Ciena Selection & Recruitment Data Privacy Policy

During your recruitment, selection and/or interview process with Ciena Corporation and/or its subsidiary and group companies (“Ciena”), we will collect and store the personal information that you provide (“Personal Data”). Please read the following privacy policy (the “Policy”) to understand how we use and protect your Personal Data. It also describes your data protection rights, including a right to object to some of the processing which Ciena carries out. More information about your rights, and how to exercise them, is set out in the Your Rights section below.

We also may provide you with additional information when we collect Personal Data, where we feel it would be helpful to provide relevant and timely information.

This Policy may be updated periodically. We will update the date at the top of this Privacy Notice accordingly. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Policy as required by applicable law.

Collection of your Personal Data

We process the following types of Personal Data when you apply for a position with us.

• Data you provide to us: We collect and store any Personal Data you provide us through your application, whether via the Ciena recruitment portal operated by a third party on Ciena’s behalf (the “Portal”) or otherwise, including your contact details; your application materials (CV, cover letter, previous work experience, education, and transcripts, and our notes from any interviews with you); your desired salary, type of employment sought and date available; your identification documents (passport number, government identification numbers where permitted, immigration status); and any other data you submit to us, including any correspondences you may have with us during the application process.
• Data from other sources: We obtain Personal Data about you from other sources, including recruiters, employment research firms, identity verification services, the references you provide to us, websites and other publicly accessible data on the Internet. We may also receive Personal Data you submit to us through third-party websites. In certain countries, where permitted, we collect – either ourselves or through third party service providers - details of professional registrations, sanctions with professional bodies, financial checks and/or criminal convictions (in accordance with applicable laws).
• Information we collect automatically: When you make an application through our Portal, we collect information sent to us by your computer, mobile phone or other access device. For example, this includes the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information, your browser type and traffic to and from our site. Some of this information is collected via cookies and other tracking technologies.

Please do not include any sensitive or special category Personal Data as part of your application, i.e. information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status or sexuality as well as information regarding criminal convictions. If we do require this information as part of your application, we will request this separately.

Where we require Personal Data to comply with legal or contractual obligations, then provision of such Personal Data is mandatory. If such Personal Data is not provided, then we will not be able to process your application, or to meet obligations placed on us. In all other cases, provision of requested Personal Data is optional and you may choose not to supply it.

Why We Collect, Use and Store this Personal Data

We collect, use and store your Personal Data for the reasons we have set out below:

• Where this is necessary for Ciena to review and assess your application for employment
  • This includes assessing your skills and interest in career opportunities at Ciena, processing your application, analyzing your qualifications, verifying your identity and your eligibility for employment, and communicating with you about your application to respond to your enquiries and schedule interviews.
• Where necessary for Ciena’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights
  • Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use relating to legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information relating to legal process or litigation) and other ethics and compliance reporting requirements.
  • Maintaining the security and integrity of our facilities, equipment and electronic platforms. This includes administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.
  • To analyse and monitor the diversity of the workforce in accordance with applicable laws. This includes for example, compliance with equal opportunity employment laws.
• Where necessary to comply with a legal obligation
  • Disclosures to law enforcement agencies.
• Where you have given consent
  • Where permitted by local law and with your consent (where required), we also carry out background checks to evaluate eligibility for employment. The level of required checks will vary by position and will usually be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and we, or our background checking providers, will obtain any necessary consents or acknowledgements prior to completing such checks. We also collect medical information with your consent if a regular or onboarding health check is required or to evaluate eligibility for applicable benefits. Where we ask for your consent, you are free to withhold or revoke it.

If your application is successful, your Personal Data will subsequently be used for the management and administration of the employer/employee relationship. The specifics of how your Personal Data will be processed as an employee of Ciena will be notified to you separately.

Disclosure of Your Personal Data

Ciena is a global organization, headquartered in the USA. As such, your Personal Data may be shared within the Ciena group of companies for the purposes of the recruitment and selection process, to administer and manage group functions or to refer you for other open positions. Your Personal Data will also be shared with companies providing services under contract to the Ciena group such as the Portal provider. Ciena may also pass your personal information to other third parties which Ciena uses as part of the recruitment process such as for background checks, psychometric tests, or assessment tests.

Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law, and if required for the legal protection of Ciena’s legitimate interests in compliance with applicable laws. If the business is sold or integrated with another business, your details may (in accordance with applicable law) be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business. Where required by local law, you will be told of such transfers.

International Transfers

If you are based in the European Economic Area (EEA) and Switzerland, and you submit an application, your Personal Data will be transferred out of the EEA and Switzerland to other international Ciena offices (such the United States, Canada, The United Kingdom and India). Any such transfer will be undertaken in accordance with appropriate technical, organizational and security measures, and in accordance with relevant law (for example, where required, EU Standard Contract Clauses (as amended by the EU from time to time) are used to transfer your Personal Data to Ciena entities and our service providers in third countries).

Retention of Your Personal Data

If your application is unsuccessful and you reside in European Union, we will retain your application and candidate record for eighteen (18) months for the purpose of matching you with future job opportunities within the Ciena group. If you reside outside of the European Union, we will retain your application and candidate record for as long as reasonably necessary. You can request that we stop holding your details for this purpose at any time by contacting us. See the How to Contact Us section below.

Security of Your Personal Data

Adequate technical and administrative measures are in place to protect the Personal Data that you provide to us, including when such data is transferred, as described in this Policy, within the Ciena group of companies and/or to the Portal provider. The Portal provider is based in the USA. By using the Portal, you acknowledge that the Personal Data that you provide via the Portal will be stored and processed securely in the USA.

Use of Cookies

The Portal provider uses cookies to improve your user experience. How such cookies are used is set out in the Portal provider’s terms and conditions, which will be available to you when you access the Portal.

Data Protection Legislation

For the purposes of the applicable European data protection laws, the data controller for your Personal Data will be the Ciena company to whom you are applying for a job. Personal Data will only be collected and processed in accordance with applicable data protection laws, and only for the purposes set out in this Policy.

Your Rights

Under European data protection laws, you may have the right to request:

1. a copy of the Personal Data which we hold relating to you (Note: we may ask you to verify your identity and for more information about your request);
2. to correct, delete or restrict processing of your Personal Data (please let us know, using the contact details below, if any Personal Data that we hold about you is not accurate); and
3. to obtain the Personal Data you provide in a structured, machine readable format.

In addition, you can object to the processing of your personal data in some circumstances (in particular where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Ciena processing your Personal Data, this will not affect any processing which has already taken place at that time.

There are exceptions to these rights. Access may be denied, for example, if making the information available would reveal Personal Data about another person or if Ciena is legally prevented from disclosing or deleting such Personal Data. If you have unresolved concerns, you have the right to complain to the data protection authority in the country you reside, where you work or where we are located.

Your Personal Data Protection Statement

By submitting your Personal Data and job application, you declare that:

1. you have read, understood, and accepted the statements set out in this Policy;
2. the information given in your job application is complete and true to the best of your knowledge, and you understand that any deliberate omissions and incorrect statements could lead to your application being rejected or, if an offer of employment is extended and accepted, your subsequent dismissal; and
3. you authorize Ciena to verify or have verified on Ciena’s behalf all statements made in connection with your job application, any other information you may provide separately, and to make any and all necessary (and legally permitted) reference and background checks.

How to Contact Us

If you have any queries about this Policy or wish to contact us for any reason in relation to our Personal Data processing activities, please contact:

Lindsay Sharp
Director, People & Culture Technology
Ciena Corporation
7035 Ridge Road
Hanover, Maryland 21076
United States
E-mail: HRdataprivacy@ciena.com

For queries from data subjects in Germany:

Thomas Schmitz
Data Protection Officer
Ciena Limited
6th Floor
Main Airport Center
Unterschweinstiege 10
D-60549 Frankfurt am Main
Deutschland
E-mail: tschmitz@ciena.com