Candidate Privacy

Privacy Notice to Job Candidates
Effective: January 1, 2023
Last Updated: December 21, 2022

Introduction

We care about your privacy and the protection of your personal information. This Privacy Notice to Job Candidates (“CN Privacy Notice”) explains how Comcast Corporation and Comcast Cable and Comcast Cable’s subsidiaries and affiliates (collectively, “Comcast”, “we”, “our” or “us”), collects, uses, and otherwise processes candidate-related personal information (sometimes referred to as “Candidate Information”) during its recruitment and selection process, including when you access or use our careers website. For purposes of this CN Privacy Notice, personal information includes any information that is linked or reasonably linkable to you.

This CN Privacy Notice explains:

1. When This CN Privacy Notice Applies
2. Information We Collect and How We Use It
3. When and With Whom We Share Information
4. How Long We Retain Your Information
5. How We Protect Your Information
6. How to Correct the Information in our Records
7. Additional Information for Individuals Located in the EEA, UK, and Switzerland
8. Additional Information for Individuals Located in the State of California, United States
9. Changes to This CN Privacy Notice
10. How to Contact Us With Questions About This CN Privacy Notice

1. When This CN Privacy Notice Applies

This CN Privacy Notice applies to any personal information Comcast collects once an individual expresses interest in being employed at Comcast. This includes data collected when an individual visits a Comcast-branded website to review job postings (“Site”), as well as information submitted by an individual during the application process. In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. Comcast does not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

This statement does not form part of any contract of employment, nor does it cover the processing of personal information that may occur in the context of employment (if we make and you accept an offer to join our team). We encourage you to read this CN Privacy Notice to Job Candidates carefully and understand its contents. If you have any questions, please direct them to Comcast_HRPrivacy@comcast.com.

2. Information We Collect and How We Use It

We will collect and process personal information about you throughout the recruitment and selection process. We will use your personal information for a variety of reasons linked to the processing and evaluation of your application as set out below. The personal information we collect, and how we use it, may vary depending on the jurisdiction where the position is based and may include, subject to applicable law:

A. Information We Collect From You

• Name and other personal information, such as alias, gender, date of birth, photograph, unique personal identifiers assigned by our systems, internet protocol address, social security number, driver’s license number, passport number, or other similar information.
  • We use this information to open and track your candidate file, communicate with you, or (if an offer has been extended to you) to conduct background, reference or conflict of interest checks.
• Contact information, such as email address, mailing address, telephone number(s),
  • We use this information to open and track your candidate file, and to communicate with you
• National identifiers and work eligibility information, including your national identification number, social security number, government identification number, country, region, and city of birth, nationality, citizenship status, visa status, residency and work permit status, and immigration information
  • We use this information to determine your eligibility to work, to verify your identify and fulfill our obligations to relevant government authorities
• Job qualifications and related information, including your resume/CV, previous jobs, descriptions of your skills and experience, education, awards, qualifications, certificates, licenses, membership in professional bodies or trade groups, references, and any other information you choose to provide in your resumes and/or applications.
  • We use this information to evaluate you for current and future job opportunities, including matching your skills and interest to applicable job requirements, conflict of interest checks, and (if Comcast decides to make an offer) determine compensation rate.
• Travel related information, including (if you travel during the candidate process) frequent flyer numbers, TSA known traveler numbers, itineraries, flight, train, rental car, car service, hotel or other similar information.
  • We use this information to facilitate your business travel, including to arrange or reimburse travel, to contact you during travel, as necessary with travel service providers, or in an emergency situation.
• Financial information, including (if you travel during the candidate process) bank account details.
  • We use financial information to process any expense claims and to comply with legal obligations.
• Surveys, including your feedback and opinions as part of voluntary surveys.
  • We use such information to understand what Comcast is doing well and what it can improve upon within the candidate journey and its operations. Your response to these surveys is optional and will have no bearing on the selection process for any vacancy at Comcast.
• Inferences and Analytical Reports drawn from other personal information, including, analyses from applicant information used for improving our hiring processes, or analyses from tests, interviews, and simulated tasks and job relevant exercises that you may engage in during your interview(s) that may reflect work-related preferences, characteristics, behaviors, attitudes, intelligence, abilities, and aptitudes.
  • We use this information to determine your suitability for certain job roles, for our internal business operations and facilitating our hiring process.
    Other audio, electronic, visual or similar information that you provide to us, including communications, documents or images that you create, provide or upload to our systems or provide to Comcast representatives
  • We use this information for our internal business operations and facilitating our hiring process.

Any other information you provide us in the context of your candidacy in order to administer aspects of your candidacy. Comcast does not generally collect or process “Sensitive Personal Information” during the recruitment and selection process. Sensitive Personal Information may include information about your racial/ethnic origin, gender, military or veteran status, sexual orientation and/or disabilities. To the extent such information is collected or provided, for example, through voluntary self-identification, we use this information (at the time and manner and to the extent permitted or required by law) to address our legal obligations to you, to make any adjustments required to assist you in the application and interview process, and to conduct meaningful equal opportunity and diversity monitoring and analyses, such as diversity and inclusion initiatives.

B. Information We Collect From Other Sources

• References, including opinions and comments of any previous employers. In connection with our evaluation of your application, we may request specific permission to seek information about you from third parties. This may include information regarding your work habits, performance in prior roles, and fitness for employment.
• We use reference information we receive to determine your suitability for certain job roles and to fulfill our obligations to regulators (including demonstrating the suitability of employees for their role to regulators and professional bodies).
• Results of background checks and screening, including education verification, criminal records and driver license checks.
  • We use this information to determine your suitability for employment (at the time and manner, and to the extent permitted or required by law), including for certain job roles (for example, home security) and to determine your eligibility for certain potential benefits (such as use of a company vehicle). We may also collect background data from public third-party sites and may not seek your specific consent where not required by law.
• Information provided by recruiting or executive search agencies
  • We use this information to determine your suitability for employment
• Information collected from publicly available sources, including any social media platforms you use or other information available online
  • We use this information (if collected, and at the time and manner, and to the extent permitted by applicable laws) to determine your suitability for employment.

C. Information We Collect Electronically

• Internet or other electronic network activity information, and audio, electronic, visual or similar information, including information about your use of our Sites and information generated in the course of the use of our Sites (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, weblogs and other communication data, the resources that you access, and how you reached our Sites, details regarding the device you use to access our Sites or digital services, including where available your IP address, operating system and browser type, and information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our services or choosing to log in through a social media account), including your account ID or username and other information included in your posts.
  • We use this information for our internal business operations and facilitating our hiring process. We do not knowingly allow others to collect personal information about your online activities over time and across third-party websites when you visit our Sites. For more information about cookies and other online tracking technologies, please visit our Cookie Notice. To manage your cookie preferences, please visit the Xfinity Privacy Preferences Center. You can also use a browser that offers you the ability to use the Global Privacy Control to communicate your privacy preferences to use when you visit our Sites. Because definitions and rules for a “Do Not Track” standard have not yet been established, including whether such signal must be user-enabled, Comcast does not yet respond to “Do Not Track” signals sent from browsers.
• On-premise monitoring, including video monitoring (e.g., closed-circuit television (“CCTV”) and visitor badge scans for security purposes, subject to local law and internal policy.
  • If you visit one of our premises, we use this information to monitor office entry/exit points, elevator lobbies, and other select areas, including those that contain highly sensitive assets or are associated with a high risk for theft. In some cases, California requires that we use different names to describe the categories of information that we collect. For more information about these categories, please see the “Additional Information about other laws and individual rights” section of this CN Privacy Notice.

D. Additional Uses of Personal Information

• In addition to the uses set forth above, Comcast may use and share personal information:
  • To comply with applicable legal and regulatory requests and obligations (including investigations) or our policies.
  • To establish or defend legal claims and allegations.
  • For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
  • To seek advice from lawyers, auditors and other professional advisers.
  • For purposes incidental to those set forth above.

3. When and With Whom We Share Information

Sometimes we share the personal information we receive from you with other companies, as described below:

The Comcast Family of Businesses
We may share such information about you with other Comcast companies (including NBCUniversal-branded companies and other non-Comcast or non-Xfinity-branded affiliates) that may consider you for open position(s) that fit your profile.

Service Providers
In order to provide and support the recruitment and selection process, we may use third party companies as service providers that work on our behalf to transmit, collect, process, or store information for us. The categories of Service Providers with whom we work include:

• Vendors that assist with the application process, including assessing candidate qualifications and providing the platform through which candidates submit their candidacy
• Auditing and accounting firms
• Professional services consultants, such as firms that perform analytics, assist with improving our programming, provide legal services, or supply project-based resources and assistance
• Analytics services, including entities that analyze traffic to and on our Sites, and assist with identifying and communicating with potential users of our Sites
• Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention
• Information technology providers, such as entities that assist with hosting, maintaining, and storing Candidate Information 

Academic Researchers
We may share candidate information with academic institutions where doing so would further an important research purpose. For example, some institutions are interested in exploring the relationship between certain academic degrees and backgrounds with the type of positions that such candidates seek at Comcast. The researchers may publish academic papers which include aggregated data about Comcast’s candidates for employment.

When Required by Law or To Protect Comcast and Others
There are times when we may be required by law to disclose information about you to third parties. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We may also disclose information that personally identifies you as permitted by law and without your consent when it is necessary to protect customers, employees, property or others; in emergency situations; or to enforce our rights or the rights of any third party under our terms of service and policies.

4. How Long We Retain Your Information

We utilize the following criteria to determine the length of time for which personal information is retained:

• Whether you are successful or unsuccessful with your application for employment
• Whether we are required to retain the information in order to comply with legal obligations or to protect health and safety
• The privacy impact to you of ongoing retention, including your likely expectations in light of the sensitivity of the information we’ve collected
• The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle in light of the volume and complexity of the systems in our infrastructure Individual pieces of personal information such as those listed above may exist in different systems that are used for different
  business or legal purposes. A different maximum retention period may apply to each use case of the information. Certain individual pieces of information may also be stored in combination with other individual pieces of information, and the maximum retention period may be determined by the purpose for which that information set is used.

5. How We Protect Your Information

We follow industry-standard practices to secure the information we collect to prevent the unauthorized access, use, or disclosure of any personal information we collect and maintain. These security practices include technical, administrative, and physical safeguards, which may vary, depending on the type and sensitivity of the information. Although we take the responsibility of safeguarding your personal information seriously, no security measures are 100% effective and we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your information.

6. How to Correct the Information in our Records

You are encouraged to ensure that the Candidate Information you provide to Comcast is kept up to date and to amend any information which is inaccurate or out of date (e.g., address). If you would like to correct any information that you have provided, please notify your Comcast recruitment contact. Comcast will endeavor to resolve any issues concerning your Candidate Information in accordance with relevant procedures.

7. Additional Information for Individuals Located in the EEA, UK, and Switzerland

The EU General Data Protection Regulation and the UK General Data Protection Regulation provides residents of the EEA, United Kingdom, and Switzerland the rights to receive notice regarding the purposes for which your personal data are processed and the legal basis for our processing, the categories of recipients of your personal information, whether the personal information will be transferred outside of the EEA, UK, and/or Switzerland, and the criteria we use to determine how long to retain your data. You also have the right to receive notice about your rights. These rights apply to all residents of these locations.
The GDPR defines “Personal Data” to mean “any information that is linked or reasonably linkable to an identified or identifiable natural person.” When we use the term “personal information” in our privacy notice, it includes Personal Data covered by this definition.
The Comcast entity to which you applied for a job is the data controller of your personal information.

Right to be Informed
The general section of this CN Privacy Notice describes the types of personal information we collect, how we collect it, and how we use it in categories that are easy to understand. For information on our retention practices, please see How Long We Retain Your Personal Information above.

Legal Basis for Processing
We rely on a variety of legal bases to process your personal information. We mainly process personal data on the following legal bases: (1) with your consent; and (2) as necessary for our legitimate interests in conducting our business where those interests do not override your fundamental rights and freedom related to data privacy. In limited circumstances, we may rely on other legal bases for processing your personal information, including when necessary to comply with a legal obligation.

Cross-Border Transfer of Information
Certain personal information may be transferred to and processed in the U.S. and other countries where we have facilities or in which we engage service providers. The laws of the U.S. regarding personal information may be different from the laws of your state or country. We implement appropriate safeguards to protect your personal information as required by relevant law, including supplemental measures, if we transfer your personal information outside of the EEA, UK, or Switzerland.

Right of Access, Right to Data Portability, Right to Request Correction, and Right to Request Deletion of Information
If you are a resident of the EEA, UK or Switzerland, you are entitled to certain rights. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you. Subject to exceptions under applicable law, these rights include the ability:

• to request from us access to personal information held by us about you
• to ask for the information we hold about you to be rectified if it is inaccurate or incomplete
• to ask for data to be erased if the data is no longer necessary for the purpose for which it was collected, if you withdraw consent and no other legal basis for processing exists, or if you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing
• to request that we restrict our processing if we are: processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics

To submit a request to exercise your rights, please contact us at Comcast_HRPrivacy@comcast.com. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we may explain that to you in our response. Users that reside in the EEA, UK or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

8. Additional Information for Individuals Located in the State of California, United States

California law provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” rights to access, delete, correct certain Personal Information we collect about them, restrict us from “selling” or “sharing” certain Personal Information, and limit our use of Sensitive Personal Information, as defined by the law and described below. As a California resident, you have a right not to receive discriminatory treatment for the exercise of your privacy rights. The California Consumer Privacy Act (“CCPA”) defines “Personal Information” to mean “information that identifies, relates to,
describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

Collection and Use of Personal Information
The CCPA requires Comcast to disclose the categories of personal information we have collected from job candidates. How we use the information within each category will vary, and not all types of information within the same category will be used for all the purposes listed. Comcast collects or may collect the following categories of personal information about candidates for employment:

Identifiers
For information collected, the purpose of use, and source, please see section 2A “Name and other Information”

Additional categories of information listed in the California Customer Records statue (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number education, employment, or financial information. Some personal information included in this category may overlap with other categories. If we do collect or use this information, we do so only at the time and manner, and to the extent permitted or required by applicable law.

• Source
  • Directly from you during the recruitment and selection process
  • From third parties
• Purpose of Collection and Use
  • Open and track your candidate file
  • To communicate with you
  • Determine your suitability and eligibility to work
  • Verify your identity
  • To comply with legal obligations or fulfill obligations to relevant government authorities
  • To make any adjustments required to assist you in the interview process
  • Conduct meaningful equal opportunity and diversity monitoring and analyses
  • Determine your qualification and selection for jobs
  • Identify potential conflicts of interest
  • To facilitate business travel, arrange or reimburse travel, to contact you during travel
  • To determine compensation offer
  • To understand what Comcast is doing well and what it can improve upon with in the candidate journey and its operations

Characteristics of protected classifications under California or federal law
For information collected, the purpose of use, and source, please see section 2A “Sensitive Personal Information”

Internet or other electronic network activity information
For information collected, the purpose of use, and source, please see section 2C, “Internet or other electronic network activity information, and audio, electronic, visual or similar information.”

Sensory data
Audio, electronic, visual, or similar information

• Source
  • From our systems during the recruitment and selection process
• Purpose of Collection and Use
  • Determine your suitability and eligibility to work
  • Determine your qualification and selection for jobs
  • Professional or employment related information
  • For information collected, the purpose of use, and source, please see section 2A, “Job Qualifications and related information.”

Inferences drawn from other personal information
For information collected, the purpose of use, and source, please see section 2A “Inferences and Analytical Reports drawn from other personal information”

Sensitive Personal Information
For information collected, the purpose of use, and source, please see section 2A “Sensitive Personal Information”

• Disclosures to Third Parties

For all enumerated categories listed above, we limit disclosures of Personal Information for business purposes to service providers, as described in 3. When And With Whom We Share Information. We do not sell information that identifies who you are to anyone and we do not knowingly sell the personal information of consumers under 16 years of age.

• Right To Know, Right to Request Correction, And Right To Request Deletion Of Information

California residents have the right to request that we disclose what personal information we collect, use, and sell, as well as the right to request that we delete certain personal information that we have collected from you, subject to certain exceptions. If we hold personal information that is not accurate, California residents have the right to request that we correct this information. You or your authorized agent may submit a request to exercise your rights by visiting www.xfinity.com/privacy/requests or calling us at (877) 909-4748. We will not discriminate against you for exercising any of the rights described in this section.
For your security and to ensure unauthorized third parties do not access your personal information, we will require you to verify your identity before we can act on your request. If you created an account profile using a Comcast recruitment platform to apply to Comcast, you must authenticate through your account. If you do not have access to the HR platform, you will be required to authenticate by visiting www.xfinity.com/privacy/requests to start the verification process. You may also be required to provide a qualified government-issued photo identification. If you are asking for access on behalf of someone else, we will require verification of your identity, as well as proof of authorization by the individual whose personal information you wish to access.
There may be information we will not return in response to your access request, such as information that would affect the privacy of others or interfere with legal requirements. Similarly, there may be reasons why we cannot comply with your deletion or correction request, such as the need to keep your personal information to continue to manage your application or to fulfill a legal obligation. In certain circumstances, we may not collect sufficient identifiers to match information in our records with your request.

• Right to Restrict Use of Sensitive Personal Information

To the extent Comcast has collected your Sensitive Personal Information, you have the right to request that we restrict our use of it in some cases. Please contact Comcast_HRPrivacy@comcast.com.

9. Changes to This CN Privacy Notice

We will publish and maintain the most current version of our CN Privacy Notice at https://jobs.comcast.com/candidate-privacy. We may modify this CN Privacy Notice over time as our business needs change. If we make material changes to this CN Privacy Notice that increase our rights to use personal information that we have previously collected about you, we will notify you through written, electronic, or other means, as permitted by law, so that you can make any necessary decisions about your ongoing use of our services.

10. How to Contact Us With Questions About This CN Privacy Notice

• Send Us a Message: Comcast_HRPrivacy@comcast.com, or
• You may write to us as follows:
  Comcast Corporation
  Attn: Privacy Legal Department – CN Privacy Notice
  One Comcast Center, Philadelphia, PA 19103-2838