Last Updated: January 1, 2023
Introduction
Instructure and its affiliated entities worldwide (“Instructure”, “we”, “us”) have developed this Prospective Employee Privacy Policy to help our prospective employees understand our policies on collection, use, and sharing of human resources data. We are committed to protecting the privacy of your personal information and to maintaining the integrity and security of human resource data. Residents of California should also review the California Privacy Notice provided as part of this policy.
Information Collection
We may collect and process personal data about you where the laws of your jurisdiction permit it. We may rely on the following legal bases to process personal information about you:
- Contract: It’s necessary to process your personal data to perform a contract with you, or because you have requested that we do something before creating a contract with you which requires that we process your personal data. For example, we process your name and passport information to begin the employment relationship.
- Legitimate Interest: There is a commercial or business interest that is important to us or others which we’ve balanced against your privacy rights. For example, we may process your resume to evaluate your fitness for the role you have applied for.
- Consent: We have asked for your permission to use your personal data. For example, we may ask for your permission to conduct a background check.
- Legal Obligation: It’s necessary to use your personal data so that we can fulfil our legal and regulatory obligations. For example, some employment and recordkeeping laws require we collect and retain certain information about prospective employees.
We process the following categories of personal data pursuant to the following legal bases:
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Instructure may receive personal data from you directly or from third parties. For example, Instructure may receive personal data from referees, recruiters, previous employers, educational establishments, third-party providers of pre-employment screening, colleagues and managers, customers and business contacts, consultants, members of the public, courts, public authorities, or other public sources, etc.
Information Use
In addition to what is set forth above, Instructure processes personal data for the following purposes:
- As required to establish the employment contract, including recruiting and hiring;
- As required by Instructure to enable its business, in particular to provide access to Instructure’s offices and management of Instructure’s IT systems and infrastructure;
- Protecting the security of Instructure’s premises, assets, systems, and intellectual property and enforcing company policies, including monitoring communications where permitted by local law, in protection of company property, and for investigations;
- Compliance with applicable laws and protection of Instructure’s legitimate business interests and legal rights, including use in connection with legal claims, compliance, regulatory, investigative purposes, and in accordance with Instructure’s ethics and compliance reporting tools; and
- To make automated decisions, which may include, for instance, evaluation of skills, experiences, or achievements, as allowable by law. We may make hiring decisions based on such analysis.
Information Sharing
We may share the information we collect with other parties, including the following:
- With other Instructure group companies when necessary for business purposes;
- With third party service providers who will process it on behalf of Instructure for the purposes above;
- As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, with Instructure advisers and any prospective purchaser's adviser and will be passed to the new owners of the business;
- With government authorities and/or law enforcement officials if required for the purposes above, if mandated by law, and if required for the legal protection of Instructure’s legitimate interests in compliance with applicable laws; and
- With your consent or as otherwise disclosed at the time of data collection or sharing.
We may share information that has been de-identified or aggregated without limitation.
Retention of your data
Instructure will keep data retained from the application and selection process to the extent permitted after the application process. In some cases, we may retain information for review related to other job openings.
Prospective Employees in the EEA and UK
This section applies to prospective employees located in the European Economic Areas (“EEA”). Switzerland, or the United Kingdom (“UK”).
Transfers outside of the EEA or UK
Personal data may be transferred to our affiliates in the United States, and to suppliers in countries outside the European Economic Area (“EEA”) or United Kingdom (“UK”) and may be stored and processed manually and electronically through global systems and tools for the purposes outlined above.
When transferring personal data to countries outside the EEA or the UK, we are required to ensure your personal data is adequately protected in the country where it is transferred. We transfer personal information to these countries only when it is subject to safeguards that assure the protection of personal information, such as entering contracts with transferee companies called the “standard contractual clauses” and the “UK addendum,” which require companies outside the EEA or UK to protect your personal data to the same extent as if it had remained in the EEA or UK.
Your rights
If you wish to access your personal data you should contact the People team via hr@instructure.com, or as described in the section below titled “How to Contact Instructure”.
You have the right to ask Instructure to rectify, block, complete, and delete your personal data, to restrict its use. You have the right to request further information about the handling of your personal data. You also have certain rights to data portability. In addition, you can object to the processing of your data by Instructure in some circumstances and, where we have asked for consent to process your data, to withdraw this consent.
There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if Instructure is legally prevented from disclosing such information. In addition, Instructure may be able to retain data even if you withdraw your consent, where Instructure can demonstrate that it has a legal requirement to process your data.
You also have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.
California Prospective Employees
Under the California Consumer Privacy Act (“CCPA”), Instructure is required to inform California residents who are prospective employees about the categories of “personal information” we collect about you and the purposes for which we will use this information. This information can be found in the “Information Collection” and “Information Use” sections above. This notice also applies to any personal information that we may collect about your emergency contacts and/or other individuals you may provide information about.
This notice applies only to “personal information” that is subject to the CCPA. For example, this notice does not apply to personal information that is exempted from the CCPA, such as personal information covered by other privacy laws like the Health Insurance Portability and Accountability Act, the Confidentiality of Medical Information Act, or the Fair Credit Reporting Act.
We may collect information about you that is unrelated to the role you have applied for, if you visit our website or one of the websites or apps that uses our services. More information about our privacy practices and your rights as a consumer under the CCPA can be found in our California Privacy Notice.
Updating Your Information
When you have an account with us, you may review, change, or update your information by contacting as described in the “Contact Us” section below.
Changes to This Notice
If our information practices change, we will post these changes on this page. We encourage you to visit this page periodically to learn of any updates.
How to Contact Instructure
If you have questions, comments, or concerns about this prospective employee privacy policy, please the Privacy team at: privacy@instructure.com or you may reach out to your local Instructure office directly.
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