Privacy Statement for Job Applicants

1. Introduction

Your personal data is in safe hands with us. As a potential job candidate, you must be secure in the knowledge that we do everything we can to protect your data. We comply with all the applicable laws and regulations, which may include but is not limited to the California Consumer Privacy Act (“CCPA”), the Personal Information and Electronic Documents Act (“PEPIDA”), Rabobank Privacy Code, and Federal Law on the Protection of Personal Data (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) and its Regulations (Reglamento de la Ley Federal de Protección de Datos Personales en Posesión de los Particulares). This Privacy Statement for the Recruitment and Selection process (referred to below as the ‘R&S process’) explains how your data is processed.

If this Statement contradicts with any national, local, or state legislation or regulations in the USA, Mexico, or Canada, the legislation or regulations will supersede this Statement.

Rabo AgriFinance LLC, Coöperatieve Rabobank U.A., New York Branch, the U.S. and Mexico representative offices of Coöperatieve Rabobank U.A., Rabobank Canada,  Rabo Diversified Services LLC, Rabo Securities USA, Inc., Rabo Securities Canada, Inc., St. Louis Agency Office, or any other affiliated entities operating in North America, (hereinafter collectively and individually referred to as ”Rabobank”), is bound by the applicable rules regarding personal data processing.

1.2 What do we mean exactly by ‘personal data’ and the processing of this data?

Personal data refers to data which relates to you personally, either directly or indirectly. This might include:

– Your name and address, date of birth, sex, telephone number and email address

– Your resumé and cover letter

– Links to your public profiles on websites such as LinkedIn

– A photograph and/or audiovisual job application video

– Gender, race, ethnicity, and veteran status if you choose to provide it

Generally, we may collect the below categories of personal information from applicants for employment at Rabobank.

Processing refers to any activity involving personal data. When you apply for a job with us, we collect, use and retain your personal data. We do this, among other things, to verify that you hold the qualifications required for the position.

The following are the service providers we use to process your data and the categories of your personal data disclosed to those providers (as referenced immediately above):

• Human Resources Information Systems
  • Receive personal data in Categories A, B, C, F & G

• Legal & Regulatory Tracking/Verification Providers
  • Receive personal data in Categories A, B, C, F & G

1.3 Whose personal data do we process, and how do we process it, during the job application process?

This Privacy Statement applies to all processing of the personal data of candidates and potential candidates as part of the R&S process at Rabobank. The data is processed in the HR system in The Netherlands, Europe by or on behalf of Rabobank. If you are hired by Rabobank, you will be subject to the Privacy Statement for Employees.

1.4 Who is responsible for processing my personal data?

Rabobank is responsible for processing all personal data processed.

Our contact details are:

Rabobank

c/o Human Resources

14767 North Outer 40 Road

Suite 400

Chesterfield, MO 63017

USA

RaboPrivacyOffice@rabobank.com

1.5 How do we obtain your personal data?

We have two ways of acquiring your personal data:

• You provide this yourself or through a third party/third parties (either through referees or an external recruitment agency).
• We also collect data (including contact details) ourselves through resources such as a resumé databases. We do this if we think you might be interested in working for Rabobank. If the recruiter contacts you, they will tell you where they found your details, upon your request. In addition, they will ask you for permission to use these details to contact you regarding a job opening or event. You can change or revoke your consent at any time.

2. Principles and purposes of processing personal data relating to a job application

We process your data:

• based on your express consent – which can be revoked at any time;
• if we have a statutory obligation to do so;
• in order to enter into an employment contract with you and subsequently perform this contract;
• based on a legitimate interest on our part.

2.1 For what purposes do we process personal data?
We process personal data for the following purposes:

a. Human resources

We require your personal data in order to be able to properly conduct our R&S process. This includes assessing whether you are suitable for the position and whether we would like to invite you for an interview. Another reason might be to produce an access card, which you require in order to enter the building. Rabobank is committed to diversity in its workforce that is welcoming for all and makes us a stronger organization.

b. Health, safety, security and ethics (including pre-employment screening)

Like all other financial institutions in North America, Rabobank subjects future employees to a background check. We are required by law to do so. Our screening procedures apply to all applicants who are potential   employees. We attempt to ascertain as accurately as possible whether you, as an applicant to the bank, are sufficiently trustworthy. A positive outcome of the background check is a condition for getting hired. All applicants to be screened are subject to the same procedure, which consists of the following two stages:

• Stage 1: the original version of your highest qualification will be verified during the job interview.
• Stage 2: if we intend to enter into an employment relationship with you, we will ask you to complete a statement; this statement advises you that we will be gathering information on you.

This includes the opinions of employers or clients you have had over the past two years regarding your trustworthiness. We may also use data for this purpose which we obtain from third parties, including former employers (through references we received from you) and recruitment agencies. We may also consult public sources during the job application process, including publicly accessible and professional social media (if this is relevant to the position and is specified in the job advert).

We also record personal data in order to protect the interests of our employees, visitors, the bank, and the financial sector. We do this, among other things, through an internal camera security system.

c. Business reports and analysis and organizational development

We may process your data to create business reports, surveys and analyses. We may also merge the various data we possess on you, for example to improve the R&S reports (e.g. the number of job openings, number of applicants and the time it takes to fill these vacancies). The results of the analyses and the resulting recommendations can never be traced back to you.

d. Statutory requirements

We collect data relating to you based on specific domestic and international laws and regulations. Certain positions may require background checks to determine if you are qualified for the position and meet all regulatory requirements.

e. Further processing must be compatible

We will not collect, use, retain, and/or share your personal information for any purpose that is unrelated or incompatible with the purpose(s) for which the personal information was originally collected or processed.  We will request explicit consent and provide a new notice if we intend to collect, use, retain, and/or share your personal information for any purpose that is unrelated or incompatible with the purpose(s) for which the personal information was originally collected or processed.

3. Do we also process special categories of personal data?

By ‘special categories of personal data’, we mean various types of sensitive data. This data may relate to a person’s health, veteran status, and data regarding gender, race, ethnic background, or citizenship. If you ask us to record special categories of personal data relating to you or are disclosing this data yourself, we will only process this data if there is a clear purpose, there are grounds to do so, and this is necessary for the purpose. Sensitive categories of personal data may also be processed, for example photographs or video recordings of you. This includes any pictures you might have enclosed with your resumé , as well as camera footage recorded of you on entering the building.  Any data regarding a person’s health, medical conditions, or disability status will be kept in separate files from other data pursuant to the Americans with Disabilities Act or similar statutes and regulations.  We process this camera footage solely for the protection of the property of Rabobank and our employees, and for other security reasons.

Race or ethnic background: This may apply, for example, to images of you. Rabobank processes this data for security reasons.

• Photos and video images may qualify as racial or ethnic data. In the United States, photos are used for security reasons, e.g., issuance of building and floor badges for site access and recording of activity at workplace entrances to secure the premises;
• Demographic reporting under applicable anti-discrimination laws;
• Communication facilities;

Personal data pertaining to criminal convictions:

This refers to data concerning any criminal activity or previous record for criminal or unlawful activities. This data is necessary to protect the interests of Rabobank, its employees and its customers, including safeguarding the security and integrity of the financial sector. This data is used for screening employees prior to and during employment and alert systems for the financial sector.

At Rabobank you can voluntarily provide certain characteristics about yourself which help us in analyzing our workforce and trying to design interventions to ensure discrimination has no role within the organization. The characteristics contain, among others, sexual orientation, race, disability status, and veteran status.

4. Does Rabobank also process my social security number (SSN)?

Rabobank does not collect your SSN as a result of your application for employment with us. Your SSN will be collected and processed should you be hired for employment.

5. How do we handle your personal data?

Your personal data is used exclusively by employees who require access to this data on account of their position. The employees who are involved in your application process are bound by confidentiality. We only reuse data if the original data is related to the new purpose.

6. How do we deal with third parties?

Sometimes we engage the services of third parties, which process personal data on our behalf. This includes external recruitment agencies, background check agencies, and research companies. We can only engage third parties if this suits the purpose for which we processed your personal data and this is sufficiently reliable. Furthermore, we will only hire the services of such a third party or parties if they have implemented the appropriate security measures and guarantee confidentiality. If your application process includes an assessment, we will notify you in advance and will only save the report to your job application file once you have approved the accompanying report.

7. How long do you keep my details?

If you created an online profile with us, you will be able to use it again for other job applications at Rabobank in the future. If your job application was unsuccessful, we will delete your personal data after the expiration of the timeframe(s) by which we are legally required to retain the data. This includes all application details, e.g. your job application letter, and resumé. You can log into your account on www.rabobank.jobs within that period and choose to delete your data. Our record retention policy applies to all personal data that we have of you, whether you are a job applicant or an employee.

8. What rights do you have in relation to your personal data?

8.1 Right of access

You can access your profile on www.rabobank.jobs at any time and view the data you have provided us. Or you may ask us to view the data we have stored in relation to you (e.g. public online details and camera footage you won’t be able to access via the profile on www.rabobank.jobs).

8.2 Right of rectification

If your data is incorrect, incomplete or in violation of the law, you can change your data at any time on www.rabobank.jobs. Or you can request us to have it rectified if you don’t have access to it through your profile on www.rabobank.jobs.

8.3 Right to be forgotten

You can delete the data recorded in relation to you if you object to this data being processed. This might be the case, for example, if the processing is no longer necessary for the purposes for which it was collected. You can do so on www.rabobank.jobs. You may also request to have data deleted if you don’t have access to it through your profile on www.rabobank.jobs.

8.4 Right not to be subject to automated decision-making

Automated decision-making’ refers to decisions made by computers rather than people. Rabobank is permitted under the law to make automated decisions, including profiling. Even though we are permitted to use automated decision-making, we currently do not use it in the job application process.

8.5 Right to object to processing

You have the option to object to the processing of your personal data. In this case, we ask you to delete your profile on www.rabobank.jobs.

All requests can be directed to the HR department handling these. You can contact them via fm.am.WorkdaySupport@rabobank.com, or phone via (855) 886 9005 or +1-314-317-8175 for areas outside the USA.

8.6 Procedure

If you submitted one of the requests described above, we will acknowledge your request within 10 business days and provide a final response to your request within 30 calendar days of receipt. Depending on the number of requests received and the complexity of the request(s), the period may be extended by another 30 days. We will keep you updated on the progress of your request. If the data you provided also contains third-party data, such third party may be requested in advance whether they object to their data being processed. You may be asked to further specify your request. We may also ask you to provide ID because we want to make certain that we are providing data to the right person. In some cases we may not be able to honor your request. For example, we will not delete the data if it is of significant importance to our processes or if there is a statutory obligation to retain it. We will notify you if this is the case.

9. Where can I address my question or complaint?

For complaints about the processing of personal data, you can approach the Rabobank division that processes your personal data. If the response is unsatisfactory, you may submit this to us at fm.am.WorkdaySupport@rabobank.com.

10. Can we amend our Privacy Statement?

The Privacy Statement may be modified from time to time. If there is new data to be processed, we will amend the Privacy Statement accordingly. You will be able to find the most up-to-date version of our Job Applicants Privacy Statement on our website. This is version 2.1, updated in December 2023.