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Recruitment Privacy Statement

HOK's Recruitment Privacy Statement

Version: 3.1 | Date: February 21, 2024

HOK Group, Inc., together with its subsidiaries and affiliates (“HOK”, “we” or “us”), is committed to protecting your personal information. All personal information provided by you or collected from third-party sources as part of the recruitment process is handled in accordance with privacy and data protection laws in the countries where HOK operates and on the terms set out in this Recruitment Privacy Statement. If you are hired by HOK, your personal information will be handled in accordance with HOK’s Corporate Integrity Handbook and your local Employee Handbook, which will be made available to you on your start date and available on HOK’s intranet.

HOK DOES NOT SELL PERSONAL INFORMATION TO OTHERS.  Residents of the European Union (“EU”), the UK and the State of California should refer to Section 7.0, Data Rights for information regarding their rights under applicable law.

1.0          HOW INFORMATION IS COLLECTED

HOK may collect your personal information orally, by telephone, in writing, by email, by publicly available online sources, and by online application at silkroad.hok.com. Information obtained in the application, review, and selection of employees (referred to as the “recruitment process”) will be handled in accordance with applicable law. HOK collects personal information directly from the individual to whom it relates, except where that individual has consented to HOK collecting the personal information from a third party or the law otherwise permits HOK to do so.

Personal information may be collected from, and disclosed to, third parties as necessary during the recruitment process, to ensure that the information HOK has is correct and to determine whether the applicant is suited to the available position. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. HOK may take steps to verify that academic, training and professional qualifications are accurate and complete and, in appropriate circumstances due to the nature of the available position, we may carry out criminal background checks and/or drug testing. Third parties may include: (i) recruitment or human-resource service providers; (ii) testing facilities; (iii) former employers; (iv) social media/network accounts; (v) police and other law enforcement agencies; and (vi) employment screening companies.

In each case, HOK treats personal information in accordance with the relevant privacy and data protection laws in the country in which we are operating, and we will take reasonable steps to ensure the personal information that we store is current, accurate, complete and confidential.

2.0         TYPES OF PERSONAL INFORMATION COLLECTED

2.1          Personal Information

Personal information means any information relating to a person or their household that enables them to be identified either directly or indirectly. Personal information that we hold about you may include your: (i) contact details (e.g. name, phone number, address and email address); (ii) academic qualifications; (iii) work experience; (iv) portfolio of work; (v) previous employment references; (vi) professional licenses; (vii) birth date; (viii) proof of identification; (ix) gender; (x) marital status; (xi) emergency contact information; (xii) spouse’s name; (xiii) spouse’s contact details; (xiv) dependents’ names; (xv) citizenship details (e.g. country of origin, visa, work permit, etc.); (xvi) current/past job titles; (xvii) current/past compensation; and (xix) C.V./ resume.

2.2          Sensitive Personal Information

Where required to do so by law, HOK collects information on the race/ethnicity of employees. In rare circumstances, when required by contract to do so, we may need to collect sensitive personal information about you, which may include criminal offenses committed by you or illegal drug screening results.  We will only use such sensitive personal information where we are legally able to so and in order to: (i) administer or process the job application that you have with us; and/or (ii) assess and respond to a complaint you might make relating to our job application process.

3.0          HOW PERSONAL INFORMATION IS USED

Your personal information is collected primarily for the purposes of evaluating your qualifications for the position(s) available at HOK. Your personal information will be used to: (i) select suitable employees for HOK; (ii) confirm information on resume, C.V., and cover letter is correct; (iii) equal opportunities/affirmative action research, reporting and monitoring; (iv) respond to any complaints you might make to us; (v) for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase, or investment in the business; (vi) improve services provided by HOK; (vii) assist you with any future requirements, including to answer reasonable inquiries by any of your future employers; and (viii) comply with HOK’s legal and regulatory obligations.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

4.0          GROUNDS FOR PROCESSING

To process your data lawfully we will rely on one or more valid legal grounds. The grounds we will rely upon include:

  1. Our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your data to prevent or detect fraud or abuses of our job application process and to verify your qualifications are as you represent them to be.
  2. Our compliance with a legal obligation. For example, we have a duty to investigate and check that you are legally entitled to work in the relevant country.

Where we process sensitive personal information about you, we rely on further legal grounds to process your information, in addition to those set out above, including:

  1. The processing of that information is necessary for the purposes of carrying out our legal rights and obligations in connection with employment. For example, we may be required on a high security project, such as an airport project, to retain employees who can meet the security requirements mandated by law, the airlines and airport operator. Such requirements may include passing a criminal background check and/or illegal drug screening.

5.0          RETENTION OF PERSONAL INFORMATION

If you are successful and offered employment with HOK, your personal information will be retained and transferred to your personnel file and used to manage your employment relationship with HOK. If you are not successful, we will only retain your information in accordance with our Record Management Program 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. We may retain a copy of your resume for potential future opportunities. If we wish to do this, we will write to you separately seeking your explicit consent.

6.0          CONFIDENTIALITY AND SECURITY

HOK is committed to: (i) seeking to safeguard all personal information that you provide to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected.  We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, subsidiary companies and third parties who need to know that information for the purposes set out in this Recruitment Privacy Statement.

6.1       DATA PROTECTION PRINCIPLES

HOK and Other Covered Entities (defined below) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  HOK has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  HOK has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

For DPF purposes, HOK refers to HOK Group, Inc. and “Other Covered Entities” refers to each of the following:

Hellmuth, Obata & Kassabaum, Inc.

HOK International, Ltd.

Hellmuth, Obata & Kassabaum, PC

HOK Architects, Inc.

HOK International Holdings, Inc.

HOK, Inc.

HOK Overseas, LLC

In cases of onward transfers to third parties of data received pursuant to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, HOK is potentially liable under the DPF Principles.

If HOK does not timely acknowledge a complaint, or if we have not satisfactorily addressed a complaint, data subjects may: (i) submit their complaint to their local data protection authority for referral to the U.S. Department of Commerce; or (ii) seek a non-monetary remedy through binding arbitration administered by the International Centre for Dispute Resolution® - American Arbitration Association® (“ICDR-AAA”) in accordance with the DPF Principles. The services of ICDR-AAA are provided at no cost to data subjects. To learn more about the independent recourse mechanism provided by the ICDR-AAA, please visit go.adr.org/privacyshield.html.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, HOK commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.

The Federal Trade Commission has jurisdiction over HOK’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

7.0          DATA RIGHTS

Your rights regarding data collected and used by HOK are subject to applicable law.  HOK will comply with a verified request to exercise your rights or provide you with a lawful basis for not doing so when applicable.

7.1          EU and UK RESIDENTS

The EU General Data Privacy Regulation (“GDPR”) and the UK GDPR, which includes similar rights, provide EU and UK residents with certain rights discussed below.  EU and UK residents may contact HOK regarding any of these rights by email at privacy@hok.com or by mail to HOK Group, Inc., 10 South Broadway, Suite 200, St. Louis, Missouri, USA, 63102; Attention: Corporate Compliance Officer.  HOK will respond within a reasonable time following receipt of a verified data subject request, in any event, within the time period specified by law. Persons exercising these rights may be required to submit a proof of identity and residency in the EU or UK as appropriate at the time the request is made. EU and UK residents have the right to:

  1. Obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you by contacting us as directed above.  HOK may deny a request to obtain a copy of your personal information when: (i) providing access to information would have an unreasonable impact on the privacy of others; (ii) the information relates to a legal proceeding or an investigation; (iii) we are required by law or contract not to disclose the information; (iv) we have an option under law not to disclose the information and have formed a good faith view that it would be inappropriate to provide access; (v) we are unable to verify your identity or residency at the time the request is made; or (vi) it is otherwise lawful to refuse the request.
  2. Correct your personal information. You may request that we rectify any inaccurate and/or complete any incomplete personal information by contacting us as directed above. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
  3. Withdraw your consent to processing. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time by contacting us as directed above. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential. It is therefore very unlikely that we would be able to continue processing your application.
  4. Object to processing. You may, as permitted by law, request that we stop processing your personal information by contacting us as directed above.
  5. Erasure. You may request that we erase your personal information by contacting us as directed above. We will comply, unless there is a lawful reason for not doing so.
  6. 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.
  7. Request the transfer of your personal information to another party.
  8. Lodge a complaint. We suggest that you first contact us as directed above regarding any questions or complaints in relation to your rights or how we process your personal information.  However, this does not limit your right to directly contact your local data protection authority.

7.2          CALIFORNIA RESIDENTS

Please refer to Sections 2-4 of this Privacy Statement above for more information about what information HOK collects and how it is used.  If you have any questions about this Privacy Statement or how we handle your personal information, or if you have a disability and need an alternative format for the information provided by this Privacy Statement, please contact us by email at privacy@hok.com; by mail at HOK Group, Inc., 10 South Broadway, Suite 200, St. Louis, Missouri, USA, 63102, Attention: Corporate Compliance Officer; or by telephone at 1 (866) 838-0888.

HOK does not sell personal information as defined under the CCPA.

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