Last Updated: 19 December 2019
Effective Date: 1 January 2020
This Notice describes the types of personal data that Rosewood collects, how we use and share your personal data, and the rights available to you. This Notice also describes the measures Rosewood takes to protect the security of the data and how you can contact Rosewood about our data protection practices.
It is important for you to review this Notice before submitting your application and personal data to us for consideration for employment, intern or apprenticeship. By submitting your personal data and by using the Rosewood Careers Website, your personal data will be handled and protected in accordance with this Notice.
This Notice is written in English and may be translated into other languages. In the event of any inconsistency, the English version shall prevail.
This Notice is intended to help you better understand the following:
1. General Information
2.What Personal Data Do We Collect
3. How Do We Collect Your Personal Data?
4. Why Is Personal Data Used?
5. How Long Do We Retain Your Personal Data?
6. When And To Whom Do We Disclose Your Personal Data?
7. Do We Sell Your Personal Data?
8. Cross-Border Data Transfers
9. Security and Integrity Of Your Data
10. Law Applicable To Your Application
11. What Are Your Rights and How To Exercise Your Rights?
12. Updating Your Personal Data
13. Legal Effect and Changes to this Notice
14. Other Important Provisions
15. Contact Us
1. GENERAL INFORMATION
In some locations around the world, Rosewood manages the day-to-day operations of hotels and other properties and performs recruiting and hiring functions on behalf of an independent third-party owner (an “Owner”). At many of these properties, the Owner may be the actual employer.
By applying for positions at Rosewood Careers Website and accordingly submitting your personal data, you may be applying for a position with a company other than Rosewood, i.e., the Owner. When Rosewood collects personal data about you in connection with such an application, Rosewood shares your personal data with the Owner to facilitate your potential employment. The Owner of the property for which you are applying for a position will act as the controller with respect to your personal data and the use of your information by such Owner will be governed by its own privacy practices. Following termination or expiration of our management agreements with an Owner, your personal data will stay with such Owner.
In particular hotels where Rosewood is the actual employer, the local Rosewood affiliate for which you are applying for a position will act as the controller with respect to your personal data. The use of your information will be governed by this Notice.
When you apply for a corporate-level position with Rosewood Hotel Group, Rosewood will act as a controller with respect to your personal data and the personal data pertaining to your application will not be shared with any Owner. The use of your information will be governed by this Notice.
2. WHAT PERSONAL DATA DO WE COLLECT?
A. Personal Data
“Personal Data” means any information relating to an identified or identifiable individual or as defined under applicable law.
When you apply for a position, Rosewood collects the following Personal Data about you:
- Contact Details And Identification Details: This includes your name, physical address, e-mail addresses, phone number. It also includes your national ID number or work permits to work in the jurisdictions for which you applied; as well as your photo or image;
- Education And Skill Details: This includes your resume, CV, cover letter; educational background, job qualifications, professional and other work-related licenses and certifications; and language skills and proficiency;
- Interest In Rosewood: This includes the position for which you would like to submit an application, details of how you heard about the position for which you are applying; your willingness to travel and/or relocate; any information relating to any previous applications you may have submitted to Rosewood or your current/prior work experience with Rosewood;
- Third-Party Personal Information: This includes the name and contact details of your recruiter (if any); your third–party employment references or referrals;
- Other Information You Choose To Provide To Rosewood: Rosewood and/or other third parties acting on our behalf (e.g., to facilitate the Rosewood Careers Website) may receive data from you whenever you elect to provide other information.
- Background Checks: If you are extended an offer, you may be asked questions about your willingness to submit to a background or criminal record check and/or medical examination as permitted by applicable law. Information about you al so may be collected from third parties and/ or consumer reporting agencies, for example, in connection with a background check or employment confirmation, and/or employment references, where permitted by applicable law. (See Section 15 “Contact Us” below to contact us to learn more about Rosewood’s background checks policies.)
If you provide us with the Personal Data of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
B. Sensitive Personal Data
Depending on the jurisdiction in which you reside, we generally do not require what is considered sensitive personal information or “special categories of personal data” under applicable privacy laws (herein referred to as “Sensitive Personal Data”). Sensitive Personal Data refers to data that reveals an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, or data concerning health or data concerning a person’s sex life or sexual orientation.
Unless otherwise expressly requested, you are not required to submit this type of data as part of your online resume and application submission. If you decide to transmit this type of data to us during the application process, we reserve the right to delete such information from our databases.
See Section 15 “Contact Us” on how to contact us for more information.
Please note that during the application process, you may be asked about your willingness to complete a drug screen or medical examination or other background check in accordance with the position for which you may have applied. Any Sensitive Personal Data derived from such examinations are only processed with your prior explicit consent.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
Information You Provide To Us
Rosewood may collect the Personal Data described above when you apply online use our Website or provide to us in any other way. This includes the Personal Data described above when you apply for a position in the following ways:
- Online. When you apply online using the Rosewood Careers Website;
- By Email. When you send your Contact Details and Identification Details and Education and Skill Details (including your resume, CV, job application and other information) directly to a Rosewood hotel or other property via email;
- In Person.When you send your application in-person directly with a Rosewood hotel or other property.
- Using Social Media. When you apply for a specific job opening using your LinkedIn social media profile, certain Personal Data is shared with us consistent with your settings within the social media service, including your Contact Details and Identification Details and Education and Skill Details, and other information you make available on your profile.
The information we collect directly from you includes your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and, should we extend an offer to you, Background Checks.
Information We Collect From Others
Rosewood may collect your Personal Data from others including from recruiters or referrals.
The information we collect may include Contact Details and Identification Details, Education and Skill Details, Third-Party Personal Information and other information such recruiters and third-party referrals choose to provide us.
Your provision of Personal Data in connection with job application is generally voluntary. If the collection of any of your Personal Data is mandatory – for example, to complete an application on the Rosewood Careers Website – we will let you know this before we collect it, as well as the consequences of failing to provide us with this information (if any).
Please note that if you decide not to provide information, it may affect the consideration of your employment, unless our receipt of such information is prohibited by applicable law.
4. WHY IS PERSONAL DATA USED
Rosewood needs to process the Personal Data described above( including your Contact Details and Identification Details, Education and Skill Details, and Third-Party Personal Information) in order to potentially enter into an employment contract or relationship with you. This includes for the following business purposes:
- Process your application for employment;
- Communicate with you;
- Provide you with services and respond to your inquiries, including on the Rosewood Careers Website;
- Assess your qualifications for a particular position (including to interview, screen, and evaluate you);
- Verify your identity and employment eligibility; and
- Verify employment references and referrals.
Rosewood also processes the Personal Data described above where it has a legitimate interest to do so or is legally obligated. For example:
- To manage record-keeping and reporting obligations in connection with its applicant pool;
- For Rosewood-managed properties, to communicate with Owners regarding qualified candidates for employment;
- If you are offered a position, to conduct criminal, medical and credit background checks (if and to the extent necessary with respect to the respective function of the position applied for); and
- To comply with applicant law and regulations.
5. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain Personal Data for the period necessary to fulfill the purposes outlined in this Notice, based on customary human resource practices and in accordance with applicable legal and regulatory requirements.
If you are selected for a position, your Personal Data will, at a minimum, be retained during the term of your employment, and such retention may be further extended by the applicable statute of limitation and applicable statutory data retention obligations, as the case may be.
Even if you are not selected for the position for which you applied or if you did not apply for a specific position, we may⸺with your consent⸺ retain your Personal Data in order to consider whether your skills are suitable for other job opportunities, in which case we would invite you to apply. Otherwise, your Personal Data will only be retained during the applicable statute of limitation and in order to comply with applicable statutory data retention obligations, as the case may be.
See Section 15 “Contact Us” below to contact us to learn more about our retention policies, to withdraw your application for employment and/or your consent for continued retention of your Personal Data after the end of the recruitment process, and to request us to purge your Personal Data. Please note that applicable law may require that we retain your resume or CV for a specific period, even if you request that we do not consider your candidacy for employment.
6. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
Rosewood will only grant access to Personal Data to specific persons on a need-to-know basis. In the preceding twelve (12) months, we have disclosed or shared your Personal Data described as follows:
6.1.Authorized personnel responsible for job openings. Recruiters, managers or their designees, HR personnel, and IT staff, as may be required to manage the Rosewood Careers Website. Some of these people may be located in different jurisdictions, and as such, your Personal Data may be shared or accessible globally. Rosewood has provided these authorized personnel with categories of Personal Data such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood and Background Checks.
6.2.Select service providers. Select service providers such as third parties assisting Rosewood with the recruiting operations, such as operation of the Rosewood Careers Website and application tracking system. These service providers will be required to use appropriate measures to protect the confidentiality and security of Personal Data. For example, see Section 8 “Cross-Border Data Transfers” below. Rosewood has provided these third parties with categories of Personal Data such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.
6.3.Other third parties such as recruiters, references or referrals, agencies that facilitate background checks, or consultants. We may have to share the Personal Data for the below stated purposes:
- When it is necessary to involve a third-party service provider to facilitate or extend recruitment services, background check processing, and similar services; and
- When explicitly requested by you.
Rosewood has provided these third parties with categories of Personal Data such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.
6.4.Relevant Rosewood property personnel or Owners. Where Rosewood performs hiring services for Owners, your Personal Data will be shared with Owners for purposes of facilitating your employment contract or employment relationship. If a management agreement expires or is terminated, your Personal Data will remain with the applicable Owner.Your Personal Data will also be transferred to an Owner should you agreed to be transferred and work at such Owner’s property.
Rosewood has provided these property personnel or Owners with categories of Personal Data such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.
6.5.Government, law enforcement authorities and/or related business consultants in business transfer. We may have to share your Personal Data for the below stated purposes:
- As required by a court order or any other legal or regulatory requirement, including in response to requests from public and government authorities outside your country of residence;
- As required in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business assets (e.g., in connection with any bankruptcy proceeding);
- To protect our operations or those of any of our affiliates;
- To protect our rights, privacy, safety or property, or that of our affiliates, you or others; and
- To comply with or in accordance with applicable law.
Rosewood has provided these third parties with categories of Personal Data including your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.
7. DO WE SELL YOUR PERSONAL DATA?
Rosewood does not rent or share your information without your consent except in accordance with this Applicant Privacy Notice or for the purposes disclosed on any online form or location on the Services where you provide Personal Data to us. Rosewood also does not engage in the sale of Personal Data.
8. CROSS-BORDER DATA TRANSFERS
Due to the global nature of Rosewood’s business, Rosewood may share your Personal Data with other Rosewood hotels and group companies in order to fulfill the purposes described in this Notice. This may imply a transfer to countries outside the European Union (“EU”) where the local laws do not provide the same level of personal data protection as the country of your residence and/or the country where you are seeking employment.
Rosewood transfers your Personal Data across country borders and, in particular, from the EU to countries outside the EU in accordance with applicable local laws and regulations. To comply with EU data protection laws, Rosewood has entered into an Intercompany Data Transfer Agreement, under the terms of which all data importers outside the EU must process and protect all Personal Data received from the EU in accordance with standard contractual clauses (the “Clauses”), as approved by the European Commission.
The transfers of data to third-party providers are secured by implementing the safeguards required under the applicable data protection law (including contractual arrangements entered into with a third-party vendor). Third-party service providers are expected to protect the confidentiality and security of Personal Data, and only use Personal Data for the provision of services to Rosewood, and in compliance with applicable law.
Contact Rosewood (see Section 15 “Contact Us” below) to obtain a redacted copy of the Clauses or relevant data transfer agreements (excluding commercial terms).
9. SECURITY AND INTEGRITY OF YOUR DATA
Rosewood maintains appropriate physical, procedural, administrative, organizational and technical security measures intended to prevent loss, misuse, unauthorized access, disclosure, or modification of your Personal Data under Rosewood’s control. To comply with data protection laws and our internal policies, we address information security at all appropriate technology infrastructure points.
While we endeavor to protect the security and integrity of the Personal Data we collect, we cannot guarantee or warrant that any information, during transmission through the Internet or while stored on our system or otherwise in our care, is 100% secure from intrusion by others. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with Section 15 “Contact Us” below.
It is your sole responsibility to use the appropriate level of care whenever you communicate with us. Do not send sensitive information to us via email.
10. LAW APPLICABLE TO YOUR APPLICATION
The Rosewood Careers Website allows you to benefit from Rosewood’s centralized global recruitment function, while applying for jobs world-wide. The Rosewood Careers Website is operated from the United States. Accordingly, any Personal Data you submit to the Rosewood Careers Website will be collected in the United States and will be subject to U.S. laws, notwithstanding the possible additional applicability of laws in your country of establishment.
However, if we share your Personal Data with an affiliate or Rosewood-managed hotel property located in the country in which you are applying for a position, then the applicable entity will handle your Personal Data in accordance with this Notice, or the Owner’s own privacy practices. Any hiring or other employment-related decisions will be made by the hiring affiliate or hotel property in accordance with the laws of the country where the job will be located.
11. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE YOUR RIGHTS
Depending on the jurisdiction in which you reside, you may have certain rights regarding the collection and use of your Personal Data.
11.1 For Applicants in the EU/European Economic Area
You are entitled to obtain access to information on the processing of your Personal Data, to object to processing of your Personal Data, to make use of your right to data portability and to have your Personal Data rectified or deleted or their processing restricted. You also are entitled to withdraw any consent that you might have given with respect to the processing of your Personal Data at any time with future effect.
If you are not satisfied with Rosewood’s response or believe that your Personal Data is not being processed in accordance with the applicable law, you also may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law.
11.2 For Applicants in California
Depending on your relationship with Rosewood, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100, et seq.) provides you with specific rights regarding your Personal Data. The Personal Data we collect from you in your capacity as a job applicant or contractor of Rosewood may not be subject to the rights identified below.
Where applicable, your rights as a California resident include a right to be informed about collection, sale or disclosure, a right to access and obtain a copy of your Personal Data, a right to delete Personal Data, right to opt-out of the sale of Personal Data (where applicable), and a right to equal service for exercising your privacy rights.
11.3 For Applicants in Other Jurisdictions
Where permitted by applicable law, you may request access, correction and deletion of the Personal Data Rosewood has about you.
How to Exercise Your Rights
If you would like to exercise your rights or learn more about the processing of your Personal Data, please contact us under Section 15 “Contact Us”. Rosewood will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time.
(1) Verification Process
Your privacy and information security are important to us. For this reason, we verify your identity or authority to make the request and confirm the Personal Data relates to you, or others, if you are an authorized agent. Accordingly, Rosewood will collect your name, e-mail address and phone number to verify your identity. Upon receiving your request, we also contact you via email and/or other secured communication channel to verify your identity by asking you additional security questions in order to match to your identity with the data we maintain about you.
Please note that, if we cannot verify your identity, we are not obligated to provide you or your Authorized Agent information regarding your personal data.
(2) For Your Security
Rosewood does not collect sensitive information, such as your full credit card details, social security or national identification number, to verify your identity. Please do not send Rosewood sensitive information and be aware of any phishing scams or fraudulent calls requesting such information from you.
While we maintain commercially reasonable safeguards to protect your Personal Data, no method of transmission is 100% secure and we do not guarantee or warrant that your Personal Data is under absolute security with the existing security technology.
(3) Submitting Request via a Third Party
You may also exercise your rights via an authorized agent (“Authorized Agent”).
An Authorized Agent can be a third party that you authorize to act on your behalf, such as a third party with power of attorney.
If you are a resident of California, an Authorized Agent can only be a person or a business entity that you authorize to act on your behalf, to submit a verifiable consumer request related to your personal data.
When an Authorized Agent is submitting a request on your behalf, we will require such Authorized Agent to provide evidence of their entitlement, e.g., a written permission, declaration or affidavit demonstrating that they have authority to make the request on your behalf, and the Authorized Agent would have to verify their own identity directly with us.
(4) Disclosure of Personal Data
Once we have verified you or your authorized agent’s identity, we will disclose the specific pieces of Personal Data we collected about you, which will be made in writing and delivered through your account with us, if you maintain such an account. If you do not maintain an account with Rosewood, we will provide such information by mail or electronically, at your option, in a readily useable format that allows you to more readily transmit the information from one entity to another entity.
12. UPDATING YOUR PERSONAL DATA
Rosewood strives to maintain your Personal Data in a manner that is accurate, complete and up to date. However, you have an obligation to keep your Personal Data up to date and inform Rosewood of any significant changes to your Personal Data. Please contact us (Section 15 “Contact Us” below) if there are any changes in your Personal Data.
13. LEGAL EFFECT AND CHANGES TO THIS NOTICE
This Notice is not, nor is it intended to be, a contract, nor does it otherwise create any legal rights or obligations. Accordingly, Rosewood, in its sole and absolute discretion, may amend, interpret, modify or withdraw any portion of this and related practices with or without Notice, and in accordance with applicable law. Any change in this Notice will apply to all Personal Data in Rosewood’s possession regardless of whether such Personal Data was obtained before or after any such Notice change. If you need clarification regarding any aspect of this Notice, please contact us as provided for in Section 15 “Contact Us” below.
14. OTHER IMPORTANT PROVISIONS
About Children. Except where permitted by local law, the Rosewood Careers Website is not intended for individuals under the age of 18.
Rosewood’s Commitment to Diversity. Cultivating a diverse and inclusive work environment is crucial to success. We encourage applicants from all cultures, races, colors, religions, sexes, national or regional origins, ages, disability status, sexual orientation, gender identity, military, protected veteran status or other status protected by law. Rosewood is an equal opportunity employer.
15. CONTACT US
If you have any questions or comments about our privacy practices or this Notice, or to exercise your rights with respect to your Personal Data (as applicable), you may:
- Email us at email@example.com
- Calls us toll free in the U.S. at 1-866-923-1608
- Write to us at either
Rosewood Hotel Group
9220 W. Sunset Blvd, Ste. 200,
West Hollywood, California 90069
Attn: Legal Department
Rosewood Hotel Group
36/F New World Tower 1
18 Queen's Road Central, Hong Kong
Attn: Legal Department
You may also submit a request to exercise your rights by visiting <<Privacy Rights Request>>, where you will find more information on how to submit a request and how do we handle your request.