AUDACY – PRIVACY NOTICE TO CALIFORNIA JOB APPLICANTS
Last updated: December 22, 2022
Thank you for your interest in joining Audacy, Inc. and/or any of its affiliates or subsidiaries (collectively referred to as “Audacy”, “the Company”, “we”, “our” or “us”). Trust is a cornerstone of our mission at Audacy. We are committed to protecting the privacy and security of personal information of all individuals, including job applicants.
This Privacy Notice (“Notice”) is directed to California residents who apply for employment with Audacy. The Notice provides the categories of personal information that we collect about job applicants, the purposes for which we use and share it, as well as your privacy rights pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), which are effective January 1, 2023.
This notice is only intended to cover information specific to California job applicants and the notice requirements of the CPRA. To review our privacy practices with respect to our customers, listeners, and the general public that use our products and service, please review our online Privacy Policy available at www.audacyinc.com/privacy-policy.
Table of Contents
- Collection and Use of Candidate Personal Information
- California Privacy Rights – How to Request to Access, Correct, and/or Delete Your Information
- Data Security & Retention
- How to Contact Us with Questions About this Privacy Notice
- Collection and Use of Candidate Personal Information
The Company collects, uses, and discloses personal information about job candidates for business purposes only and consistent with applicable laws. The Company does not sell or otherwise disclose this personal information for monetary consideration to any third parties. Further, the Company does not use or share your personal information for purposes of cross-contextual behavioral advertising.
We work with third-party vendors who assist in our recruiting, hiring, and onboarding processes, such as iCIMS (which hosts our job recruiting platform). Whenever we share your personal information with our trusted vendors, or ask that they collect your personal information on our behalf (such as your resume and contact information), the vendor is required to keep your information confidential and secure.
The chart below summarizes our information practices as it relates to job applicants as of the date of this Notice. It also includes how we have collected and used the personal information of job applicants over the past 12 months, and the purposes for doing so when you inquire about and/or apply for employment at the Company. The chart summarizes our information practices generally, although not every category will be applicable to every job applicant:
Category of Personal Information | Category of the Sources of Your Information | How We Use It – The Purpose for Collecting Your Information |
Contact information: such as your name, home and work address, personal and work telephone numbers, personal and work email addresses. | We receive this information from you – either directly or indirectly through a recruiter, information you have posted in an online job board or in an online public profile, such as LinkedIn. | We will use this information to open and maintain candidate records and communicate with you regarding your interest in a job opportunity with us, your application for employment, or updates on your candidacy. |
Job-related information and qualifications: such as position applied for, previous job roles, education, awards, qualifications, certificates, licenses, desired compensation information, and any other information you choose to provide in your resumes, cover letters, applications and interviews, including how you heard about the position for which you are applying. | We receive this information from you – either directly or indirectly through a recruiter, information you have posted in an online job board or in an online public profile, such as LinkedIn; from your professional references | We will use this information to assess your suitability for a position at the Company and conflict of interest reporting. |
National identification information: such as your country of birth or the country where you are a registered national or citizen, social security number and/or other identification information, and any visa or other right to work. | We receive this information from you | We will use this information to assess your suitability for a position at the Company and conflict of interest reporting. |
Results of background checks and screening: such as education verification, criminal records and driver history and /or license checks. | We receive this information from references, publicly available resources, and vendor platforms that collect and process this information for employment purposes | We may use this to determine your suitability for certain job roles (to the extent permitted or required by law). |
Health and disability records: such as information relating to any disability or health status or condition (including COVID vaccination status) that is relevant to your role that you disclose to us during the application | We receive this information from you | We will use this information to address our legal obligations to you, make any adjustments required to assist you in the application process or performance of the role for which you are applying and determine whether you are fit to undertake tasks required by the job for which you are applying. |
Equal opportunities monitoring information: such as your race, color, religion or creed, national origin or ancestry, sex (including gender, pregnancy, sexual orientation, and gender identity), age, physical or mental disability, veteran status. | We receive this information from you | We will use this to conduct equal opportunity and diversity monitoring where permitted or required by law. |
In-Person Visitor Information: such visitor security badge logs, security camera footage, and meeting information. | From you, security camera footage, and visitor security badge screening technologies; if you are visiting an office that we lease, this information may be provided by the owner of the property. | This information may be collected at our facilities as part of our day-to-day visitor security practices. Additional health information may be collected when and if necessary for in-person meetings to prevent the spread of COVID-19. |
References: such as opinions and comments of any previous employers. | From your professional references | We will use this to determine your suitability for certain job roles and to fulfill our obligations to regulators (including demonstrating the suitability of employees for their role to regulators and professional bodies). |
In addition to the uses set forth above, the Company may use and share personal information:
- To comply with applicable legal and regulatory requests and obligations, such as responding to subpoenas, court orders, legal process, and other law enforcement measures;
- To establish or defend legal claims and allegations;
- For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct; and
- To seek advice from lawyers, auditors and other professional advisers.
For example, Audacy owns, and certain of Audacy’s subsidiaries operate, broadcast radio stations in the United States licensed by the Federal Communications Commission (the “FCC”). As a result, Audacy is subject to certain FCC regulations. Audacy may need to provide certain information related to your job application to the FCC if, and only to the extent required and/or requested by, the FCC.
- California Privacy Rights – How to Access, Correct, and Delete Your Information.
A. Your California Privacy Rights
If you are a California resident, the CPRA provides you with the following rights with respect to your personal information. Additional information is available on the California Privacy Protection Agency website available at: https://cppa.ca.gov/. As a California resident, your rights include:
- The Right to Know and Access. You have the right to request to know and access the categories and specific pieces of personal information we have collected about you, dating back to January 1, 2022. You also have the right to know the sources from which the personal information is collected and the business or commercial purpose for collecting it. In most instances, information we have collected will be that which you provided by creating an account and logging into on our our official recruitment website, hosted on the iCIMS platform or during a job interview. You can log in and view your profile and contact information, your application materials (such as your resume, cover letter, references, etc.) and the positions to which you have applied.
- The Right to Correct. You have the right to request that we amend or update your personal information where it is inacurate or incomplete. You can log in to your account on our official recruitment website to update your information. If you have communicated with a member of our Talent Aquisition Team, you are also welcome to reach out to this individual directly to update your information.
- The Right to Delete. You have the right to request that we delete any personal information we have collected about you. We will delete your personal information if we have no other no other legal ground or purpose to retain it. We may need to retain some information about you in order to satisfy our legal and security obligations and so it may not always be possible to completely remove or modify information in our databases, although we will make reasonable efforts to do so, upon your request.
- The Right to Opt-Out of Sale and Sharing of Your Personal Information. Audacy does not sell your personal information. Moreover, Audacy does not share your personal information for cross-contextual behavioral advertising purposes.
- The Right not to Receive Discriminatory Treatment. Businesses cannot discriminate or retaliate against you for exercising your CPRA rights. If you choose to exercise your rights, it will not impact our decision whether or not to offer you a position.
B. How to Exercise Your Rights
In addition to the various options descibed above, you may submit a request to exercise any or all of the above rights by:
- Visiting our online privacy portal at: audacyprivacy.com and submitting a web form;
- Calling our dedicated privacy help line at 1-855-665-0026; or
- Mailing a written request to:
Audacy, Inc.
Attn: Legal Department – Job Candidate Privacy Request
2400 Market Street, 4th Floor
Philadelphia, PA 19103
You may also designate an authorized agent to make a request on your behalf.
When you exercise these rights and submit a request to us, we will attempt to verify your identity through an email verification process and by providing us with specific information for the limited purpose of verifying your identity to prevent unauthorized disclosure of your information. We may also use a third-party verification provider to assist in the verification process.
The fact that you have elected to exercise these rights will have no adverse effect on your employment or job application with Audacy.
- Data Security and Retention
A. Data Security
We care about the safety and security of your information, and are committed to protecting it. We have adopted technical, administrative, and physical security measures to help protect your information from loss, interference, misuse, unauthorized access, alteration, and disclosure. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please be aware that third-party recruiting sites are vulnerable to scam job postings. Solicitations from these sites or people falsely representing Audacy may result in an attempt to obtain your personal information. All Audacy positions are listed on our official recruitment website.
Please note that no data transmission or storage can be guaranteed to be 100% secure. We urge you to take every precaution to protect your personal information while you are on the Internet. Please refer to the websites of the U.S. Federal Trade Commission for information regarding online privacy and security and how to protect yourself from identity theft.
B. Data Retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which we have collected it and to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
Audacy, Inc.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
As noted above, Audacy is subject to certain FCC regulations. In order to comply with the FCC Equal Employment Opportunity (EEO) regulations, we must maintain certain recruiting records for a period of time, including information about job candidates and the positions to which they applied. Audacy must maintain these records for at least three years, and often-times longer depending on the radio station FCC license renewal date and any FCC audit request relevant to our hiring practices.
4. Data Security and Retention
If you have questions regarding this Notice or our Privacy Policy please contact us at:
Audacy, Inc.
2400 Market St., 4th Floor
Philadelphia, PA 19103
Attn: Legal Department – Privacy Officer
Or by email at: audacyHRCCPA@audacy.com
Or by calling us toll-free at: 1-855-665-0026. Please note that this toll-free number is a dedicated specific to privacy-related questions and not hiring or employment-related inquiries.
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AUDACY, INC.
PRIVACY NOTICE TO EUROPEAN JOB APPLICANTS
Last updated: June 22, 2022
Thank you for your interest in joining Audacy, Inc. and/or any of its affiliates or subsidiaries (“Audacy” or “the Company” or “we” or “us”). Trust is a cornerstone of our mission at Audacy. We are committed to protecting the privacy and security of personal information of all individuals, including job applicants. The purpose of this Privacy Notice (“Notice”) is to make you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and for how long it will usually be retained.
The Company is a "controller" in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this Notice because you are applying for work with us (whether as an employee, worker or contractor) or you are inquiring about a position. This Notice is intended to comply with all applicable laws and so provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation's (EU GDPR) (together, the “GDPR”).
We will only process your personal data in accordance with this Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
- Data protection principles
We intend to comply with all applicable data protection law and principles, which means that your personal data will be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely.
- Collection and Use of Candidate Personal Information
In connection with your application or inquiries to work with us, in the table below, we provide details of the categories of personal information that we collect, store and use about you when you inquire about and/or apply for employment at the Company. The Company collects, uses, and discloses personal information about job candidates for business purposes only as outlined in detail in the table below and are consistent with applicable laws. The Company does not sell or otherwise disclose this personal information for monetary consideration to any third parties. :
Category of Personal Information | How We Use It |
Contact information: such as your name, home and work address, personal and work telephone numbers, personal and work email addresses. | We will use this information to open and maintain candidate records and communicate with you regarding your interest in a job opportunity with us, your application for employment, or updates on your candidacy. |
Job-related information and qualifications: such as position applied for, previous job roles, education, awards, qualifications, certificates, licenses, desired compensation information, and any other information you choose to provide in your resumes, cover letters, applications and interviews, including how you heard about the position for which you are applying. | We will use this information to assess your suitability for a position at the Company and conflict of interest reporting. |
National identification information: such as your country of birth or the country where you are a registered national or citizen, social security number and/or other identification information, and any visa or other right to work. | We will use this information to determine your eligibility to work and fulfill our obligations to relevant government authorities. |
Travel-related records: frequent flyer numbers, itineraries, flight, train, rental car, car service, hotel or other similar information. | We will use this information to arrange or reimburse travel where you require travel to interview with us or in connection with your candidacy for employment, to contact you during travel, as necessary with travel service providers, or in an emergency situation. |
Results of background checks and screening: such as education verification, driver history and /or license checks, and more sensitive information relating to criminal records. | We may use this to determine your suitability for certain job roles (to the extent permitted or required by law). With your permission, we will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). A review of your criminal records history is necessary in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. |
Sensitive personal information relating to Health and disability records: such as information relating to any disability or health status or condition (including COVID vaccination status) that is relevant to your role that you disclose to us during the application process and for which you may need a reasonable accommodation. | We will use this information to address our legal obligations to you, make any adjustments required to assist you in the application process or performance of the role for which you are applying and determine whether you are fit to undertake tasks required by the job for which you are applying. |
Sensitive personal information relating to Equal opportunities monitoring information: such as your race, color, religion or creed, national origin or ancestry, sex (including gender, pregnancy, sexual orientation, and gender identity), age, physical or mental disability, veteran status. | We will use this to conduct equal opportunity and diversity monitoring where permitted or required by law. |
In-Person Visitor Information: such visitor security badge logs, security camera footage, and meeting information. | This information may be collected at our facilities as part of our day-to-day visitor security practices. Additional sensitive personal information relating to health information may be collected when and if necessary for in-person meetings to prevent the spread of COVID-19. |
In addition to the above, it is in our legitimate interests to decide whether to appoint you to the role for which you are applying since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract of employment with you, if applicable.
Having received application, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role we will then contact your references and, if applicable for the role, carry out a motor vehicle/driver’s history and/or criminal background screening before confirming your appointment.
Collection and Use of Special Categories of Personal Data
The following special categories of personal data are considered sensitive under the European data protection laws and may receive special protection:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Data concerning health
- Data concerning sex life or sexual orientation
- Data relating to criminal convictions or offences
We may collect and process the following special categories of personal data when you voluntarily provide them, or we receive them from a third party with your consent, when relevant for a particular position to carry out our obligations under employment law, or as applicable law otherwise permits:
- Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position;
- Race or ethnic origin to comply with statutory obligations; and
- Previous criminal charges or convictions where relevant for the position.
Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.
Automated Decision-Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
If You Fail to Provide Personal Information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
- How Your Personal Information is Collected
We collect personal information about candidates from the following sources:
- You, the candidate;
- Recruitment agencies and Internet job boards (such as LinkedIn, Monster.com, Indeed, Glassdoor, Direct Employer, and Recruit.net), from which we collect resumes, cover letters, and professional biographic information; and
- Third-party vendors that process criminal background and driver’s license/motor vehicle background screening information. Please note that driver’s license/motor vehicle driving history is sourced from publicly accessible sources.
- Additional Purposes for Using Personal Information
In addition to the uses set forth above, the Company may use and share the personal information or categories of personal information identified:
- Where we need to perform the contract we have entered into with you;
- Where we need to comply with a legal obligation; and
- Where it is necessary for legitimate interests pursued by us or a third party (for example the defense of potential legal claims or maintaining standards of performance and discipline) and your interests and fundamental rights do not override those interests.
- We may also use your personal information in the following situations, which are rare:
- Where we need to protect your interests (or someone else's interests) or
- Where it is needed in the public interest.
- Data Sharing
We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.
We require all of our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances;
- To protect the rights and property of the Company;
- During emergency situations or where necessary to protect the safety of persons;
- Where the personal data is publicly available;
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction; and
- For additional purposes with your consent where such consent is required by law.
In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data when it is feasoable and appropriate to do so.
- Transfer of Personal Information to Other Jurisdictions
Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Notice. If you are located in the UK or EU, we have implemented standard contractual clauses to secure the transfer of your personal data to the United States and other jurisdictions, as necessary to perform our contractual obligations with you.
- Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach when we are legally required to do so.
- Data retention
We will retain your personal information for a period of 36 months after we have communicated to you our decision about whether to appoint you to the applicable role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
- Rights of Access, Correction, Erasure, and Objection
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Withdraw your consent. When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
If you want to exercise any of these rights please submit a personal data request:
- By calling us at: 1-855-665-0026. Please leave a detailed message, including your name, email, mailing address, and specific request regarding your personal data.
- Sending a request by postal mail to the following address:
Audacy International, LLC
Attn: Legal Department – Privacy Officer
2400 Market St., 4th Floor
Philadelphia, PA 19103
USA
For spam filtering purposes, only email with the subject line “Audacy Privacy Request” will be read. Please include your name, mailing address, and the year that you applied for a position with Audacy. Please also identify yourself as an individual that has previously applied for a position with Audacy.
- Changes to this Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
- How to Contact Us with Questions About this Privacy Notice
Additionally, the Company’s Privacy Policy is available on our website at: https://audacyinc.com/privacy-policy/
If you have questions regarding this Notice, about our processing of your personal data, or would like to make an access or other request please contact us at:
Audacy International, LLC
Attn: Legal Department – Privacy Officer
2400 Market St., 4th Floor
Philadelphia, PA 19103
USA
By email: privacy@audacy.com
For spam filtering purposes, only email with the subject line “Audacy Privacy Request” will be read.
