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Privacy Agreement 

ALNYLAM Pharmaceuticals Recruitment Privacy Notice


This Privacy Notice was last updated on October12th 2018.


ALNYLAM Pharmaceuticals, and its subsidiaries and affiliates (“ALNYLAM”, “us”, “we”), understand that your privacy is important. ALNYLAM subsidiaries and affiliates (http://www.alnylam.com/contact-us) may process your personal data in their capacity as data controllers. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with ALNYLAM’s recruiting processes and programs.


This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, and our optional recruiting programs and events. It does not apply to our employees, contractors or clients, or other personal data that ALNYLAM collects for other purposes.


As used in this Privacy Notice, “personal data” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative recruitment channels (e.g., via professional recruiting firms), or as part of references or background checks. 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 EUdataprivacy@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. “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


By submitting your personal data to us, you acknowledge that:

 

 

  • You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
  • Your personal data may be transferred and processed worldwide, including to third countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.

  • You are not required to provide any requested information to us but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.

  • All your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.

  • This Privacy Notice does not form part of any contract of employment offered to candidates hired by ALNYLAM.

Personal data 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, and test results. We also may collect personal data about you from third parties, such as your references, prior employers, ALNYLAM employees with whom you have interviewed, and employment background check providers, to the extent this is permitted by applicable law. We may also collect and process your personal data from publicly available social media profiles e.g. Facebook, LinkedIn.


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).


Use of your personal data


We collect and use your personal data in connection with your application for employment and if your application is successful, for legitimate human resources and business management purposes related to your employment and benefits including:


  • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;

  • recordkeeping in relation to recruiting and hiring;

  • ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;

  • conducting criminal history checks as permitted by applicable law;

  • 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

  • emergency situations where the health or safety of one or more individuals may be endangered.

  • Being contacted by us or our recruitment partners via the details you have provides us in relation to your application

     

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


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


We will also retain your personal data to consider you for future employment opportunities that may arise in the next 12 months and may keep your data which may vary depending on the country but will not exceed a period of 2 years.  If you do not wish us to retain your data for such purposes, you can always opt-out at any given time. 


If you wish to correct or complete or otherwise update your personal data held by us, or you have any questions regarding how we use or store your personal data please contact us at EUdataprivacy@alnylam.com.


Data recipients and international data transfers


Your personal data may be accessed by recruiters and interviewers 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. Individuals performing administrative functions and IT personnel within ALNYLAM may also have a limited access to your personal data in order to perform their jobs. We have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by ALNYLAM subsidiaries and affiliates within the ALNYLAM global organization, including the transfer of your personal data to countries other than the one in which you reside. Please note that the data protection laws of such third countries may not be equivalent to those in your country.


We also use third party service providers to provide a recruiting software system. We also share your personal data with other third-party service providers that may assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices. These service providers may include insurers and professional advisors. We may also share your personal data with references.


We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data. Where required by law, we put in place legal mechanisms designed to ensure adequate data protection of your personal data.


In the case of any cross-border data transfer, 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. 


In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business, we may disclose or transfer your personal data.


An updated list of all third-party recipients, controllers or processors, processing personal information of job applicants and potential candidates of ALNYLAM, can be made available to you upon submission of a relevant request via e-mail at EUdataprivacy@alnylam.com.


Data retention


If you accept an offer of employment by us, 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 we do not employ you, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on the country and will not exceed a period of 2s year) for system administration and reporting purposes, to consider you for potential future roles and employment opportunities and to perform research.


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.


Security of Processing


We have implemented generally acceptable standards of technical and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized personnel of ALNYLAM and of our third-party service providers are provided access to personal data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data.


Your rights


We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Notice and applicable data protection laws.


You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data and information with regard to the related data processing; where personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer; you will also be provided with a copy of your personal data undergoing processing.


You have the right to correct or to complete personal data that we hold about you that is inaccurate or incomplete.


In certain circumstances, you have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller.


You also have the right to object to be the subject of automated decision making, including profiling.


Upon certain conditions, you have the right to request the erasure of your data; you also have the right to restrict the processing of your data or to object to certain types of processing such as direct marketing. You can also withdraw your consent to the processing of your personal data by ALNYLAM at any given time and without giving reasons.


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


To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the ALNYLAM’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.


In addition, and where granted by applicable law, if you are not satisfied with how your personal data is being processed by ALNYLAM (or third parties), or how your request or complaint has been handled by ALNYLAM, you have the right to lodge a complaint directly with ALNYLAM’s data protection representatives (our EU Data Privacy Officer at EUdataprivacy@alnylam.com ) or 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  


Cookies and other tracking technologies


We may use Cookies and other tracking technologies to provide individuals with a customized online experience. 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


If you have any questions about this specific Recruitment Privacy Notice, our general Privacy Policy or if you require any assistance in navigating or reading the content on ALNYLAM sites, please contact us at:


Email address: EUdataprivacy@alnylam.com


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.