Privacy disclaimer - Billerud North America

RECRUITMENT PRIVACY NOTICE - BILLERUD NORTH AMERICA 

1. INTRODUCTION AND CONTACT DETAILS

1.1 In this privacy notice, we explain how your personal data is processed by Billerud Americas Corporation when you apply for our positions in our recruitment tool or otherwise apply for a job or internship with Billerud Americas Corporation or its subsidiaries (hereinafter, collectively "BNA"). This notice applies to applicants located in the United States.

1.2 It is important to us that you feel confident that we treat your personal data with due care. We have therefore implemented the technical and organizational security measures necessary in order to protect your personal data against unauthorized access and use. We encourage you to take the time to read this privacy notice carefully.

1.3 Billerud Americas Corporation is the data controller and is thereby responsible for the processing of your personal data carried out by us or on our behalf. If you have any questions regarding the processing of your personal data, you are welcome to contact our HR department or the contact person indicated as responsible for the relevant recruitment, who may refer you to BNA's designated privacy contact.

Contact Information: Billerud Americas Corporation, 10050 Innovation Dr, Suite 200 Miamisburg, OH 45342 Email: [privacy@billerud.com]

2. WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?

2.1 Personal data is all information that may be associated with you as an individual. We process personal data that you provide in connection with applying to us, sending us your application, or that we otherwise collect, such as:
• Your name and contact details. In the US context, we do not collect national identification numbers unless required by law or for background check purposes with your consent.
• Your CV and application letter.
• Other documentation that you have provided to us, such as employment history, employment certificates, current employment information, etc.
• Information obtained in connection with interviews, digital screening questions, skills assessments, or from references you have provided to us.
• Information from background checks (if appropriate/necessary for the job and always after you have been informed in advance). BNA uses third-party background check providers compliant with the Fair Credit Reporting Act ("FCRA") and applicable state laws. You will be informed and will provide written authorization before any background check is conducted.
• Results from pre-employment drug and alcohol testing, where required by applicable law or company policy and where permitted for the relevant position, which may include information about your health status.

2.2 As part of our recruitment processes, BNA may use occupational and skills assessment tools provided by approved third-party suppliers. The personal data processed in connection with such assessments includes your name, contact details, as well as assessment results and behavioral indicators generated when you complete the assessments. This process is carried out for the purpose of obtaining an objective, structured, and quality-assured basis for evaluating your competencies and suitability for the specific position. BNA has a legitimate business interest in making well-informed hiring decisions, and this processing is necessary to further that interest.

2.3 BNA may use a digital reference checking service as part of our recruitment processes. In connection with reference checks, we process the reference person's name, telephone number, email address, and the personal data contained in the assessment provided by the reference person. Our legitimate interest is to obtain structured and relevant assessments of candidates in a quality-assured manner in order to evaluate their competencies and suitability for the specific position.

2.4 In certain recruitment processes, background checks are carried out through our approved thirdparty background check provider(s). These checks are only performed for positions where this is justified in accordance with BNA's internal guidelines. The personal data processed depends on the type of check being conducted but may include, for example, identity information, criminal history records (to the extent permitted by applicable law), financial information, and other data required to verify the information provided by you during the recruitment process. If a background check becomes relevant, you will always be informed in advance and your written authorization will be obtained in compliance with the FCRA and applicable state laws.

2.5 For certain positions, a pre-employment drug and/or alcohol screening may be conducted prior to employment, where required or permitted by applicable law. In connection with ordering such a screening, we will provide your name and contact details to our designated occupational health or testing service provider. Results from such tests are treated as confidential medical information.

2.6 Providing your personal data is necessary for us to process your application. If you do not provide the requested information, we will not be able to consider your application for employment.

2.7 In addition to the information you provide directly to us, we may obtain personal data from third parties such as: references you have provided and background check providers (where appropriate and after you have been informed in advance). BNA may also use other external sources that you have approved or provided (e.g., your LinkedIn account). Information may also be obtained from recruitment consultants who interview you.

2.8 To the extent required by applicable law or collective bargaining agreements, BNA may process and share certain personal data in connection with the commencement of employment. We will notify you if such sharing is required.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

3.1 We use the personal data described above for the following purposes:
• Reviewing your application for the specific position you have applied for and other positions that we consider appropriate for you (if you have given your consent to our processing), based on the information you have provided to us.
• Contacting you to inform you about future job opportunities that may be of interest to you (if you have given your consent to our processing for future employment opportunities).
• Making decisions in our recruitment processes.
• Fulfilling our legal obligations and defending our company in case of any legal claims. • Complying with federal and state employment laws, including equal employment opportunity ("EEO") obligations, FCRA requirements, and any applicable state-specific requirements (including, where applicable, the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA") for California applicants).
• Conducting workforce planning and improving our recruitment processes.

3.2 In processes where the number of applicants, number of vacant positions, or other similar reasons result in a significant administrative burden, we may use digital screening tools as part of our selection process. The purpose is both to streamline the administration and to ensure that the selection is carried out in a fact-based and qualified manner based on the requirements for the relevant position. Any such screening process is always subject to human oversight, and we do not make recruitment decisions based solely on automated processing.

4. WHEN IS YOUR PERSONAL DATA ERASED / RETENTION PERIODS

4.1 If your application results in you becoming an employee or intern, your personal data will be transferred from the recruitment system to the HR system, and data will thereafter be retained in accordance with BNA's Records Retention Schedule applicable to employee personnel records. If you are not offered the specific position or internship you applied for, we will retain your recruitment data for a period of two (2) years following the hiring decision in case we need it in connection with an equal employment opportunity inquiry, legal claim, or dispute, unless you have consented to other processing.

4.2 If we wish to retain your personal data for the purpose of contacting you regarding future employment opportunities, we will request your consent to do so. In the absence of such consent, your personal data will be erased following the expiration of the applicable retention period described in Section 4.1, with the exception of data that we need to retain in order to protect our legitimate interest in defending ourselves in the event of a legal dispute. If you have consented to us contacting you regarding future employment opportunities, we will retain your data for a period of two (2) years following the hiring decision, in accordance with BNA's Records Retention Schedule. Thereafter, your data will be erased.

4.3 Personal data from reference checks is retained for a period of two (2) years following the hiring decision, in accordance with BNA's Records Retention Schedule, after which the data is erased.

4.4 Information from drug and alcohol tests is retained for a period of four (4) years, in accordance with BNA's Records Retention Schedule. Information from background checks is retained for a period of five (5) years following completion of the check, in accordance with BNA's Records Retention Schedule. Such data is treated as confidential and access is restricted to authorized personnel. Assessment results (e.g., from skills or personality assessments) are retained for a period of two (2) years following the hiring decision, in accordance with BNA's Records Retention Schedule, provided that you have not participated in a new recruitment during that period. If your application results in you becoming an employee or intern, your assessment results may be used during your initial period of employment as support for us as an employer to offer opportunities for career development, follow up on goals and any shortcomings, or to take disciplinary measures where necessary; in relation to employees, we carry out competence development and performance reviews.

5. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

5.1 BNA processes your personal data on the following legal bases, as applicable under US federal and state law:
• Legitimate business interest: Our primary basis for recruitment-related processing is our legitimate interest in identifying, evaluating, and selecting qualified candidates for employment.
• Pre-employment necessity: To the extent necessary to take steps at your request prior to entering into an employer/employee relatioinship.
• Legal compliance: We process certain data to comply with applicable federal and state laws, including EEO recordkeeping requirements, FCRA obligations, and other employment-related statutes.
• Consent: Where processing is not covered by the above bases, we will obtain your explicit consent prior to processing. If we perform any processing of data that requires your consent, such as requesting you to provide a certain document or extract, we will obtain such consent from you in connection with the specific processing activity.

5.2 For California residents, our processing activities are further governed by the CCPA/CPRA. Please see Section 8 below for your specific rights as a California resident.

5.3 When processing sensitive personal data (such as results of drug and alcohol tests, or information about health status), BNA processes such data only to the extent permitted or required by applicable law and, where required, with your prior authorization.

6. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

6.1 Your personal data may be shared within the Billerud group for recruitment purposes and to external parties outside of BNA, for example companies providing services to BNA such as recruitment services. We use an Applicant Tracking System (“ATS”) that serves as a candidate portal where your personal data will be processed. Accordingly, companies providing IT and platform services in connection with our ATS may have access to candidates' personal data as part of the operation of the service. All such service providers are covered by data processing agreements to ensure appropriate data security and confidentiality.

6.2 We also share personal data with the following categories of third-party service providers:
• Background check providers: To conduct FCRA-compliant background checks where applicable.
• Drug/alcohol testing service providers: For pre-employment screening where required or permitted by law.
• Skills and assessment providers: For occupational and behavioral assessments used in our recruitment process.
• Reference checking services: For structured reference verification.
• Recruitment consultants: Where external recruiters are engaged to assist with sourcing candidates.

6.3 The companies that process the data on our behalf (e.g., parties providing services to us) are only allowed to process your data in accordance with our instructions and by way of agreement we ensure a high level of security for your personal data. Should we transfer your data outside of the United States, we will ensure that appropriate safeguards are in place to protect your personal data.

6.4 We will also disclose data to governmental authorities, regulatory agencies, or courts if we are obliged to do so by applicable law, regulation, legal process, or enforceable governmental request.

7. DATA SECURITY

7.1 We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction within our recruitment system. We impose strict security requirements on our service providers through contractual obligations. Access to the recruitment system is controlled through individual user credentials, consisting of a personal user ID and password. Access to personal data is granted only to personnel who require such access in order to perform their duties and obligations in connection with their role within BNA.

7.2 The security of personal data is also ensured when transferring or disclosing the data to other processors. The measures employed vary based on the sensitivity of the data and include, for example, identification of authorized recipients and encryption.

7.3 Candidate data is processed primarily electronically in the recruitment systems. If printouts are made or manual data is otherwise processed, the personnel handling the recruitment process have been instructed to handle the material carefully and ensure that the material is only disclosed to those employees within BNA who are responsible for the recruitment and related decisions, and to destroy the material when it is no longer needed in connection with the current recruitment process or if the candidate so requests.

7.4 In the event of a data breach affecting your personal data, BNA will notify you and the relevant authorities as required by applicable federal and state data breach notification laws.

8. YOUR PRIVACY RIGHTS

8.1 You may have certain rights with respect to our processing of your personal data under applicable federal and state law.
• Right to rectification: Where provided by applicable state law, a right to have inaccurate personal data corrected.
• Right to erasure/deletion: Where provided by applicable state law, a right to have your personal data deleted, subject to applicable legal exceptions.
• Right of access: Where provided by applicable state law, a right to obtain information about what personal data we process about you and a copy of the personal data undergoing processing.
• Right to restriction of processing: Where provided by applicable state law, a right to request that our processing of your personal data be restricted in certain circumstances, for example if you contest the accuracy of the personal data we are processing.
• Right to data portability: Where provided by applicable state law, a right to request that your personal data be provided to you or transferred to another entity in a portable format, to the extent technically feasible.
• Right to object: Where provided by applicable state law, a right to object to certain processing of your personal data.
• Right to withdraw consent: You may withdraw your consent at any time, although a withdrawal will not affect the lawfulness of processing based on your consent before its withdrawal.
• Right to opt out of sale/sharing (California): If you are a California resident, you have the right to opt out of the "sale" or "sharing" of your personal information as defined under the CCPA/CPRA. Note that BNA does not sell your personal data.
• Right to non-discrimination: You have the right not to be discriminated against for exercising any of your privacy rights.

8.2 Some of the rights above are only applicable in certain situations. In case you would like to exercise any of your rights, please contact us, preferably by sending an email to privacy@billerud.com. We will respond to verifiable requests within the timeframe required by applicable law.

8.3 California Residents: Under the CCPA/CPRA, you have additional rights, including the right to know the categories of personal information collected about you, the right to know the business or commercial purposes for collecting such information, and the right to know the categories of third parties with whom we share your personal information. To submit a request, please contact us using the contact details in Section 1.

8.4 For All Applicants: You have rights under applicable federal anti-discrimination laws, including the right not to be subjected to unlawful employment discrimination. If a background check is used in a hiring decision, you have rights under the FCRA, including the right to receive a copy of the background check report and to dispute inaccurate information.

9. EQUAL EMPLOYMENT OPPORTUNITY & VOLUNTARY DISCLOSURE

9.1 BNA is an Equal Opportunity Employer. We collect certain demographic information (such as race, ethnicity, gender, veteran status, and disability status) on a voluntary basis as required by federal and state EEO reporting obligations (e.g., EEO-1 reporting). This information is kept strictly separate from your recruitment file and is used solely for compliance reporting purposes. Providing or declining to provide this information will have no bearing on your candidacy.

10. UPDATES TO THIS NOTICE

10.1 We may update this privacy notice from time to time. The current version will be made available on our website and in the application form under Career. We will notify you of material changes as required by applicable law.

If, at any time, you have questions or concerns about our online privacy commitment, please feel free to email us at contactus@billerud.com or call our Corporate Human Resources office to speak to one of our team members.