APPLICANT PRIVACY NOTICE

FOUR SEASONS HOTELS AND RESORTS
APPLICANT PRIVACY NOTICE

Our Commitment to Privacy
 

Four Seasons Hotels and Resorts (“Four Seasons”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. We are committed to using and securing your Personal Information (defined below) in a reasonable manner as set out in this Applicant Privacy Notice (“Notice”).[1]

This Notice has been designed to comply with various laws in the jurisdictions in which we operate that govern how entities may collect and use Personal Information (“Privacy Laws”).  

This Notice applies to how Four Seasons processes the Personal Information of individuals applying for positions with Four Seasons (“Applicant(s)”) and explains the ways in which we collect, use, store, protect and disclose Applicants’ Personal Information. If Applicable Laws (defined below) conflict with this Notice, Applicants must comply with the Applicable Laws.

This Notice may be amended or updated from time to time. The effective date is indicated at the bottom of the Notice. 

 

1.   What Is Personal Information?

“Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Information is considered to relate to an identifiable individual where that information can be used, either by itself or together with other information, directly or indirectly, to identify an individual. Personal Information includes, among other things, an Applicant’s name, email address, phone number, identification number such as passport number, social insurance number or social security number, as well as online identifiers such as IP address or device ID. 

 

2.   What Personal Information Do We Collect?

We may collect, store, and use (collectively, “process”), the following types of Personal Information about you to the extent permitted under Privacy Laws, which may vary by jurisdiction:

  • Contact Information: including name, maiden name and surname, title, home address, telephone numbers, and personal email address(es);
  • Identity Information: including date and place of birth, citizenship, country of residence, government-issued documentation (for example, national identification number, driving license information), gender, civil status, and a photograph of you;
  • Recruitment Information: including copies of your authorization to work documentation; background checks, references and other information included in your CV, cover letter or correspondence with us as part of the application and recruitment process (for example, information about your qualifications, experience, knowledge, skills, and abilities);
  • Terms and Conditions of Employment: including details relating to or contained in offer letters and contracts of employment (for example, job title, start date, location of employment or workplace, type of contract, salary and remuneration, schedule, annual leave, and pension);
  • Financial Information: including your credit history as part of a credit check, which may include certain bank account information, credit limits, and student loan and other loan information;
  • Voice or Image Recordings: including recordings from Closed Circuit Television (CCTV) footage at Four Seasons’ corporate offices (“Offices”) and Properties, and, where permissible under Privacy Laws, recordings of interviews conducted in person or remotely.

We also process Sensitive Personal Information in jurisdictions where we are permitted or required to do so by Privacy Laws and other Applicable Laws, and only for specific purposes such as conducting background checks, gathering equal opportunity employment data, representation data to report on our Diversity, Inclusion and Belonging initiatives, or collecting and providing legally required information to a local government authority. Such Sensitive Personal Information might include biometric information, social security, driver's license, state identification card, or passport number; racial or ethnic origin; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; religious or philosophical beliefs; union membership; your physical and mental health (e.g., your medical history, treatments, current state of illness, drug test results, and doctor’s standpoint on any limitations or requested accommodations related to your potential role), criminal convictions and offenses, disabilities; or genetic data.

 

3.   How Is Your Personal Information Collected?

Subject to Privacy Laws, Personal Information is collected by us through the application and recruitment process when you provide it to us or when you authorize us to collect it from others (such as with respect to background and credit checks).

CCTV systems monitor many of the exteriors and interiors of our Offices and Properties 24 hours a day for security reasons. This data may be recorded. Use of CCTV and recording of CCTV data is only carried out if and to the extent permitted by Privacy Laws or as required by Applicable Laws.

 

4.   For What Purposes Do We Process Your Personal Information?

Four Seasons processes your Personal Information only for purposes that are permitted by Privacy Laws. Those purposes align with one or more of the following legal bases, under which we are permitted to process your Personal Information: (1) to pursue our legitimate business interests in identifying candidates to join the Four Seasons workforce at our Offices and Properties around the world, as well as managing the application, recruitment, and job offer process; and (2) to comply with our legal and regulatory obligations in the countries in which Four Seasons operates. 

To the extent permitted under Privacy Laws and other Applicable Laws, we will process your Personal Information for the following purposes:

Furthering Legitimate Business Interests: We process your Personal Information for the following purposes in furtherance of our legitimate interests:

  • reviewing and assessing job candidates’ qualifications for employment;
  • communicating with applicants and references;
  • managing the in-person and remote interview process, including allowing Applicants to book interview appointments electronically; and
  • for successful Applicants, managing the Four Seasons onboarding process.

Complying with Legal Obligations: We process your Personal information to comply with legal and regulatory obligations, including for purposes of:

  • ensuring that you are legally entitled to work in the jurisdiction in which you would be employed and satisfy legal requirements related to your job function; for example, if you will be employed as a driver, we will confirm that you have all necessary licenses and permits to operate the vehicle(s) you will be employed to operate;
  • monitoring and reporting on equal employment opportunities; and
  • complying with laws, procedures, and regulations applicable in the countries where we operate, including those related to disclosing Personal Information to governmental authorities (“Applicable Laws”).

 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. There will always be human intervention into decisions based on automated processing, including automated analytics, testing, and profiling.

We process Personal Information in accordance with Privacy Laws. We do not process Personal Information for any purpose or in any way other than as described in this Notice unless we either (1) separately inform you of the new purpose, or (2) we have obtained your consent, directly or indirectly, prior to using or disclosing your Personal Information. To the extent permitted and/or required by Privacy or other Applicable Laws, we may provide your Personal Information to law enforcement agencies, regulatory bodies, or other government agencies without your knowledge or consent.

 

5.   With Whom Do We Share Your Personal Information?

Due to the global nature of our operations, we need the ability to move your Personal Information across our organization. As such, we may share certain of your Personal Information with Four Seasons employees and entities, such as your potential manager, employees with whom you may work, individuals who will interview you for a position at Four Seasons, as well as Four Seasons’ Offices.

 

To carry out the purposes outlined above, we will share your Personal Information with third parties where it is necessary to administer the application process, where required by law, or where we have another legitimate interest in doing so. We may share certain of your Personal Information with the following categories of third parties:

  • information technology service providers (e.g., computer backup, archival storage, IT systems suppliers);
  • consultants and other professional service providers (e.g., accountants, auditors, human resource management, recruitment services, external legal counsel, and advisory services);
  • other third-party service providers (e.g., re-location services, background check vendors, international emergency services, and business travel agents);
  • legal and regulatory authorities; and
  • state or federal government agencies.

Four Seasons may be involved in (a) the purchase, sale, or other acquisition or disposition of all or part of our business or any of our assets, or a Property owned by a third-party; (b) our merger or amalgamation with another organization; (c) the making of a loan or provision of other financing; (d) the creating of a charge on, or the taking of a security interest in or a security on, any assets or securities; or (e) the lease or licensing of any of Four Seasons’ assets (each a “Business Transaction”). In the context of a Business Transaction, we may disclose Personal Information and in doing so we will comply with the requirements of Privacy Laws.

Four Seasons manages Properties on behalf of third-party property owners. Four Seasons may disclose to such a property owner certain Applicant information as needed to manage the potential contractual relationship between the Applicant and relevant third-party property owner, where applicable. All other Personal Information is proprietary to Four Seasons and is not shared with property owners.

 

See the “Protecting Your Personal Information” section for information on how we keep your Personal Information secure when sharing it with others.

6.   Transfers of Your Personal Information Outside of Your Home Country

Your Personal Information may be processed by Four Seasons and those other parties described in the “With Whom do We Share Your Personal Information” section, anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country. We will implement appropriate measures to ensure that your Personal Information remains protected and secure when it is transferred outside of your home country, in accordance with Privacy Laws.

 

7.   Protecting Your Personal Information

We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, collection, disclosure, copying, use, disposal, or modification, regardless of the format in which the information is held. Security safeguards in place include physical, organizational, and technological measures to protect Personal Information that is in our custody or control. For instance, we use electronic firewalls and secure means of disposing of Personal Information.

We also implement access controls to limit how much of your Personal Information is available to employees, agents, contractors, and other third parties based on their business need to know your Personal Information. We only permit service providers to process your Personal Information for specified purposes and/or in accordance with our instructions. All third-party service providers are contractually obligated to implement appropriate technical and organizational security measures to protect your Personal Information and are otherwise required to adopt appropriate safeguards in relation to the handling of your Personal Information (including in relation to maintaining the confidentiality of your Personal Information).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8.   For How Long Will We Keep Your Personal Information?

 

We will keep your Personal Information, as updated from time to time consistent with this Notice, for the period of time required or permitted by Privacy or other Applicable Laws in the country in which it is stored. We will delete your Personal Information once it is no longer reasonably necessary for the purposes for which it was collected. 

 

9.   Your Rights

You may be entitled to:

  • ask us about the processing of your Personal Information, including requesting (i) categories of Personal Information collected, (ii) sources of Personal Information, (iii) third parties to whom the business disclosed the Personal Information, and (iv) what Personal Information was shared and to whom;
  • request the correction and/or deletion of your Personal Information;
  • request the restriction of the processing of your Personal Information, or object to that processing;
  • request receipt or transmission of your Personal Information to another organization, in a machine-readable format; and
  • in certain countries, file a complaint with your local supervisory authority if you believe your privacy rights have been violated, or if you have suffered because of unlawful processing of your Personal Information.

Exercising your rights is free of charge. However, we have the right at our sole discretion to refuse to fulfill your request or charge a reasonable fee for fulfilling several similar consecutive requests, or requests that are manifestly unfounded or excessive. We are also entitled to decline requests on statutory grounds; in such cases we will inform you of such declination and explain our grounds for doing so.

Please note that your rights may vary depending on the jurisdiction in which your Personal Information is processed. If you would like more information about your rights or have any concerns about our processing of your Personal Information, please contact the Four Seasons Chief Privacy Officer (see contact details below).

 

10.        Questions, Complaints, and Further Information

 

If you are applying for a position at a Four Seasons Property, your primary point of contact related to this Notice is your People & Culture contact for the Property. In addition, Four Seasons has designated a Chief Privacy Officer who can answer any questions you have about this Notice and address any concerns you may have related to your Personal Information. Our Chief Privacy Officer can be reached at:

 

Chief Privacy Officer
Four Seasons Hotels and Resorts
1165 Leslie Street
Toronto, Ontario M3C 2K8
Canada
E-mail: privacy.officer@fourseasons.com

 

Date:    January 2023

 

[1] This Notice has been adopted by Four Seasons Hotels Limited and its direct and indirect subsidiaries and affiliates that manage and operate Four Seasons branded hotels, resorts, residential properties, and the Four Seasons Private Jet and Yacht (each a “Property”, and collectively “Properties”). References to “we”, “us”, “our” and “Four Seasons” throughout this Privacy Notice, depending on the context, refer either collectively to those separate and distinct legal entities or to an individual entity.

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