Privacy Notice for Job Applicants


Aristocrat Leisure Limited and its affiliates worldwide (“Aristocrat”, the “Company”, “we” or “us”) are committed to protecting the privacy and security of your Personal Data.

This Privacy Notice for Job Applicants (“Privacy Notice”) describes how we Process Personal Data about you in the context of our application and recruitment process.

In some jurisdictions, such as the European Economic Area (“EEA”), United Kingdom (“UK”) and Brazil, Applicable Data Protection Laws include the concept of a “controller.” Where that concept is recognized, the Aristocrat entity to which you are applying or which is considering hiring you is the controller of your Personal Data.

If you have any queries or issues about how we Process your Personal Data, we invite you to contact privacy@aristocrat.com.


1. What type of Personal Data do we Process about you? How do we collect your Personal Data?

We process the Personal Data, including sensitive Personal Data, that you and others provide to us during the recruitment and application process, such as if you submit an application to us directly or through a third party (e.g., a head hunter). Depending on where you live, this information may include:

a. Contact information, such as your name, address, email address, telephone numbers and other contact information.

b. Information and documents that support your job application, including resumes or curriculum vitae, employment and education history, professional licenses, references, and information about your work preferences and abilities.

c. Information about our interactions with you, including responses to screening questions, results of assessments, information obtained through interviews, from references or from background checks (where applicable), and recordings of you, such as voicemail and closed-circuit television footage.

d. Information we collect in connection with other standard business processes, such as reimbursing authorized travel expenses and any applicable security and health screenings if you visit our work spaces. We also may collect your social security number/social insurance and birthdate and, where applicable, background check information. For some jobs, we may also conduct drug tests, as permitted by law.

e. Sensitive or demographic information obtained during the application or recruitment process, such as gender, information about your citizenship and/or nationality, medical or health information, and racial or ethnic origin. We also may collect demographic information about racial and ethnic origin, disability, sexual orientation, religion, and gender, if you otherwise provide the information, such as through surveys on diversity and inclusion topics.

f. Information that you make available on professional social media networks, such as LinkedIn, job boards, and from other publicly accessible sources.

g. Device and usage information that we collect automatically when you click on a job posting or otherwise interact with us electronically in the context of our job application or recruitment activities, such as your referral source (i.e., the website where you saw the job advert); details of the pages you have viewed, including how long you spend on a page and which links you select; information about your computer, such as the web browser used and device type; and your IP address. We also may capture your approximate Geolocation Data.

h. Other information that you provide us, such as through surveys and forms and our communications, or that we collect in connection with our recruitment and hiring activities.

We may collect additional information if you become an employee pursuant to our internal policies and notices.

2. 
How do we use your Personal Data?

We will only use your Personal Data as permitted by Applicable Data Protection Law. In those countries where we need a legal basis to Process your Personal Data (such as in the EEA, UK and Brazil), we will typically use your Personal Data for any of the following legal bases:

a. Where we have your Consent to do so.

b. Where we need to take steps prior to entering into a contract of employment with you.

c. Where we need to comply with a legal obligation.

d. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. See below for further details.

Below we list some of the purposes for which we Process your Personal Data.  We reserve the right to add a new purpose to the list of purposes below at any time, although we will comply with any relevant legal requirements to notify you of changes.
Flexbox Layout
Lawful Basis
Processing Activities
Where we need to take steps prior to potentially entering into a contract with you
We will Process your Personal Data as reasonably necessary prior to our potentially entering into a contract of employment with you, such as to:
  • assess your suitability for a job at Aristocrat (including Processing your application, assessing your fit with us or for a specific role, conducting interviews, carrying out background and reference checks in accordance with law, and keeping records related to our hiring process);
  • comply with our legal obligations, including those related to tax and employment laws;
  • communicate with you during and about the recruitment process; and
  • conduct your on-boarding process if your application is successful. This includes using your Personal Data for preparation of an employment contract, and other administrative purposes necessary for you to commence employment with Aristocrat.
Where it is necessary for our legitimate interests
We may Process your Personal Data to:
  • match you with other job vacancies in Aristocrat;
  • contact you in case of an alternative career opportunity within Aristocrat;
  • ask you about your experience with the recruitment process and to otherwise support and enhance our recruitment and retention processes, including to support efforts to promote diversity and inclusion in accordance with applicable law; where required by Applicable Data Protection Law, we will obtain your Consent to collect the diversity and inclusion information;
  • aggregate your Personal Data and create statistics, including to help us understand the type of applications we receive; and
  • establish, exercise or defend legal claims.

We may conduct the checks described in this policy on any prospective or current employee in order to prevent or detect unlawful acts, given the confidential and sensitive nature of the information that all employees will have access to and handle throughout their employment with Aristocrat. In such cases, we will ask you to authorize our third-party screening provider to obtain the criminal record disclosure as part of our background screening checks. We will exclude records from our review in accordance with local laws.


We will use Personal Data obtained through our external background screening providers (which may include address history, employment history, education background, criminals records information, credit history and employment history) to verify (1) the information provided by you on your CV; (2) the relevant qualifications/requirements for the role; (3) your employee declaration and as necessary for compliance and as required by regulatory bodies; and to verify that there are no issues with your credit history that could place unnecessary risks on Aristocrat or third parties.


We normally request references from your current employer and a previous employer, and we also conduct the same checks on gaps in your employment history.

Where we obtain your Consent
Where required by Applicable Data Protection Law, we may request your Consent for certain Processing activities.
Where we need to comply with a legal obligation

We Process your Personal Data to check whether you are legally entitled to work in the jurisdiction where you are applying for work.


Further, we may collect information about your health as permitted by Applicable Data Protection Laws, such as information on certain health conditions, symptoms information, testing information, and other information that is needed for screening purposes and in order to make reasonable adjustments to the recruitment process for you as required by law.

3. With whom might we share your Personal Data?

For the purposes listed above, we may share your data with third parties, including third-party service providers and any sub-contractors of those service providers. For example, we may use third parties to host and manage applications, to store Personal Data in a talent database, and to advertise our job openings.


In the context (and for the purposes) of the application process, we will contact and discuss your previous experience and performance with any persons you indicated as references. This may involve sharing some of your Personal Data with these persons.

We may also disclose or otherwise Process your Personal Data in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by Applicable Data Protection Law, court order, or otherwise as required for the purposes of any regulatory audit to which we may be subject from time to time. For instance, we may be required to share your Personal Data with government entities, law enforcement authorities and other public entities.  Finally, we may share personal information for other purposes disclosed to you at the time we collect your information or pursuant to your Consent.

If your application is successful, we will Process your Personal Data in accordance with our internal policies and notices, which we will provide to you during on-boarding.


If we need to transfer your Personal Data to another country we will use a lawful basis to do so where required by Applicable Data Protection Law. For example, we may transfer your personal data to our head office in Australia, to our U.S. base in Nevada for review, or to India where our P&C management system Workday is administered.

Where Applicable Data Protection Law provides for the use of EU-approved Standard Contractual Clauses or other transfer agreements to transfer data abroad, we generally rely on such clauses for our transfers unless other transfer grounds are more appropriate. You can ask for a copy or information about these clauses by contacting
privacy@aristocrat.com.


4. 
How long will we retain your Personal Data?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for. However, we may retain your Personal Data for longer if we need to, for example, to comply with a legal obligation, for the length of any applicable statutory limitation period for a potential complaint or legal claim, or for the establishment, exercise or defense of legal claims. Please contact us at privacy@aristocrat.com for more information on how long we retain your Personal Data.

If your application is successful and you are offered an employment with us, your Personal Data will be transferred to an employee personnel file and will be Processed and retained in accordance with our internal policies and notices.

5. 
What are your rights and obligations as a data subject?


Depending on where you live and the job opportunity within Aristocrat that your application is being considered for, you may have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This allows you or “Data Subject Rights Request”) to request information about and a copy of the Personal Data we hold about you and to check that we are lawfully Processing it.
  • Request correction of the Personal Data that we hold about you. This allows you to request that incomplete or inaccurate information we hold about you be corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data, but only where there is no valid reason for us continuing to Process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to Processing.
  • Object to Processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which causes you to object to Processing on this ground.
  • Request the restriction of Processing of your Personal Data. This enables you to ask us to suspend the Processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for Processing it.
  • Request the transfer of your Personal Data to another party.
  • Request information about the recipients of your Personal Data.
  • Request information about the criteria and proceedings used to take an automated decision.
  • Lodge a complaint with a supervisory authority, in particular in the jurisdiction of your habitual residence, place of work or place of the alleged infringement of Applicable Data Protection Law.
  • Opt-out of the sharing of Personal Data for targeted advertising. We do not otherwise sell Personal Data that we Process about you, such as for monetary consideration.

The above-mentioned rights are not absolute. Applicable Data Protection Law limits these rights.

We will not unlawfully discriminate or retaliate against you for exercising your rights and choices under relevant laws.

If you want to request to exercise these rights, you or your authorized agent should please contact
privacy@aristocrat.com or, to opt out of the sharing of your personal information for targeted advertising, by clicking the “Do Not Share My Personal Information” link in the footer of applicable web pages.  We will respond in accordance with local laws.  We will also support global opt-out preference signals in accordance with relevant legal requirements.

What we may need from you

Where appropriate, we may need to request specific information from you to help us confirm your identity and verify your right to access the information (or to exercise many of your other rights). This is another appropriate security measure designed to protect individuals.

What are your rights to withdraw Consent to Processing?

Depending on your jurisdiction, you may have the right to withdraw your Consent to allow us to continue Processing your Personal Data, but only where Consent was sought as a lawful means of Processing your Personal Data.

In the limited circumstances where you may have provided your Consent to the Processing of your Personal Data for a specific purpose, you may have the right in accordance with local laws to request to withdraw your Consent for that specific Processing at any time. Your withdrawal will not affect the lawfulness of Processing based on Consent before its withdrawal.  We do not use or disclose sensitive data except for purposes required or permitted by law.

To request to withdraw your Consent, please contact
privacy@aristocrat.com.

 
6. 
Security

We maintain security measures to help safeguard information from loss, theft, and unauthorized Processing. However, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current.  Please note that information collected by third parties may not have the same security protections as information you submit to us. We are not responsible for third party’s security practices or the protection of information collected by third parties.
 
7. What happens if we change this Privacy Notice?

This Privacy Notice was last updated March 2023. We reserve the right to update this Privacy Notice at any time by posting an updated notice or notifying you. Changes to this Privacy Notice will be posted to the relevant locations. Please check back regularly to ensure you are familiar with our current practices. We may notify you in other ways from time to time about the Processing of your Personal Data.