behalf of franchisees and allows access to its Careers Site for applicants of these franchise entities as an optional resource only. You understand and agree that, by applying through this site, you may be applying for a position with a franchised property (not Hilton) and Hilton will not be your employer of record.
Your Acknowledgement
Please read this Notice carefully and indicate your acknowledgment and acceptance of our collection, retention, use, transfer and disclosure of personal information as described in this Notice by clicking the "I Accept" button at the end of this Notice.
Your personal information may be transferred to countries outside your home country, including countries where data protection laws may differ from those of your home country.
Hilton maintains safeguards designed to protect your personal information. Please see Appendix A for additional information.
Information We Collect
Hilton may collect personal information in connection with your submitting to apply or searching for a position on the Hilton Careers Site. This includes information you provide as well as passive information collection.
• Information You Provide
• Log-in and password, for users of the Careers Site;
• Information on how you found out about the job;
• Identifiers and contact Information including names and addresses, telephone numbers, mobile telephone numbers, email addresses, dates of birth, Social Security numbers, driver’s license or state identification numbers, bank account information, and other similar contact information and identifiers);
• Professional and employment-related information including:
• data submitted with employment applications including employment history and experience, employment recommendations or references, employment preferences, willingness to relocate, willingness to travel, desired salary, CV, résumé, cover letter, etc.
• background check and criminal history;
• work authorization;
• fitness for duty data and reports;
• Education information including education history such as education level, school, major, certifications held, etc.
• Protected classification information including characteristics of protected classifications under applicable state or federal law by your self-identification (such as Age range, Gender, Religion, Disabled, Ethnic Group).
• Internet or other electronic network activity information including all activity on the Hilton Careers Site or Hilton information systems, such as search history on the Careers Site.
Hilton may also collect the following information from applicants in the United Kingdom and Ireland and other EEA jurisdictions, as well as Canada:
• Right to Work Document Type;
• For Visa/Work Permits, the type of such permit;
• Related to a Right to Work Document or Permit: Document Number, Country of Issue, Place of Issue, Issue Date, Expiration Date.
We do not require, but you may voluntarily choose to provide, other relevant information as part of your application. Please do not submit the following sensitive information unless we specifically request that you provide such information so that we may comply with our legal obligations and/or internal policies relating to diversity and anti-discrimination: sexual orientation, race, ethnic origin, religion, political and religious beliefs, disability, marital status, creed, nationality, national origin, color and/or age.
By voluntarily submitting information about your racial or ethnic origin; physical or mental health or condition; job evaluations or educational records; commission (or alleged commission) of an offence or related proceedings; political opinions or beliefs; religious beliefs; sex life; membership in a trade union or political party, you expressly authorize Hilton to receive and process such information for the purpose of processing your application.
Any information you submit must be true, complete, and not misleading and you must have the lawful right to provide it. If not, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been hired.
If you intend to provide us with details of a reference or any other third party as part of your CV/resume, it is your responsibility to obtain consent from that third party prior to providing his/her personal information to us.
The provision of personal information, including on the Careers Site, is voluntary. Please note however that the failure to provide sufficient information may result in you being unable to be considered for employment.
• Passive Information Collection: Cookies and Similar Technology
We and our service providers may use "cookies" and similar technologies on the Careers Site. Cookies are data that a web server transfers to an individual's computer for record keeping purposes. We use cookies and other technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our Careers Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. However, if you decline session management cookies from Taleo (the third-party that hosts the Careers Site), the Careers Site may not function properly for you.
If you are a resident of certain countries, we are required to obtain your consent before placing certain cookies or similar technology on your computer. We will separately prompt you for this consent before we attempt to place a cookie or similar technology on your computer.
Legal Bases, Use, and Disclosure of Personal Information
The information that you submit on the Careers Site will be stored in the United States (and in the relevant jurisdiction(s) if the job relates to one of our franchise companies or affiliated entities outside of the United States). As a reminder, you may be applying for a position at a franchised property in which case, the franchised property will process your personal data in accordance with its own policies and procedures, which may be provided to you via a separate privacy policy.
The following information may be collected, used, transferred and disclosed by employees, consultants and/or service providers of Hilton around the world for Hilton's global recruitment functions and for related management and planning purposes, including, as permitted by local law, to:
• Maintain personnel records and record retention requirements.
• Prevent unauthorized access to or use of the Hilton’s property, including Hilton’s information systems, electronic devices, network, and data.
• Investigate complaints, grievances, and suspected violations of Hilton policy.
• Design, implement, and promote Hilton’s diversity and inclusion programs
• Improve safety of our facilities for employees, customers and the public with regard to use of Hilton property and equipment.
• Confirm eligibility for employment and related checks regarding fitness for duty.
• Conduct background checks if you are offered a job.
• Comply with applicable state and federal health, labor, employment, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations
Personal information about you will be added to Hilton's international candidate database and may be used for the purposes of considering whether your profile is suitable for other job vacancies at Hilton. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. The processing of your personal information for these purposes is based on your consent. If you become a Team Member, any personal information that you submit may become part of your Team Member file and may be used for other employment/work-related purposes and otherwise in accordance with the Hilton Team Member Privacy Notice.
To the extent any use is inconsistent with or outside of the contemplated uses in this Notice, we will communicate it to you at the time of use.
Personal information about you will be reviewed by Hilton Team Members or agents who have a business need to access such personal information and may include recruiters, human resources personnel, technical services personnel and managers or their designees.
We may share personal information about you with selected service providers or consultants acting on our behalf, such as third parties assisting Hilton with the operation of the Careers Site (including (a) Taleo (with its primary place of business at 4140 Dublin Boulevard, Suite 400, Dublin, CA 94568 USA), which is the Applicant Tracking System and hosts job openings for the Careers Site, (b) Phenom (with its primary place of business at 300 Brookside Ave., Building 18, Suite 200, Ambler, PA 19022), which hosts the Careers Site and talent relationship and content management system, and (c) SHL (with its primary place of business at 1 Atwell Place, Thames Ditton, Surrey, KT7 ONE UK), which conducts job- specific candidate assessments). Those third parties are required by contract to use appropriate measures to protect the confidentiality and security of personal information.
Hilton also may disclose personal information about you in order to:
1. Protect the legal rights, privacy, safety or property of Hilton or its Team Members, agents, contractors, customers or the public;
2. Protect the safety and security of visitors to our web sites or other properties;
3. Protect against fraud or other illegal activity or for risk management purposes;
4. Respond to inquiries or requests from legal authorities;
5. Permit Hilton to pursue available remedies or limit the damages that we may sustain;
6. Enforce our website Terms of Service;
7. Respond to an emergency;
8. Comply with the law or legal process;
9. Effect a license, sale or transfer of a business or assets (including in connection with any bankruptcy or similar proceedings); or
10. Manage acquisitions, mergers and re-organizations.
Data Retention
We are required to retain information relating to candidates applying for jobs within the United States. We will retain your personal information for three years, or a longer time if required or allowable by applicable law, during which time we or a franchise company or affiliate may contact you regarding open positions. Personal Information of candidates applying for jobs in other parts of the world will be retained in accordance with local law. If there is no activity in relation to the personal information, Hilton may remove it from its database, subject to Hilton's data retention obligations and policies and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities.
Note that Hilton may delete personal information about you at any time (including your CV/resume), without any reason. Therefore, please retain your own copy of the personal information provided to us.
Access, Correction and Deletion
If you choose to register on the Careers Site, you may access, review, and change some of the personal information collected about you and stored on the Careers Site by logging into the Careers Site and choosing to update 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 already have submitted for consideration for a specific position, please resubmit your application to update personal information about you that is associated with that job application. We encourage you to promptly update your personal information if it changes or is inaccurate. Upon your request, we will deactivate or remove your personal information from our active databases, although some information may be retained as permitted or required by law.
If you have any questions or concerns about how we otherwise process personal information please contact us at the e-mail link below.
[Click here to send an email to DataProtectionOffice@hilton.com]
You may access, modify or object to the use of personal information as permitted by applicable local law. Applicants who would like to review, update, or request that we delete their personal information should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA. Please note, however, that certain personal information may be exempt from access, correction or deletion rights pursuant to applicable data protection laws. If you are a resident of a country that grants you certain rights with respect to your personal information (such as EEA residents), you may have other rights with respect to your personal information, which are explained in Appendix A.
Career Site Security
We take reasonable precautions to safeguard the personal information transmitted between visitors and the Careers Site and the personal information stored on our servers. Unfortunately, no method of transmitting or storing data can be guaranteed to be 100% secure. Do not send sensitive information via email. It is your sole responsibility to use the appropriate level of care whenever communicating with us.
If you have reason to believe that your interaction with us is no longer secure (for example, you feel that the security of any account you might have with us has been compromised), you should immediately notify us of the problem by contacting us at the link below.
[Click here to send an email to ISC@hilton.com]
Hilton hereby disclaims, as far as permitted by law, any liability for itself and its affiliated companies and contractors for any of your information sent to our Careers Site that is lost, misused, illegally accessed, disclosed, altered or destroyed or not integrally or timely delivered to our Careers Site.
Links to other websites
The Careers Site may contain links to other websites. The operators of those other websites may collect information about you, through cookies or other technologies. If you link to another website, you will leave the Careers Site and this Notice will not apply to your use of and activity on those other sites.
If you provide personal information through or on any other site, your transaction will occur on that website (not the Hilton Careers Site) and the personal information you provide will be collected by, and controlled by, the privacy policy of that website operator.
Links on the Careers Site to other websites are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site. We encourage you to read the legal notice posted on those sites, including their privacy policies. We have no responsibility or liability for your visits to, or the data collection or use practices of, other sites.
Law Applicable to Job Application
The Careers Site allows you to benefit from Hilton's centralized global recruitment function, while applying for jobs worldwide. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the U.S. and will be subject to U.S. laws. However, if we share your personal information with a Hilton entity located in another country in its capacity as a potential employer (or acting as recruiter for a Hotel owner), the Hilton entity will handle your personal information in accordance with this Notice. Franchisee entities may handle your information pursuant to a separate privacy notice they may provide to you. Any hiring or other employment-related decisions will be made by the hiring entity in accordance with the laws of the country where the job will be located. Please see Appendix A for additional information on International Data Transfers.
About Children
The Careers Site is not intended for minors under the age of 15 or the lawful age of employment (whichever is greater) in any country in which we operate.
Changes to the Notice
We reserve the right to amend this Notice at any time without advance notice in order to address future developments of Hilton, the Careers Site or changes in industry or legal trends. We will post the revised Notice on the Careers Site or announce the change on the home page of the Careers Site. You can determine when the Notice was revised by referring to the "Last Updated" legend on the top of this Notice. Any changes will become effective upon the posting of the revised Notice on the Careers Site. By continuing to use the Careers Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose to not continue to use the Careers Site.
Additional Privacy Provisions for Applicants from Certain Countries
Please see Appendix A for additional provisions that pertain to you if you are a resident of a country that has enacted a privacy law granting additional rights to residents of that country.
APPENDIX A
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF APPLICANTS FROM COUNTRIES WITH PRIVACY LAWS GRANTING ADDITIONAL RIGHTS TO INDIVIDUALS
For applicants from countries that have enacted privacy laws granting additional rights to individuals, this Appendix outlines certain additional information that Hilton is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws.
Hilton Controller:
Hilton Domestic Operating Company Inc. is the data controller with respect to your personal information and can be contacted by email at DataProtectionOffice@Hilton.com or at the following address:
Hilton Data Protection Officer
7930 Jones Branch Drive
McLean, Virginia 22102 USA
Purposes and Legal Basis for Processing
Hilton processes your personal information for the purpose of either recruiting and evaluating candidates for employment, or to allow franchisee entities to access your personal information if you are applying for a position at a franchised property. Hilton processes your information pursuant to its legitimate business interests and, in some cases, based on your consent.
Data Subject Rights
Access, Correction and Erasure Requests: Applicants who would like to review, update, or request that we delete their personal information should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA. Please note, however, that certain personal information may be exempt from access, correction or deletion rights pursuant to applicable data protection laws.
Restriction Requests: Applicants who would like to request that Hilton cease processing of certain personal information should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA.
Please note, however, that certain personal information may be exempt from such requests pursuant to applicable data protection laws.
Data Portability Requests: Applicants who would like to request a copy of certain of their personal information, or request that such personal information be transmitted to a third party, should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA. Please note, however, that data portability rights apply only in limited circumstances and to limited data sets.
Disclosures of your Information
In order to administer and manage the job application process, and to otherwise perform the activities set forth in this Notice, your information will be shared with other Hilton personnel, such as personnel responsible for hiring determinations, members of the human resources team, as well as other employees and individuals within Hilton involved in the recruitment and selection process. Hilton will provide franchisee entities with access to your information if you are applying for a job with a franchise property.
Your information will be shared with various third party service providers engaged by Hilton to support its recruitment efforts for its corporate offices and owned and managed properties. These third parties include:
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human resources services, performance management and talent management
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back office IT systems suppliers and providers
We will also share information with legal and regulatory authorities and our accountants, auditors, lawyers and other outside professional advisors.
We also share information with third parties:
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if, in good faith, we believe that the disclosure is required to comply with a judicial proceeding, court order, subpoena, warrant or legal process, and such disclosure is in compliance with local law;
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in the event of a merger or acquisition, asset sale, a transfer of some or all of Hilton’s business, or other related transaction; and
International Data Transfers
We reserve the right to transfer your personal information to, or process your personal information in, countries that have not been found to provide adequate protection of data pursuant to a country-specific law. In particular, we collect and store the personal information you provide via the Careers Site in the United States.
We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented data transfer agreements, such as the European Commission controller-to- controller standard contractual clauses or other similar safeguards, for such purposes. To obtain a copy of theses clauses or additional information on transfers, you may send your request to privacy@hilton.com.
Complaints
You have the right to lodge a complaint regarding the processing of your personal information with us at privacy@hilton.com or with the supervisory authority in the Member State of your residence or place of work if you believe that the processing of your personal information infringes applicable local laws.
Privacy Notice Changes
This Notice may be changed from time to time. You can determine when this Notice was last revised by referring to the “Last Updated” legend at the top of this Notice. Any changes to this Notice will become effective upon our posting of the revised Notice on the Careers Site.
