Applicant Data Disclosure & Privacy Notice (GDPR + CPRA)
This Applicant Data Disclosure & Privacy Notice (“Notice”) explains how IMPACT Group (“Company,” “we,” “our,” or “us”) collects, uses, shares, retains, and protects personal data in connection with our recruiting and hiring process, including when you apply for a job through our applicant tracking system (“ATS”).
This Notice applies to applicants, candidates, and individuals interacting with our recruitment process (“Applicants”).
1) Who We Are (Controller / Business)
Company Name: IMPACT Group
Address: 12977 North Outer 40 Drive, Suite 300, St. Louis, MO 63141 United States
Email: hresources@impactgrouphr.com
Phone: + 1 800-420-2420
GDPR Data Controller
For individuals located in the European Economic Area (EEA), United Kingdom, or Switzerland, IMPACT Group is the data controller of your personal data.
California CPRA Business
For California residents, IMPACT Group is a “business” as defined under the California Privacy Rights Act (“CPRA”).
2) Categories of Personal Data We Collect
We may collect the following categories of personal data from you, depending on the role and recruitment stage:
A. Identifiers & Contact Information
• Name, email address, phone number
• Mailing address (if provided)
• Online identifiers (e.g., IP address, device identifiers)
B. Professional & Employment-Related Information
• Resume/CV, cover letter, work history, education
• Certifications, languages, skills, portfolio, writing samples
• References and referral information (if provided)
C. Recruiting Process Information
• Interview notes, assessment results, communications
• Application status, scheduling history, outcomes
D. Sensitive Personal Information (Only When Permitted/Required)
We may collect limited sensitive personal data only where permitted by law and/or relevant to the hiring process, such as:
• Disability or accommodation needs
• Work authorization/immigration status (as required)
• Diversity/equal opportunity data (optional, where applicable)
• Background check results (only after applicable notice/authorization)
E. Technical & Usage Data (ATS and Website)
• Log data, browser type, operating system
• Interaction data within our career site/ATS
3) Sources of Personal Data
We collect personal data from:
• You directly (applications, communications, interviews)
• Recruiting sources you authorize (e.g., LinkedIn or job boards)
• Referees you provide (where permitted)
• Service providers supporting recruiting (e.g., ATS, assessments)
• Background check providers (only where applicable and authorized)
4) Purposes for Using Personal Data
We use your personal data to:
1. Process your application and evaluate your qualifications
2. Communicate with you about roles, interviews, and outcomes
3. Conduct interviews and assessments (where applicable)
4. Verify information provided (e.g., references, work eligibility)
5. Perform background checks (only when permitted/authorized)
6. Comply with legal obligations, including employment and recordkeeping laws
7. Improve our recruiting process, including system administration, analytics, and security
8. Maintain talent pools (with your consent where required)
5) Legal Bases for Processing (GDPR)
If you are located in the EEA/UK/Switzerland, we process your personal data under one or more of these legal bases:
• Legitimate Interests: to manage recruitment, assess candidates, and secure our systems
• Contract / Pre-contractual Steps: to take steps at your request prior to entering an employment contract
• Legal Obligation: to comply with employment, tax, immigration, and equal opportunity laws
• Consent: for certain optional activities (e.g., keeping you in a talent pool, diversity data where required)
6) CPRA Notice at Collection (California Applicants)
If you are a California resident, the CPRA requires that we disclose the categories of personal information collected and the purposes for which it is used.
We collect the categories listed in Section 2 above for the business purposes described in Section 4, including:7) How We Disclose/Share Personal Data
We may disclose personal data to:
A. Internal Stakeholders
• HR, recruiting staff, hiring managers, and interviewers
• Internal legal, IT, finance, and security staff (as needed)
8) Automated Decision-Making
We do not make hiring decisions based solely on automated decision-making that produces legal or similarly significant effects.
If we use automated tools to assist with recruiting (for example, to help sort applications), they are used with human review and appropriate safeguards.9) Data Retention
We retain applicant data only as long as reasonably necessary for recruiting and legal compliance.
Typical retention periods:10) International Transfers (GDPR)
Because we are U.S.-based, your information may be transferred to and processed in the United States or other countries where we or our service providers operate.
Where required under GDPR, we use appropriate safeguards such as:11) Your Rights
A. GDPR Rights (EEA/UK/Switzerland)
You may have the right to:
• Access your personal data
• Correct inaccurate or incomplete personal data
• Request deletion (“right to be forgotten”)
• Restrict processing
• Object to processing (including based on legitimate interests)
• Data portability (where applicable)
• Lodge a complaint with your local supervisory authority
12) How to Submit a Privacy Request
To exercise privacy rights, please contact:
Email: hresources@impactgrouphr.com
Subject Line: “Applicant Privacy Request”
Mail: 12977 North Outer 40 Drive, Suite 300, St. Louis, MO 63141 United States
13) Security Measures
We use reasonable administrative, technical, and organizational safeguards designed to protect applicant data, such as access controls, encryption (where appropriate), and vendor security requirements.
No system can be guaranteed 100% secure, but we work to protect your personal data against unauthorized access, loss, misuse, or alteration.14) Equal Opportunity and Optional Demographic Data
Where permitted or required, we may request optional demographic information (e.g., gender, race/ethnicity, disability status) to support equal employment opportunity reporting and diversity initiatives.
Providing this information is voluntary (where applicable) and will not affect hiring decisions.15) Children’s Privacy
Our recruiting process is not intended for children under 16, and we do not knowingly collect personal data from children through our ATS.
16) Changes to This Notice
We may update this Notice periodically. If we make material changes, we will post the updated Notice with a revised effective date.
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