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Privacy Agreement 

Alnylam Pharmaceuticals Recruitment Privacy Notice


This Privacy Notice was last updated on March 4th, 2019.


"Alnylam " means Alnylam Pharmaceuticals Inc and any of its subsidiaries and affiliates. Alnylam is also referred to in this Notice as "we", "us" or "our".  You can contact us at privacy@alnylam.com  for a list of all other Alnylam entities.


For the purposes of this notice Alnylam is the data controller.

 
Purpose

The Notice provides you with ("you" or "your”) information regarding how we handle, process and protect your personal data, in connection with our recruiting process as well as informing you of the rights that you have under data protection law.  Please read this Notice carefully prior to providing your personal data to Alnylam.


As used in this Privacy Notice, “personal data” means information that identifies job applicants and potential candidates for employment with Alnylam, either submitted as part of the online application and/or through alternative recruitment channels (e.g., via social channels, professional recruiting firms or thorough our Employee Referral Scheme).


An updated list of recruiting agencies and other third-party sources, providing Alnylam personal information on job applicants and potential candidates, can be available to you upon submission of a relevant request via e-mail at privacy@alnylam.com.


We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable data protection laws, in which case, applicable data protection laws will prevail.

 
Legal Basis for Processing

Alnylam must have a legal basis for processing your personal information.  The legal basis for processing varies for the different types of personal information we collect, process and disclose.  Most commonly, the conditions for processing your personal information in relation to recruitment will be one of the following:

  • Consent - You have given your consent for the processing to take place e.g. contacting and disclosing information to a referee or for pre-employment screening where applicable
  • Legitimate interests - the processing is necessary for our legitimate interests or the legitimate interests of a third party e.g. to process and assess your application for employment with us.

Where we have relied on your consent as the legal basis for processing your personal information, you have the right to withdraw your consent at any time.  For further information on how to withdraw your consent please see the “Your Rights” section.

 
The Information we collect

The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.


We usually collect personal data directly from you when you apply for a role with us, such as your name, address, contact information, work and educational history, achievements, test results and other relevant information from your Curriculum Vitae (CV). We also may collect personal data about you from third parties, such as your references, prior employers, and Alnylam employees with whom you have interviewed.  We may also collect and process your personal data from publicly available social media profiles e.g. Facebook, LinkedIn.  Finally, we collect and store login and password details for your online account.


Sensitive personal data is a subset of personal data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as allowed by law. We do not seek to obtain and will not collect such data about a candidate unless permitted or required to do so by applicable laws (e.g., government reporting in the US).

 
How we use your personal data

We collect and use your personal data in connection with your application for employment:

  • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
  • supporting and processing your application, for example, so we can assess your ability to meet the specification,
  • to verify references and professional qualifications provided by applicants;
  • evaluating and assessing the results of interviews;
  • record keeping in relation to recruiting and hiring;
  • carrying out pre-employment screening, that is appropriate and proportionate to the nature of the job function, subject to specific local regulations;
  • protecting our legal rights to the extent authorized or permitted by law; or
  • Being contacted by us or our recruitment partners via the details you have provides us in relation to your application

We may also analyse your personal data or aggregated/anonymised data to improve our recruitment and hiring process and augment our ability to attract successful candidates.

 
Automated Decision Making

We do not make recruiting or hiring decisions based solely on automated decision-making.

 
Who we share your data with
  • Within Alnylam – We restrict access to your personal data to people within Alnylam who “need to know” that information, e.g. the individuals who will process your job application and manage the recruitment process working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Alnylam global organization.
  • Outside Alnylam – Alnylam shares your personal data with trusted third-party providers, in order to manage recruitment, notably to conduct screening and verification of your application and the information you provide, e.g. academic/professional qualifications, where necessary and applicable.

Generally, Alnylam will only disclose your personal data to other third parties:

when required to do so by law;
  • in response to a legitimate request for assistance by the police or other law enforcement agency; and
  • to seek legal advice from Alnylam’s external lawyers or in connection with litigation.
International Transfers

In the case of any cross-border data transfer e.g. the transfer of your personal data to countries other than the one in which you reside, Alnylam shall ensure that appropriate data safeguards are in place to ensure an adequate level of data protection as the one provided in the European Union through the use of appropriate contractual arrangements with third-party recipients established in third countries; in particular, Alnylam shall execute with such third-party recipients the appropriate EU Standard Contractual Clauses for cross-border data transfers from the EU to controllers or processors in third countries, as adopted by the European Commission. 


Please note that the data protection laws of such third countries may not be equivalent to those in the country where you reside.  

 
Data Retention

If you accept an offer of employment by Alnylam, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements and internal policies and procedures.


If your application is unsuccessful, we will hold your personal data on file for the purpose of system administration and reporting purposes and to consider you for potential future roles and employment opportunities.  This will be for a period which may vary depending on the country but will not exceed a period of 2 years or 1 year for EU citizens.


At the end of such period we may ask you to renew your consent and provide you an opportunity to update your personal data. If you accept, the retention period shall be extended, otherwise your data will be safely and permanently deleted from our records, in accordance with our data retention policy and schedule.

 
Your rights

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below.  We will require evidence of your identity before we are able to act on your request.

  • Right of Access - Access to the personal data we hold about you, free of charge in most cases.
  • Right to Rectification - The correction of your personal data when incorrect, out of date or incomplete.
  • Right to Erasure - The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end. 
  • Right to Data Portability - A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
  • Right to object to or restrict processing - Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made. 
  • Right to Object - That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
  • Rights in relation to automatic decision making and profiling - Review of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).

If you would like to exercise any of the above rights or make a request to access, review, or correct the personal data we have collected and hold about you, or to receive further information on how we process your personal data, please contact us at privacy@alnylam.com.

 

Children’s Policy
We are committed to protecting the privacy of children. You should be aware that our recruitment site is not intended for, or designed to attract, children under the age of 16. No information should be submitted to Alnylam through the web site by visitors who are less than 16 years old. As noted above, we do not collect personally identifiable information unless you provided it to us including an individual’s age.


Your California Privacy Rights
California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. As stated in our Privacy Policy, Alnylam will not sell or share your personal information with anyone other than our research and/or development partners or agents and will not sell or share your personal information with anyone for their direct marketing purposes. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us as at privacy@alnylam.com.

Cookies and other tracking technologies

Alnylam does not track its users over time and across third party websites and therefore does not respond to Do Not Track (DNT) signals.  Alnylam does not authorize third parties to collect Personal Data directly from our users on our web site, such as through the use of third party advertisements.


You can learn more about our use of Cookies and other tracking technologies by reading our Privacy Policy available here   http://www.alnylam.com/privacy-policy/  as well as our Cookies Notice available here http://www.alnylam.com/legal-notice/.

 

Contact Us

If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us at privacy@alnylam.com

 
The Right to Complain

If you have any concerns or complaints regarding the processing of your personal data, or our compliance with the EU General Data Protection Regulation (GDPR), you can contact Alnylam’s Data Protection Officer Arianna Sekeri at EUdataprivacy@alnylam.com

 
Contacting the Regulator

EU residents also have the right to lodge a complaint with the with the competent data protection authority, contact details of which can be reached at the following link: https://edpb.europa.eu/about-edpb/board/members_en.  

 

Alnylam reserves the right to modify this Privacy Notice. We will post any changes made to our Privacy Notice on this page. Please check this page regularly to keep up-to-date.