Effective Date: September 16, 2024
This Applicant Privacy Notice (“ Applicant Notice“) explains how Tandem Diabetes Care Inc. and the Tandem legal entities with whom you are applying (collectively, “Tandem”, “we”, “our”, or “us”) collects, uses, stores, discloses and erases (“Processes“) personal information about our recruits and job applicants (“Applicants”), why we Process it and how that Processing may affect you. We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law.
This notice does not apply to Applicants in California and Canada.
Please read this Notice in full to ensure you are completely informed about how we Process your personal information.
We collect personal information about you when you apply for a job with us and during the recruitment process. How far you progress in the recruitment process will depend on the level of data that we collect. Your personal information will be collected either directly from you or indirectly from third parties.
We collect personal information directly from you when you choose to provide us with this information online and any subsequent communications between ourselves whether online or offline throughout the recruitment process.
On occasions, Tandem will use recruiters, who will provide us with your personal information. We also used LinkedIn to advertise roles within Tandem, and we may receive information when you apply for a role on LinkedIn.
Any offer we make will be subject to the receipt of references and other relevant background checks. We will only contact referees whose details you provide to us. We will make it clear to you at the outset of the application process whether checks are undertaken with background checking organisations like the Disclosure and Barring Service.
The table below describes the categories of personal information we collect from and about you through our online application process and on social media.
| Personal information description | Source(s) |
|---|---|
| Contact Information such as your title, name, phone number, home address and personal email address. | Directly from you online |
| Job Application Information, Professional History, Educational History and Qualifications such as position applied for, previous roles, job description, responsibilities and assignments, years of service, qualifications and experience, compensation and salary data as volunteered by the candidate, eligibility for and participation in benefit schemes and other information contained in your CV. | Directly from you online |
| Results of Reference Checks and Screenings such as verification of education and employment history. | Third parties |
| Background Check Information, such as disbarment and other searches relevant to the role for which you are applying. The sharing of this information will only be requested at the end of the final stage of the recruitment process, once the offer has been made and the applicant has accepted. | Third parties |
| Nationality, Citizenship and Right to Work Information such as country of birth, government identification documents (including passports and residency permits) and, where relevant, visa information. | Directly from you online and offline |
| Interview Information such as comments and notes made by interviewers or other Tandem employees in connection with your application. | Directly from you offline and from others involve in the interview process |
| Any other data provided by you in the course of the application process such as electronic communications with you in relation to the application process. | Directly from you online |
| Equal Opportunity Information such as information relating to your gender, race, ethnicity, and disability. | Directly from you online |
The provision of your contact information, work history and education is necessary for processing your application. The provision of your right to work and background check information is necessary to demonstrate your right to work in the country in which you are applying for a job, and that you have the appropriate background to undertake the role that you are applying for.
We use the personal information that we collect from and about you only for the purposes described in this Applicant Notice. Depending on our purpose for collecting your information, we rely on one of the following legal bases, in so far as required by applicable data protection law:
The following table provides more details on our purposes for Processing your personal information. The legal basis under which your personal information is Processed will depend on the data concerned and the specific context in which we collect it.
We collect and use your personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying out reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.
| Category of personal information | How we use it (purposes) |
|---|---|
| Contact Information such as your title, name, phone number, home address and personal e-mail address. |
|
| Job Application Information, Professional History, Educational History and Qualifications such as position applied for, previous roles, job description, responsibilities and assignments, years of service, qualifications and experience, compensation and salary data as volunteer by the candidate, eligibility for and participation in benefit schemes and other information contained in your CV. |
|
| Results of Reference Checks and Screenings such as verification of education and employment history. |
|
| Background Check Information, such as criminal records checks, disbarment and other searches relevant to the role for which you are applying. The sharing of this information will only be requested at the end of the final stage of the recruitment process, once the offer has been made and the applicant has accepted will they be asked for their “criminal record certificate." | We use this information to verify your suitability for a role, where the nature of the role requires additional background checks (e.g., disbarment). |
| Nationality, Citizenship and Right to Work Information such as country of birth, government identification documents (including passports and residency permits) and, where relevant, visa information. |
|
| Interview Information such as comments and notes made by interviewers or other Tandem employees in connection with your application. |
|
| Any other data provided by you in the course of the application process including electronic communications with you in relation to the application process. |
|
| Equal Opportunity Information such as information relating to your gender, race, ethnicity, disability and veteran status on a voluntary basis only. | We will anonymize this information where possible. We will aggregate this information to understand, monitor and improve our application and recruitment processes in line with our diversity and inclusion strategy. |
As a general rule, during the recruitment process, we try not to collect or process any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life; as well as, for the purposes of the Swiss Data Protection Act, data on administrative or criminal proceedings and sanctions, data on social security measures and data on the intimate sphere in general ("Sensitive Personal Information"), unless authorized by law or where necessary to comply with applicable laws.
In some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment related purposes, for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:
We use appropriate administrative, technical, physical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include managerial measures, including establishment and implementation of internal management plan and periodic training for employees; technical measures, including controlling access rights to personal information processing systems and encryption of important data; and physical measures, including external security and management of system servers. While we implement security measures designed to be appropriate to the relevant risks, please note no data transmission over the Internet or any wireless network can be guaranteed as being 100% secure.
As we operate internationally, in some cases, where your personal information is transferred to another Tandem company, it is processed in countries other than the country in which you are resident, including in the United States, where Tandem is headquartered. This means that when we collect your personal information, we will process it in any of these countries, potentially in any country in the world. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Where we transfer your personal information to countries and territories outside of the European Economic Area, the UK and Switzerland which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant "adequacy decisions" from the European Commission, the "adequacy regulations" (data bridges) from the Secretary of State in the UK, and the adequacy assessment from the Swiss Federal Council, as applicable (together referred to as "EEA/Swiss/UK adequacy decisions").
Some EEA/Swiss/UK adequacy decisions require Tandem to take steps in order for relevant transfers to be covered, in particular for transfers to the U.S. under the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF ("UK Extension"), and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce.
Tandem's US entities (Tandem Diabetes Care, Inc. and Sugarmate, Inc.) have certified to the U.S. Department of Commerce that they adhere to:
To learn more about the Data Privacy Framework ("DPF") and to view our certification, see here. It is important however for us to provide you with the following information about our certification:
Where the transfer is not subject to an adequacy decision or regulations, we take appropriate safeguards to require your personal information will remain protected. The safeguards we use under GDPR, include the European Commission's Standard Contractual Clauses ("SCCs") as issued on 4 June 2021, in the form of modules 1 (controller to controller), module 2 (controller to processor), module 3 (processor to processor) and/or module 4 (processor to controller), as appropriate depending on our relationship with the recipient(s). We incorporate the UK's International Data Transfer Addendum to the EU Commission SCCs as permitted under Article 46 of the UK GDPR, when transferring personal information protected under UK GDPR and the Swiss Addendum to the SCCs as provided by the FDPIC in its statement of 27 August 2021.
Our SCCs can be provided on request. Please note some sensitive commercial information may be redacted. In exceptional circumstances, personal information may also be transferred to countries that are not subject to an adequacy decision or regulations on the basis of a derogation. A derogation may apply, for example, in case of legal proceedings abroad, if transfer is necessary for the performance of a contract, if you have consented to the transfer, or if the data has been made generally available by you and you have not objected to the processing.
For details of what personal information may be transferred to Tandem group entities or third parties, please see the Disclosing Your Information section of this Notice above.
We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.
If your application is successful and you become an employee, where permitted by local law the personal data we collect during the application process may be transferred to your personnel file and stored in accordance with our Employee Privacy Policy, which will be made available to you at the start of your employment.
Please note, we do not currently use your personal information for automated decision making which produces legal effects concerning you or similarly significantly affects you.
The GDPR and UK GDPR provide EEA and UK residents with certain rights regarding their personal information. If you are a resident of the EEA or the UK, subject to certain conditions, you may ask us to take the following actions in relation to your personal information:
Under the Swiss Data Protection Act you have similar rights, subject to certain restrictions defined by law that we are entitled or even required to apply (e.g., to protect third party interests).
If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at DPO@tandemdiabetes.com or you have the right to submit a complaint to a data protection regulator. EEA residents can find information about your data protection regulator here. The data protection regulator for residents of the UK is the Information Commissioner’s Office. The data protection regulator for residents in Switzerland is the Federal Data Protection and Information Commissioner
You can submit requests by email to DPO@tandemdiabetes.com. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at DPO@tandemdiabetes.com or submit a complaint to a data protection regulator. EEA residents can find information about your data protection regulator here. The data protection regulator for residents of the United Kingdom is the Information Commissioner’s Office. The data protection regulator for residents in Switzerland is the Federal Data Protection and Information Commissioner
We may update this Applicant Notice from time to time. You can see when this Applicant Notice was last updated by checking the "Last Updated" date displayed at the top of this Applicant Notice. You will be informed, via relevant means, of any material changes to this Privacy Notice. Any changes to this Privacy Notice take effect immediately after being posted or otherwise provided by Tandem.
Please note that you may reach out to your line manager in the first instance if you have any question regarding data protection.
You can also contact us as follows:
Either contact Tandem directly at privacy@tandemdiabetes.com; or Tandem’s EEA and UK Data Protection Officer (DPO) at:
Fieldfisher LLP
Attn: Data Privacy
Riverbank House
2 Swan Lane
London
EC4R 3TT
Email: DPO@tandemdiabetes.com