PARAMOUNT RECRUITMENT PRIVACY NOTICE

Paramount is a leading global media and entertainment company that collects information about individuals applying for employment or to provide services to us, either directly or through our recruitment, casting and production service providers and partners. While this notice is global in nature, our goal is to meet the requirements in each country where applicants are located and where this notice conflicts with local requirements, those laws will take precedence.

If you accept an offer from us, we will process further information from you in your capacity as a member of our workforce. and will provide you with a full workplace privacy notice as part of the onboarding process.

Nothing in this notice is intended to create an employment relationship between Paramount and any non-employee and does not create contractual rights or obligations. 

Click on each header below for more information or scroll down to read the full notice.

What Personal Information We Collect About You & Why We Use It

Where the Personal Information Comes From

Retaining Your Personal Information

Who We Share Your Personal Information With & Why

Protecting Your Information

Changes to this Notice

Contact Us

Who is the Data Controller of Your Personal Data

Legal Grounds for Processing Personal Data

Processing Special Personal Data

Further Information on the Personal Data we Process and Our Purposes

Sharing Your Personal Data Outside the Group Companies

Access to Your Personal Data and Other Rights

International Transfers

GENERAL INFORMATION FOR APPLICANTS

What Personal Information We Collect About You & Why We Use It

Paramount collects a variety of information about you, which we use to support the recruiting and application process. This information can identify you or be linked to you. Below, we list categories of the personal information we may collect and the purposes for which we may use it.

• Contact Information, such as your full name, email address, mailing address, phone number, emergency contact information, and next of kin.

• Demographic Information and/or Protected Classifications, such as your age, gender, racial and ethnic or national origin, disability, veteran status. These may be protected characteristics under applicable law and are used as part of our diversity initiatives and in accordance with applicable law.

• Professional and Employment-Related Information, such as work history, educational background, language skills, and any other information you submit to us, and our assessment of it.

• Identity Verification Information such as your date of birth, age, and social security information or other government-issued identification number.

• Visa Status related to whether you currently or will need us to sponsor you for an employment visa.

• Audio and Video Recordings, such as CCTV images upon attendance for an interview or pursuant to virtual live and/or pre-recorded interviews. If you are seeking a role on a scripted or unscripted program, we may also obtain audio or video recordings from, for example, audition videos.

• Internet Activity Information, such as interactions with Company Internet website.

• Information from Background Checks, as consistent with applicable law.

• Information on Your Proposed Salary, Expected Bonus, and Other Compensation (as applicable), and other terms of your proposed employment or other contractual relationship.

• Information Concerning your Health or Disability, as necessary and consistent with applicable law.

• Any Other Information You Provide Us, including information relevant or potentially relevant to a dispute or legal proceeding affecting us.

We may use your personal information for a variety of legitimate business purposes in connection with the recruitment process, such as:

• To assess your qualifications, suitability, and eligibility for a position as an employee or contractor, and terms of any offer.

• To enter into a contract or employment relationship with you (if you are made an offer) and to make working arrangements such as place of work and hours.

• To contact you or others on your behalf (such as using your emergency contact information in the event of an emergency).

• To contact references or other individuals who may provide information to us about your employment history or fitness for employment or contract work with us.

• For financial planning and budgeting.

• For physical and system security (such as with your CCTV images from attendance at an interview).

• To provide information about your offer, contract, or terms of employment to third parties in connection with transactions, such as a prospective purchaser, seller, or outsourcer.

• To conduct diversity and equal opportunity initiatives.

• To protect the rights and property of the Company, comply with our legal obligations, and defend or pursue any legal proceedings affecting us.

• To provide a safe and healthy workplace.

• To make staffing decisions.

• To evaluate and improve the recruitment process.

• To ensure security and integrity.

• To plan travel arrangements and manage expense reimbursement during the application and interview process.

We may use each of the categories of personal information we collect for any of the uses described above, as warranted.

Where the Personal Information Comes From

We collect your information directly from you or your representatives, third parties authorized by you when you apply to work with us (such as job references, professional organizations, or staffing and recruiting agencies), public internet sources (sch as public social media profiles), public records, and our service providers (such as background check companies).

Retaining Your Personal Information

We retain your information for the time period necessary to achieve the purposes described in this notice, unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies. In general, if you become employed by us, we will keep your information for the duration of your employment and for a period afterwards.

Who We Share Your Personal Information With & Why

We may share your personal information within the Paramount family of companies. We may share your information with the Paramount family of companies and Paramount personnel for the purposes described in this notice. This includes to relevant managers, HR, and other administrators for the purposes of reviewing your application and as mentioned herein. We will also disclose this to other members of our group companies where necessary for decision making regarding your application – this will depend on the type of role you are applying for.

We may share your personal information in connection with a corporate transaction. We may disclose or transfer your personal information as part of, or during negotiations for, any purchase, sale, lease, merger, or any other type of acquisition, disposal, or financing involving our brands. Any sharing of your personal information in connection with a corporate transaction will always be subject to a customary confidentiality agreement between the parties.

We may share your personal information with service providers and contractors who perform services on our behalf or that are necessary for our business purposes. We may share your information with service providers and contractors that provide us with professional advice, business support, perform services on our behalf or in connection with carrying out our business. Examples of these service providers and contractors include payroll and benefit service providers, insurers vendors, and information technology providers (this would normally occur if you accept an offer from us and would be carried out as part of the on-boarding process); recruitment consultants (and/or recruitment portals that we may use from time to time), professional advisors such as lawyers and accountants; and background check providers as part of the recruitment process and other similar businesses that we interact with as part of the recruitment process.

We may share your personal information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share personal information with legal and tax advisors, insurers, law enforcement, judicial and other government bodies, and others as necessary to comply with applicable law or legal process, to respond to legal claims, or to protect our rights or the property or personal safety of our applicants, employees, or the public.

We may share your personal information for reasons not described in this notice. We will tell you before we do this if reasonably practicable.

Protecting Your Information

We use reasonable security measures. We have adopted commercially reasonable technical, administrative, and physical security procedures to help protect your personal information from loss, misuse, unauthorized access, and alteration.

Changes to this Notice

From time to time, we may change this notice to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will let you know if these changes are material and, where required by applicable law, we will obtain your consent.

Contact Us

If you have any questions about this notice, you may contact us by completing the form in our Privacy Rights Center and selecting ‘General Privacy Request’.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a resident of California, the following additional information applies to you.

The following are categories of personal data that we may collect about you (and may have collected during the 12-month period prior to the Last Modified date of this notice), as well as examples of the types of personal information that may be collected (or may have been collected):

We collect personal information from the following sources:

• Directly from you (e.g., in your application, assessments, surveys, or during the course of your relationship with us)

• Service Providers, (e.g., recruiters)

• Third Parties (e.g., job references, business partners, professional organizations, staffing agencies, insurance companies)

• Public Internet Sources

• Public Records

• Automated Technologies

• Surveillance Technologies, e.g., video surveillance in common areas, in accordance with applicable law

• Labor processes

• Union

• Government or administrative agencies

• Acquired company

We may use your personal information for the purposes described in “What Personal Information We Collect About You & Why We Use It” section of this notice.

Personal Information Disclosed for a Business Purpose to Third Parties

The categories of personal information listed above may be disclosed for a business purpose to the categories of third parties listed above in the section titled “Who We Share Your Personal Information With & Why”.

Retention

We retain your personal information as described in “Retaining Your Personal Information” section of this notice.

Your Privacy Rights And How To Exercise Them

If you are a resident of California, you have certain rights regarding your personal information, which include: 

• Right to Know. You have the right to submit a verifiable request for specific pieces of personal information obtained from you. In addition, you have a right to know the categories of personal information collected about you, including the categories of sources from which personal information was collected, the business purpose for collecting the personal information, and the categories of third parties to whom the personal information is disclosed.

• Right to Delete. You have the right to submit a verifiable request that we delete personal information collected from you.

• Right to Correct. You have the right to submit a verifiable request to correct inaccurate personal information maintained by us.

Sensitive Personal Information. We do not collect or process sensitive personal information for purposes of inferring characteristics about individuals.

Sale and Sharing of Personal Data. We do not sell your personal data nor disclose your personal data for cross-context behavioral advertising.

Deidentified Information. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

You or your authorized agent may submit a request to exercise any of the above rights by visiting the Privacy Rights Center and completing the form relevant to your request or calling us at +1(888)300-2638. We may require additional information or send you an email to verify your identity or to confirm that your authorized agent has the authority to make the request on your behalf.  The verification process depends on the nature and type of request that is submitted. If we cannot verify your identity or your authorized agent’s authority to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot complete your request.

We will not unlawfully discriminate or retaliate against you for exercising your rights.

ADDITIONAL INFORMATION FOR APPLICANTS LOCATED OUTSIDE OF THE UNITED STATES

If you are located outside the US, including in the European Economic Area (EEA), United Kingdom (the UK), and Switzerland, the following additional information applies to you, except as otherwise noted in the INTERNATIONAL SUPPLEMENTS.

Who is the Data Controller of Your Personal Data

The entity set out in the International Supplement for your jurisdiction will be a data controller of your personal data (as defined under applicable law). In many cases our US and UK entities (including Paramount Inc.) will also be data controllers of your personal data, as well as other Paramount entities with whom your personal data is shared from time to time, and as set out in this Notice.

Legal Grounds for Processing Personal Data

Under applicable data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. The grounds for processing are as follows:

• Contract: this is processing necessary for performance of a contract with you or to take steps at your request to enter a contract. This covers carrying out our contractual duties and exercising our contractual rights.

• Legal Obligation: this is processing necessary to comply with our legal obligations. The processing is necessary for ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work, complying with health and safety laws, or avoiding unlawful discrimination.

• Legitimate Interest: this is processing necessary for our or a third party’s legitimate interests. We or a third party have legitimate interests in carrying on, managing, and administering our respective businesses effectively and properly and in connection with those interests processing your data. Where we rely on legitimate interests, we consider:

  1. what our legitimate interest is – these are set out in the table below;

  2. whether the processing is necessary to achieve it (i.e. whether it is proportionate); and

  3. whether it can be balanced against individuals’ interests, rights, and freedoms (via the protections described in this Notice).

Where this test is not met, we do not rely on legitimate interest. This Notice serves as a record of our legitimate interest assessment.

• Consent: this is where you have given specific consent to processing your personal data. In the UK and EU, processing of your data in connection with employment is generally not conditional on your consent. But there may be occasions where we do specific things for which we require your consent. In certain jurisdictions we will ask for consent as the basis for processing certain of your personal data.

Additional legal bases may apply in your jurisdiction.

Processing Special Personal Data

Where necessary in your jurisdiction, if we process special personal data about you (for example, processing personal data relating to diversity monitoring) we will also make sure that one or more of the grounds for processing special personal data applies. Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by certain privacy law, including EU privacy law, to be “special” or “sensitive” personal data. Data relating to criminal records or offences is treated in a similar way and, for purposes of this Notice, included in this definition. In some jurisdictions a different term may be used to describe data warranting special protection. However, the remainder of this Notice uses the term “special” personal data for ease.

In outline, these additional grounds for processing include:

• Processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law or collective agreement;

• Processing relating to personal data about you that you have made public;

• Processing being necessary for the purpose of establishing, making, or defending legal claims;

• Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity; and

• Processing based on us having received your explicit consent (although please note as set out above that, in general, processing of your personal data in connection with employment is not conditional on your consent in the EU or UK).

Further Information on the Personal Data we Process and Our Purposes

Examples of the personal data and the grounds on which we process your personal data are described in the table below. Although these examples represent a comprehensive description of the processing we engage, this list is not exhaustive.

Please note that if you accept an offer from us, the business will process further information as part of the employment relationship. We will provide you with our a fully workplace privacy notice as part of the on-boarding process.

Sharing Your Personal Data Outside the Group Companies

We will only disclose your personal data outside our group companies if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.

We will disclose your personal data if it is necessary for our legitimate interests as an organization or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). We may also disclose your personal data if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.

Access to Your Personal Data and Other Rights

We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us. Subject to applicable laws in your jurisdiction, you may have certain rights on your personal data, which may include:

• The right to request access to and/or a copy of the personal data we hold about you, including details as to how we process this personal data;

• The right to object to or restrict our processing of your personal data;

• The right to request that your personal data be erased from further use;

• The right to correct, amend, or update personal data you have given us (in some instances, such as on our internal employee portals, you can also do this by logging in and updating your personal data);

• The right of portability, which allows you to request that we share your personal data with others;

• The right not to be subject to automated decision making i.e. a decision made solely by automated processing; and

• If we have relied on consent as a ground for processing, the right to withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

To make a request, visit the Privacy Rights Center and complete the form relevant to your request t. The regulator in your jurisdiction may have produced forms to assist you in making a request – where this is the case you can attach these to your request. Before responding to your request, we may require additional information or send you an email to confirm your identity. Please note that, while we will carefully assess every request we receive, your rights may differ according to your place of residence and we may not always be required to comply. If we do not comply with your request, we will explain why.

If you have any unresolved privacy concerns that we have not addressed satisfactorily after contacting us, you may have the right to contact your local data protection authority.

International Transfers

In connection with our business and for employment, administrative, management and legal purposes, we will where necessary transfer your personal data across country borders in accordance with applicable law. Such transfers include to members of our group of companies and third-party service providers, including in the US and in other jurisdictions in which we are established. For example, some of the systems that we use in connection with our business and your application (such as our recruiting platform) are hosted in the US. We will ensure that any transfer is lawful, including putting in place legal safeguards and ensuring that there are appropriate security arrangements. More specifically, (i) for transfers outside the EEA / UK, this includes entering into the relevant official European or UK Standard Contractual Clauses for transfers to third countries with Paramount group entities and third parties located outside the EEA / UK and, where necessary, implementing further measures to ensure the personal information is subject to equivalent local protection; (ii) for transfers outside of Argentina, we will enter into the applicable official Argentina Model Clauses with Paramount group entities, and third parties located outside Argentina when necessary; and (iii) for transfers outside of certain other jurisdictions, where required by applicable law, we apply the substantive requirements of the official European or UK Standard Contractual Clauses.

If you want further details of any of these safeguards or agreements, please contact us as set forth in the “Contact Us” section.

INTERNATIONAL SUPPLEMENTS

Argentina

Australia

Belgium

Brazil

Canada

China

Czech Republic

Denmark

Finland

France

Germany

Hungary

Ireland

Italy

Mexico

Netherlands

Poland

Portugal

Russia

Singapore

South Africa

Spain

Sweden

Switzerland

United Kingdom

ARGENTINA

If you provide personal data as part of a recruitment process in Argentina, the following additional information applies.

The local regulator is the Public Information Access Agency (A.A.I.P.)

In addition:

In accordance with Act No. 25,326 (Personal Data law) and Act No. 20,744 (Labor Contract law) we can transfer your personal data without your consent in these specified cases:

• When the transfer is foreseen or authorized by law.

• When the transfer is necessary for the prevention or medical diagnosis, the provision of health care, medical treatment, or the management of health services.

• When the transfer is necessary or legally required for a reason of public interest.

• When the transfer is necessary for the exercise or defense of a right in a legal process.

AUSTRALIA

If you provide personal data as part of a recruitment process in Australia or if your personal data is collected by any of the local Data Controllers listed below, the following additional information applies.

The local regulator is the Office of the Australian Information Commissioner (OAIC).

Workplace surveillance

• Surveillance devices will not be used in the following locations in changing rooms, toilet facilities, shower, or other bathing facilities

• Where camera surveillance takes place, the camera will be clearly visible in the place where surveillance is taking place and signs notifying people of the surveillance will be clearly visible at the entrance to the workplace;

• Where computer surveillance takes place, it will be carried out in accordance with local laws and Paramount policy;

• Where tracking surveillance is used in relation to a vehicle (or other thing), there will be a notice visible on the vehicle (or other thing) indicating that it is the subject of tracking;

• Covert surveillance in the workplace will not occur unless authorized by a Magistrate (i.e. for determining whether a worker is engaged in an unlawful activity in the workplace).

Special personal data

Not all of the grounds for processing special personal data described in the section of this Notice entitled “PROCESSING SPECIAL PERSONAL DATA” apply to your special personal data. As such, we will only process your special personal data as permitted by law, for example where we have received your consent to do so or the collection is required by law.

Complaints

If we receive a complaint from you in relation to our processing of your data, we will investigate the complaint and determine whether a breach of this Notice or the Privacy Act has occurred and what action, if any, to take. Paramount will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is one month unless your query is complex. Paramount expects our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the OAIC:

www.oaic.gov.au

Complaints to the OAIC must be made in writing.

BELGIUM

If you provide personal data as part of a recruitment process in Belgium, the following additional information applies.

The local regulator is the Data Protection Authority (in Dutch: ‘Gegevensbeschermingsautoriteit’ / in French: ‘l'Autorité de protection des données’).

In addition:

• If we would like to process (reproduce/disclose) your picture, we will ask for your active and explicit consent (by means of a paper consent form or by ticking a box electronically). This does not apply to pictures you have voluntarily provided (such as in your CV, or via chat or video conferencing tools) or if we have another legal basis to process it (e.g. pictures on access badges, the relevant legal basis for which is our legitimate interest in ensuring the security of our premises).

• If we would like to carry out reference checks with third parties, we will ask for your explicit consent and keep you informed when we request information from external organizations and persons.

• Monitoring of diversity and equal opportunities: as there is currently no exception for Belgian companies from the prohibition on processing special personal data as part of a diversity policy, we will not process any special personal data for this purpose unless otherwise permitted under applicable law or will do so on an anonymous basis only.

• When we use CCTV, we will observe the provisions of national collective bargaining agreement no. 68.

BRAZIL

If you provide personal data as part of a recruitment process in Brazil, the following additional information applies.

The local regulator is the National Data Protection Authority (in Portuguese: Autoridade Nacional de Proteção de Dados – ANPD), as created by the Law No. 13,709/2018 (LGPD).

In addition:

• We may process special personal data if the processing is necessary for the purpose of preventing fraud and ensuring the safety of the data subject with respect to registering for and authenticating access to our electronic systems.

• Any kind of background checks will be carried out only if strictly necessary in connection with the duties assigned.

• Brazilian data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent.

CANADA

If you provide personal data as part of a recruitment process in Canada, the following additional information applies.

The statutory regulator in British Columbia is the Information and Privacy Commissioner.

In addition:

If you send us a request (to the email address provided in this Notice) to access or correct your personal data, we will contact you within 30 days (although it may take us longer to fully respond to your request).

CHINA

If you provide personal data as part of a recruitment process in the People’s Republic of China, the following additional information applies.

The local regulators are the Cyberspace Administration of China (CAC), Industry and Information Technology Department Bureau and Public Security Bureau.

In addition:

• We do not process personal data without your consent. The purpose of the collection of personal data, the scope of the information collected, and the individuals or entities with which the data will be shared and accessed are generally listed in the above Notice. If we collect personal data from a third party, we will do so with your consent.

• As noted above, we may require you to provide emergency contact information and information of your next of kin, and you are responsible for getting necessary consent from these individuals whose personal data is provided to us and agree that, when disclosing the personal data of these individuals, you will be acting on their behalf.

CZECH REPUBLIC

If you provide personal data as part of a recruitment process in the Czech Republic, the following additional information applies.

The local regulator is Úřad pro ochranu osobních údajů.

In addition:

The following examples of the personal data that we process and our grounds for processing them differ from those provided in the Notice above:

• Before you begin your employment, we only process personal data relevant to the application process, i.e. personal data relating to qualifications, work experience, skills, and knowledge.

• The Czech data protection legislation does not allow for the processing of special personal data for equality and diversity purposes.

• Generally, we will not process any information on:

(a) pregnancy;

(b) family and property situation;

(c) sexual orientation;

(d) national/ethnic origin;

(e) trade union organization membership;

(f) membership of political parties or movements;

(g) religion or confession; or

(h) criminal records.

However, with the exception of (c), (d), (e), (f) and (g), we may process the above in rare cases where there is an objective reason for doing so relating to your role (for example if you are pregnant in relation to your parental leave or if you are responsible for large amounts of money, information about your criminal record may be requested). We may also process such personal data in cases where we are legally required to do so.

DENMARK

If you provide personal data as part of a recruitment process in Denmark, the following additional information applies.

The local regulator is the Datatilsynet (the Danish Data Protection Agency).

https://www.datatilsynet.dk/

In addition:

• If we would like to process (reproduce/disclose) your picture for marketing or customer/client relations purposes, we will ask for your consent. This does not apply to pictures you have voluntarily provided (such as in your CV, chat, or video conferring tools) or if we have another legal basis to process it.

• Danish legislation does not include any specific provisions allowing the processing of personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes except for age, gender, and disability, in which case we will ask for your consent, or we will do so on an anonymous basis only.

FINLAND

If you provide personal data as part of a recruitment process in Finland, the following additional information applies.

The local regulator is Tietosuojavaltuutettu (the Data Protection Ombudsman) (https://tietosuoja.fi/en/home)

In addition:

• We only process personal data that is directly necessary for your employment relationship.

• We primarily collect personal data directly from you. If we collect personal data from elsewhere, we will do so only with your consent. In any event, we will notify you of the collection of your personal data from such external sources prior to making any decisions based on that information.

• CCTV surveillance will be used only where the legal requirements for its use are fulfilled, including, but not limited to, any prior cooperative and consultative procedures. The personal data collected will be used only for the purposes for which the CCTV was originally implemented.

FRANCE

If you provide personal data as part of a recruitment process in France, the following additional information applies.

The local regulator is the Commission Nationale de l’Informatique et des Libertés (CNIL).

In addition:

• The French data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

• Under French data protection legislation, you have the right to give instructions on what happens with your personal data after your death.

GERMANY

If you provide personal data as part of a recruitment process in Germany, the following additional information applies.

The local regulator is:

In addition:

In Germany, personal data will be processed where necessary under Section 26 of the Federal Data Protection Act ("Bundesdatenschutzgesetz") and on the following legal bases:

• For employment-related purposes where necessary for hiring decisions or to exercise or satisfy rights and obligations laid down by law or by collective agreements or other agreements between us and the staff council.

• To detect crimes only if there is a documented reason to believe you have committed a crime while employed, and where the processing of such personal data is necessary to investigate the crime and is not outweighed by your legitimate interest in us not processing the personal data (and in particular where the type and extent of the data processing are not disproportionate to the reason).

• If your personal data is processed on the basis of consent, we shall take into account whether you are able to freely give it. This may include where there is an economic advantage for you, or where we are pursuing the same interests. Consent will normally be requested in written or electronic form unless a different form is appropriate because of special circumstances. Where we rely on consent, we ensure you are fully informed and you will have the right to withdraw consent.

• Special personal data:

  • If it is necessary to exercise rights or comply with legal obligations derived from labor law, social security and social protection law, and there is no reason to believe that the you have an overriding legitimate interest in us not processing the personal data. Where we process such personal data based on your consent, we will request the consent specifically. We may also process special personal data on the basis of collective agreements.

  • The German data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

HUNGARY

If you provide personal data as part of a recruitment process in Hungary, the following additional information applies.

The local regulator is the National Data Protection and Freedom of Information Authority (http://www.naih.hu/).

In addition:

The following examples of the data that we process and grounds for processing differ than as provided in this Notice:

• Hungarian data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

• Data regarding disability may be processed based on Act CXCI of 2011 to determine the percentage of disabled employees, calculate the amount of the rehabilitation contribution payable by Paramount, and to determine if Paramount is entitled to further allowances.

IRELAND

If you provide personal data as part of a recruitment process in Ireland, the following additional information applies.

The local regulator is the Data Protection Commission (www.dataprotection.ie).

In addition:

• Irish data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only

• Generally, we do not carry out criminal record checks in Ireland unless this is particularly necessary given your role – e.g. you are going to be working with children or vulnerable adults. We may also require you to complete a self-declaration questionnaire where relevant to a particular role.

• Generally, we do not carry out credit background checks in Ireland, but we may carry out judgment and bankruptcy searches against current or prospective employees where necessary and proportionate, as such databases are accessible by the general public.

ITALY

If you provide personal data as part of a recruitment process in Italy, the following additional information applies.

The local regulator is Autorità Garante della Privacy.

In addition:

Italian data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we will generally only process personal data, including special personal data, for these purposes where we have a legal obligation – e.g. in relation to gender and disability reporting – we have your consent; or we do so on an anonymous basis.

MEXICO

If you provide personal data as part of a recruitment process in Mexico, the following additional information applies.

The statutory regulator is the National Institute for Transparency, Access to Information and Personal Data Protection (‘INAI’)

In addition:

In terms of the Federal Law on the Protection of Personal Data in the Possession of Private Parties and its Regulations, note that in the event we refuse to respond to a request regarding your personal data rights, or in the case that you disagree with our response, you may file before the National Institute of Transparency, Access to Information and Personal Data Protection the corresponding Application for the Protection of Rights within the deadlines and terms established by chapter VII and other related chapters, as well as the ones relevant from the Regulations to the Law.

NETHERLANDS

If you provide personal data as part of a recruitment process in the Netherlands, the following additional information applies.

The local regulator is Autoriteit Persoonsgegevens. Mailbox 93374, 2509 AJ THE HAGUE. Phone: (+31) – (9)70 88 85 00.

In addition:

• Data regarding nationality, race and ethnic origin may be processed for diversity monitoring / equal opportunities purposes where necessary in order to reduce factual disadvantages related to race or ethnic background. However, we will stop such processing if you ask us to.

• Data regarding disability may be processed for diversity monitoring / equal opportunities purposes in order to meet our legal obligations.

• With regard to other special personal data categories, we will not process this personal data for the purposes of diversity monitoring / equal opportunities purposes or will do so on an anonymous basis only.

POLAND

If you provide personal data as part of a recruitment process in Poland, the following additional information applies.

The local regulator is the Prezes Urzędu Ochrony Danych Osobowych (The President of the Personal Data Protection Office), Stawki 2, 00-193 Warsaw, Poland.

In addition:

• If hired, your personal data will be processed and kept for the period of performance of your employment contract, and after the expiration of the contract for the period necessary for us to perform our legal obligations deriving from legally binding provisions. If your personal data is only useful for a short period (for example a record of a holiday request), we will delete it when it is no longer useful (during your employment), in accordance with our retention policies.

• The following provisions of local law determine the retention periods for your personal data:

  • regarding employee documentation (dokumentacja osobowa i płacowa) – Polish Labor Code (Kodeks pracy) and the relevant regulations pertaining to employee documentation issued under the Labour Code; and

  • regarding the personal data processed by means of the CCTV – Polish Labor Code.

• Polish data protection legislation does not include any specific provisions on processing personal data for equality and diversity purposes. Therefore, we do not process special personal data for these purposes without your consent or will do so on an anonymous basis only.

PORTUGAL

If you provide personal data as part of a recruitment process in Portugal, the following additional information applies.

The local regulator is Comissão Nacional de Protecção de Dados (CNPD).

In addition:

• We will not collect or process any CCTV images in the interior of spaces reserved to employees, such as dining areas, locker rooms, etc. In any case and when admissible, video surveillance with sound recording will normally only occur upon prior authorization from the local regulator.

• Any personal data recorded by remote surveillance will generally only be used in the context of criminal proceedings. In that situation, such personal data may also be used to establish disciplinary responsibility.

• We do not process special personal data for equality and diversity purposes without your consent or will do so on an anonymous basis only.

• Background checks will be carried out only if strictly necessary in connection with the duties assigned and to the extent that this would be allowed under the applicable law.

RUSSIA

If you provide personal data as part of a recruitment process in Russia, the following additional information applies.

The local regulator is the Russian Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor).

Legal grounds for processing personal data

In most scenarios described in the “FURTHER INFORMATION ON THE PERSONAL DATA WE PROCESS AND OUR PURPOSES” section of this Notice we will request your explicit consent to the processing of your personal data for the respective purposes. Moreover, where we are required to do so by Russian law, we will request your consent. Grounds for the data processing described in said section of this Notice apply together with your consent and will further apply in case you revoke your consent.

Further information on the data we process and our purposes

Subject to certain statutory exceptions, we will not process personal data relating to your criminal convictions. In general, we will process your special personal data and biometric data only to an extent we need to do so as per Russian law and subject to your consent.

Who gets to see your data?

We will keep records of the third parties who may access your personal data or otherwise may be involved in its processing. If you want to learn more about such third parties, please contact us at EmployeePrivacy@Paramount.com

Retaining your personal data

As per Russian tax, accounting, and archive laws we are required to retain certain documents containing your personal data. For example, we may need to retain your personnel files and employment contracts for up to 50 years. We put in place all appropriate safeguards to ensure that such documents are retained in a secure manner and destroyed upon expiration of the prescribed statutory terms.

International transfers

Although we may transfer your personal data outside Russia, we will in any case make sure that we comply with applicable local requirements on the initial processing of your personal data in Russia (e.g. data localization requirements).

How we process your personal data

In most cases, we process your personal data with the use of automated means, however in some cases we also need to do so without such means (manually).

We may process your personal data by way of any operations to the extent required to fulfil the processing purposes declared. In particular, such operations may include collection, recording, systematization, accumulation, storage, specification (update, modification), retrieval, use, transfer (provision, access, dissemination), depersonalization, blockage, deletion, or destruction of personal data.

SINGAPORE

If you provide personal data as part of a recruitment process in Singapore, the following additional information applies.

The local regulator is the Personal Data Protection Commission (“the PDPC”).

The Personal Data Protection Act 2012 establishes a general data protection law in Singapore which governs the collection, use and disclosure of individuals’ personal data by organizations. “Organizations” include any company formed or recognized in Singapore or having an office or a place of business in Singapore.

SOUTH AFRICA

If you provide personal data as part of a recruitment process in South Africa, the following additional information applies.

The local regulator is the Information Regulator.

Your rights under the laws of South Africa

If you are a resident of South Africa, you have certain additional rights under South African law:

• The right to be notified that your personal data is being collected;

• The right to be notified that your personal data has been accessed or acquired by an unauthorized person;

• The right not to have your personal data processed for purposes of direct marketing by means of unsolicited electronic communications;

• The right not to be subject to a decision based solely on the automated processing of your personal data intended to provide a profile of you;

• The right to submit a complaint to the Information Regulator regarding the alleged interference with the protection of your personal data; and

• The right to institute civil proceedings regarding the alleged interference with the protection of your personal data.

In addition:

When processing personal data and special personal data for diversity and inclusion purposes, we will typically rely on the legal obligations imposed on us under the Employment Equity Act 55 of 1998 in respect of employment equity planning. Where, however, certain personal data is not legally required (for example sexual orientation or LGBTQ status), this personal data will be processed on the basis of specific and explicit consent.

SPAIN

If you provide personal data as part of a recruitment process in Spain, the following additional information applies.

The local regulator is the Spanish Data Protection Authority (www.aepd.es).

In addition:

We will generally not process health data and will only receive limited information – i.e. whether an employee is fit for the job from a health perspective. Notwithstanding this, as stated in the Notice, personal data may be collected as necessary to maintain the safety and health of employees in relation to COVID 19 or other pandemics, in accordance with the Return to Workplace Privacy Notice, which may apply to you in the event you enter our worksites.

SWEDEN

If you provide personal data as part of a recruitment process in Sweden, the following additional information applies.

The local regulator is Integritetsskyddsmyndigheten.

In addition:

We will not process special personal data for diversity and equal opportunities purposes or will do so on an anonymous basis only.

SWITZERLAND

If you provide personal data as part of a recruitment process in Switzerland, the following additional information applies.

The local regulator is the Federal Data Protection and Information Commissioner.

In addition:

• When collecting special personal data, criminal data, or personality profiles, we will inform you in advance of the data collection purpose and of any data recipient and will ask you for your consent.

• We will only gather references from former employers with your prior consent.

UNITED KINGDOM

If you provide personal data as part of a recruitment process in the United Kingdom, the following additional information applies.

The local regulator is the Information Commissioner’s Office (ICO).

In addition:

When processing special personal data for diversity and inclusion purposes we will typically rely on Schedule 1(8) Data Protection Act 2018 as the legal basis for processing, rather than consent. However, in practice this sort of processing would normally still be voluntary.

This Notice, along with other related Paramount policies and/or protocols, shall form Paramount’ policy for processing special personal data as required by the UK Data Protection Act 2018 (Schedule 1 Part IV).