Global Candidate Privacy Notice

Last Updated and Effective Date: October 2, 2023

1. Introduction

This Global Candidate Privacy Notice (“Notice”) describes how Hillenbrand, Inc. and its subsidiaries and/or affiliates (collectively, “we,” “our,” “Hillenbrand” or the “Company”) will collect, use, store, and disclose the personal information about any individuals who apply to an open position with us, who we contact for or who express interest in employment with us, who attend a recruitment event or who undergo an interview or assessment with us, whether online or offline (“Candidate Personal Information”).

In general, personal information (also known as personal data) is any information that can identify who you are, either directly (for example, your name or identification number) or indirectly in combination with other information we may have about you. Some laws define “personal information” differently, and we use those definitions when they are applicable. In addition, many countries have specific legal requirements governing the use of personal information, including Candidate Personal Information. We will comply with all applicable laws and regulations and will implement additional policies and procedures when needed to meet these requirements. Accordingly, the actual Candidate Personal Information collected and/or accessed by the Company may differ from jurisdiction to jurisdiction to comply with local laws.

2. Candidate Personal Information We Collect and Process

We try to minimize the types and amount of Candidate Personal Information the Company may collect from or about you. The collection of information and access to such information will vary depending on country-specific legal and/or business requirements. We will notify you at the point of collection when the Candidate Personal Information that we request is voluntary (rather than required) to proceed with your recruitment process.

3. Sources of Candidate Personal Information

We may collect Candidate Personal Information from sources that include the following:

• Information you provide to us directly. We primarily obtain Candidate Personal Information from you. For example, when you create or submit a job application or provide personal data to us as part of the interview process.
• Information collected from other individuals. We may collect personal information from other individuals. For instance, references during the application process or if you are referred for a role by someone else, as permissible.
• External Sources. We may collect personal information from third parties such as job references, public databases and background check services, professional or sanctions registries, academic institutions and training or certification providers, information made publicly available on a social network or webpage (where permitted), and recruiting or executive search agencies.

We may combine information that we receive from the various sources described in this Notice and use or disclose it for the purposes described in this Notice.

4. Legal Basis for Processing Your Candidate Personal Information

Certain jurisdictions require Hillenbrand to have a legal basis for processing your personal information. Where applicable law requires us to justify our processing activities, our legal basis for collecting and using Candidate Personal Information as described in this Notice will depend on the personal information concerned and the specific context in which we collect it.

• In general, we will normally collect Candidate Personal Information from you where we have your consent to do so and where we need your personal information to process your application. By accessing our website/career portal or applying for one of our roles, you provide your consent to Hillenbrand to collect and further process the personal information described above for the purposes described in this Notice. You may withdraw your consent at any time by submitting a request to the contacts below.
• Legitimate Interests. In Hillenbrand’s legitimate interests, namely the recruitment, selection, evaluation, and appointment of new employees, the management and administration of the recruitment and HR processes, ensuring the recruitment of a diverse workforce and the safety of our workforce, to the extent our legitimate interests are not overridden by your fundamental rights and freedoms.
• Legal Obligations. Compliance with Hillenbrand’s legal obligations where employment laws or other laws require the processing of Candidate Personal Information.
• Vital Interests. We may also need Candidate Personal Information to protect your vital interests or those of another natural person.

We generally do not make recruiting or hiring decisions based solely on automated decision-making within the meaning of the EU General Data Protection Regulation. In the event we rely on automated decision-making that could have a significant impact on you, we will provide you an opportunity to express your views and will provide any other safeguards required by law.

5. Transfer and Sharing of Candidate Personal Information

Hillenbrand is a global organization. As such, some Candidate Personal Information may be transferred to or accessible by parties located outside of the country in which you reside, in accordance with applicable law:

Inside the Hillenbrand Group

• We may transfer Candidate Personal Information to other members of the Hillenbrand group companies, including but not limited to talent acquisition, human resources, and related hiring managers for the purposes of facilitating the recruiting and hiring process. Certain Hillenbrand group companies may also carry out IT-related or HR related tasks as data processors, i.e., on behalf and by instruction of other Hillenbrand group companies.

Outside the Hillenbrand Group

• We may also share Candidate Personal Information with service providers that support our talent acquisition teams during the recruiting and hiring process.
• We may also share Candidate Personal Information with governmental agencies and regulators, courts, external advisors, and social insurance carriers to comply with our legal obligations or enforce our rights.
• We may also share Candidate Personal Information with third parties if we transfer, purchase, merge or sell any part of our business or the business of a third party.
• Hillenbrand group companies contract with third-party service providers (e.g., banks, IT providers, payroll service providers, benefits providers), and your Candidate Personal Information may be disclosed to these to carry out certain business functions, such as IT support, payroll processing and administrative functions.

When Candidate Personal Information is transferred to or accessed from countries outside your home country, we implement appropriate safeguards as well as any legally required administrative, technical, and/or contractual requirements to protect your Candidate Personal Information. We perform transfers of data from the European Union and United Kingdom to outside the European Union and the United Kingdom, we utilize contractual protections (such as Standard Contractual Clauses). You may find these clauses here:  https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en or ask the contacts below for the applicable contracts.

6. Retention of Candidate Personal Information

We will only retain Candidate Personal Information for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory or internal policy requirements, whichever is longer. In general, although there may be exceptions, data relating to potential candidates for roles within the Company is kept for 12 months. Any maximum storage term set forth by applicable local law will prevail. If your application is successful, your application will be retained as part of your personnel record.

7. How We Protect Candidate Personal Information

We implement appropriate physical, administrative, contractual, and technical measures, such as encryption and access controls, designed to protect Candidate Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access or use, and all other unlawful forms of processing.

8. Your Rights

Subject to applicable law, you may have the following rights in relation to your Candidate Personal Information that we hold:

1. Right of access: To request information about the Candidate Personal Information stored about you.
2. Right to rectification: To request incorrect Candidate Personal Information be rectified.
3. Right to erasure (right to be forgotten): To request your Candidate Personal Information be deleted.
4. Right to restriction of processing: To request the restriction of processing of your Candidate Personal Information in certain cases.
5. Right to data portability: To request the data provided by you be provided in a structured, common and machine-readable format.
6. Right to object. To object to the processing of your Candidate Personal Information in certain circumstances. In such case, the controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Please note that the above rights may be limited under applicable data protection law. Depending on your location, you may have other or additional privacy rights. If you are a Californian resident, please refer to Additional Information for California Residents in Section 11 below.

Where our processing of your Candidate Personal Information is based on your consent, you have the right to withdraw your consent at any time.  If you decide to withdraw your consent, we will stop processing your Candidate Personal Information, unless there is another lawful basis on which we can rely.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.  You may submit a request through the applicable contacts below. If you have a complaint regarding the Company’s processing of your Candidate Personal Information, you may also lodge such complaints with the data protection authority in your country as applicable.

9. Changes to this Notice

We may modify this Notice to comply with changes in legal, regulatory, or operational requirements, our practices, and other factors. Where such changes materially affect our processing of your Candidate Personal Information or is otherwise required under applicable law, we will notify you accordingly.

10. Questions and Contacts

In most cases, the entity identified as the recruiting Company is the controller of your Candidate Personal Information, either solely or jointly with its affiliates within the Hillenbrand group of companies. If you have any questions about controllership, please contact us using the contact information provided below.

If you have questions about your Candidate Personal Information or specific subsidiaries and affiliates that may have access to your Personal Information, please email us at the contacts below. If you have any questions concerning this Privacy Notice or wish to exercise your rights noted above, please contact one of data protection contacts below.

11. Additional Information for California Residents

Pursuant to the California Consumer Privacy Act (CCPA), this section applies to certain personal data collected about Candidates that are California residents and supplements the rest of our Notice above.  The chart below provides a summary of our prior 12-month Personal Information handling practices based on the CCPA’s categories of Personal Information. You can learn more about the information we collect in the sections above.

You have the right to send us a request for the following rights covering the twelve-month period that precedes your request. Please note that these rights are not absolute and in certain cases are subject to limitations as specified in applicable law:

• The right to know what personal information we have collected about you, the categories of sources from which we collected your personal information; the business or commercial purpose for which we collected your personal information for, and the categories of third parties with which we disclose your personal information;
• The right to delete your personal information;
• The right to correct inaccurate personal information about you;
• The right to opt out of the sale or sharing of your personal information;
• The right to limit the processing of your sensitive personal information;
• The right to be free from unlawful discrimination for exercising your rights under applicable laws.

We will facilitate your exercise of the rights that apply to you in accordance with applicable law and, considering the type and sensitivity of the personal information subject to the request, for your protection, we may need to request verify your identity and request additional information from you.

To exercise any of your rights, California privacy rights requests may be submitted here, by emailing [email protected] or calling us at 1-833-496-1947.

We do not retaliate or discriminate against Candidates for exercising their rights under the CCPA.