STARBUCKS JOB APPLICANT AND NON-PARTNER PRIVACY STATEMENT
Effective date: July, 2021
At Starbucks, we put people first, including you—our job applicants, professional service providers and contingent workers (together, “Non-Partners”). We seek to respect and maintain your trust, including in relation to your privacy. Grab a cup of coffee and learn more below.
This Starbucks Job Applicant and Non-Partner Privacy Statement describes the types of personal data (which we will be calling “ your personal information”) that we collect from Non-Partners, how we use it, how and when it may be shared, and how to exercise your rights with respect to your information. This notice applies solely to the processing of personal information of professional service providers and contingent workers, and the processing of personal information collected during the job application process to become a Starbucks Partner or Non-Partner.
Our goal is to clarify how and why we process information and to provide you with points of contact, should you have any questions about our policies or procedures. Thank you for taking the time to read and understand our data and privacy-related practices.
To read the privacy statement that applies to customers and visitors to our websites or mobile applications, please see here or visit your local Starbucks website.
Current Starbucks Partners may access the Partner Privacy Statement found on “My Partner Info” and the “Partner Hub” to read about personal information collection and use in the employment context.
- Applicability and Scope
- Updates to this Privacy Statement
- Starbucks Global Privacy Standard and Core Privacy Principles
- Information We Collect
- Sensitive Personal Information
- How We Use Your Information
- How We Share Your Information
- How We Protect Your Information
- Network and Device Usage Monitoring
- Retention and Disposal of Your Informationstrong
- Transferring Your Information Overseas
- Your Privacy Rights
- Contact Us
1. Applicability and Scope
This Starbucks Job Applicant and Non-Partner Privacy Statement (“Privacy Statement”) applies to the personal information collected from job applicants, professional service providers and contingent workers (together, “Non-Partners”) during the course of your applying to work at Starbucks (as a Partner or Non-Partner job applicant) or during your placement with Starbucks (for professional service providers and contingent workers).
This Privacy Statement does not cover your use of Starbucks products or services (e.g., a Starbucks website) as a customer or any collection of information outside of the job application process or your Non-Partner engagement with Starbucks.
The terms “personal information” or “personal data” are broad and mean any information relating to a natural person who may be directly or indirectly identified by reference by an identifier such as name, ID number, location data, online identifier, or other information that identifies a unique individual, or as otherwise defined by applicable laws, regulations and/or statutes. In relation to the processing of the personal data of our Non-Partners, this policy may refer to “Non-Partner Personal Information.”
In this Privacy Statement, the term “Starbucks” refers to Starbucks Corporation, including the Starbucks entity to which you are applying or where you are being assigned or engaged—which is referred to in this Privacy Statement as your “Starbucks Employer.” Your Starbucks Employer (“we”, “us” or “our“) is responsible for the processing of your Non-Partner Personal Information.
2. Updates to this Privacy Statement
This Privacy Statement went into effect on the “Effective date” or “Last revised” date noted near the top of this page. This Privacy Statement is not a contract and Starbucks reserves the right to update this Privacy Statement from time to time. We will notify you of any modifications to this Privacy Statement that might materially affect your rights or the way that we use or disclose your personal information by posting a message within future Privacy Statements indicating that such changes would apply. Please check this Privacy Statement regularly on the site from which you accessed it to learn about any updates to the policy.
We encourage you to familiarize yourself with this Privacy Statement as well as other policies issued by Starbucks that are applicable to you. This includes without limitation any relevant specific data privacy statements that we may issue from time to time.
3. Starbucks Global Privacy Standard and Core Privacy Principles
Your Starbucks Employer values your contributions and has created this notice in line with Starbucks’ Global Privacy Standard and core privacy principles and values.
3.1 Starbucks Principles. In collecting and processing your personal information, we will comply with applicable laws and regulations, and we will implement additional procedures, standards, and policies wherever needed to meet those requirements. In particular, we are committed to complying with Starbucks core principles. The personal information we hold about you is:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in a manner that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Maintained as long as is necessary for the purposes we have told you about; and
- Maintained securely.
3.2 Interaction With Local Laws. This Privacy Statement provides a standard for Starbucks with respect to its protection of personal information. The jurisdiction where you reside may require different levels of protection. Therefore, we will handle your personal information in accordance with applicable laws and regulations at the place where your Starbucks Employer is located. Where applicable local law provides a lower level of protection than that established by this notice, we will still strive to meet the requirements of this Privacy Statement.
4. Information We Collect
We typically collect personal information about our Non-Partners either directly from you or sometimes from a third-party source as noted below. We also collect personal information in the course of the application/hiring process or as part of job-related activities throughout the period you are engaged with us. Some of the information we collect may constitute “Sensitive Personal Information,” as described below, depending on where you reside.
Please note that if you decline to provide certain information when requested, we may not be able to fulfil our responsibilities (such as paying you), or we may be prevented from complying with our legal obligations (such as safeguarding the health and safety of Non-Partners present in our facilities). Therefore, if you do not provide certain information, we will not be able to enter into a contract with you or accept your engagement.
Subject to applicable law requirements, the categories of personal information that we may collect, store, and use about you in the normal course of the job application process or your engagement with us include:
(a) Personal identification information, such as your name, home address, date and place of birth, usernames, personal email address, and home or wireless phone number;
(b) Demographic information, such as race or ethnicity, nationality, languages spoken, marital status, religion/religious beliefs, veterans status, and gender;
(c) Job-related information, such as effective dates and years of service, work location, current/prior work record, and other career history information;
(d) Academic and professional qualifications, such as your educational status, certificates and licenses, degrees earned, vocational records and in-house training attendance, including as part of resumes/CVs;
(e) Information related to your usage of Starbucks’s assets, in particular its computers and telecommunication systems (“IT”), and traffic generated on the Internet, including emails sent and received, building and information system access, and Starbucks device/system/application usage when accessing and using Starbucks buildings, networks, company-issed devices, and/or assets;
(f) Information needed for compliance and risk management, such as disciplinary records, garnishments, background check reports and security data;
(g) Employment eligibility information, including immigration, right-to-work, alien registration status, refugee status, work permits, and residence status;
(h) Travel and passport information; and
(i) Photographs and video footage, subject to applicable law requirements.
If we ask you to provide any other personal information not described above, then we will make clear to you what specific personal information we need and the reason(s) why we ask you to provide it.
We also may collect information automatically from you. For instance, when you apply to a position using the application portal on our website, we may gather information from using cookies and other tracking technologies. To learn more about our use of these technologies, please visit the Starbucks Privacy Statement here
4.1 Specific Consent. Depending on the location in which you live, local laws may require that you provide specific consent for the collection, use and disclosure of personal information for some of these purposes. Where required, you may be asked to provide your consent by appropriate and permitted means.
4.2 Third Party Sources In general, we collect Non-Partner Personal Information directly from our Non-Partners. However, in some cases, we may collect personal information about Non-Partners from third parties, such as background verification providers, recruiters, agencies, or market research companies.
5. Sensitive Personal Information
Certain types of personal information may be more sensitive than others. Data protection laws around the world may use varying terminology in naming these categories of sensitive data (such as “Special Categories of Personal Data”), and also set varied compliance requirements for companies to follow in their processing of this data.
Recognizing the variation in terminology and requirements established by applicable laws, Starbucks strives to meet the relevant compliance elements in its processing of these more sensitive categories of personal information.
Further, Starbucks may also internally identify certain categories of higher sensitivity data as “Sensitive Personal Information” or “SPI.” Starbucks defines SPI to be any information relating to an identifiable person that includes or implies race, ethnicity, political views, religion, health, sexual orientation, genetic or biometric data, and information about criminal convictions and offenses.
5.1 Company-Related SPI Only. Starbucks prohibits Non-Partners’ use of SPI for personal purposes on Starbucks networks and devices (e.g., sharing SPI via email, on company message boards, through company-issued devices). The only permitted use of SPI is company-related. This means that Starbucks processes and uses your SPI in two ways: (1) as required for business and employment purposes (e.g., providing you with health benefits, recording work disabilities or injuries, etc.) and (2) based on your consent if you use company-sponsored services or platforms that might gather SPI (e.g., a company-approved health and wellness application).
With this in mind, Starbucks processes Sensitive Personal Information to provide you with company benefits, comply with applicable laws or valid requests from law enforcement or courts, and/or to protect your data from cybersecurity threats. If you have questions about what SPI is, and/or how Starbucks handles such data, please contact the Starbucks Global Privacy Department as described in the “Contact Us” section below.
6. How We Use Your Information
We use your personal information in compliance with applicable laws, and we do so primarily to manage our relationship with you and to further your workplace facilities and IT systems interactions. We require your personal information primarily to allow us to perform our Starbucks Employer duties and to enable us to comply with our legal obligations. We use your personal information for the following purposes:
(a) To administer the Non-Partner relationship or other commitments we have made to you, including to assess qualifications for a particular job or task or to communicate with you about your application or engagement.;
(b) To administer pay, such as monitoring salary details and processing payment account details, and other compensation, and payroll administration (e.g., salary, tax withholding, etc.);
(c) For workforce development, talent management, education, training and certification;
(d) For general business management and operations, such as for risk management or to generate analytics;
(e) For professional issues resolution, such as in relation to grievances, auditing, conflict of interest reporting, or to gather evidence for disciplinary action or ending an engagement;
(f) To identify a contact point in the event of an emergency, to further the health and safety needs for our workforce;
(g) To comply with applicable labor statutes, and for accounting, financial reporting and business planning;
(h) To ensure your safety and the security of Starbucks-held information, including as part of business continuity planning and disaster recovery;
(i) As required or expressly authorized by laws or regulations applicable to our business or by government agencies that oversee our business, or as part of legal proceedings and government investigations, including preservation of relevant data; and
(j) For any other purposes that are reasonably requiredby Starbucks in connection with application for and during the course of your application process or engagement with Starbucks.
6.1 Compatible Purposes. We use your personal information for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose and there is a legal basis for further processing, if required.
6.2 Accuracy. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with Starbucks.
7. How We Share Your Information
Starbucks ensures that your personal information will be accessed only by those who have a legitimate business interest to access it in order to perform a service for you or for Starbucks. The circumstances for which we may disclose your personal information include the following:
(a) When We Work Together – We may share information between and among Starbucks Corporation, its subsidiaries, and affiliated companies for purposes of management and analysis, decision making, and other human resources and employment-related business purposes.
(b) When We Work with Service Providers – We may share your information with service providers that provide us with support services, such as payroll services and administration, IT services and website hosting, health and safety compliance, facilities management, and email and postal delivery. We do not allow our third-party service providers to use your personal information for their own purposes.
(c) When We Work on Business Transactions – If we become involved with a merger, reorganization, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
(d) When Sharing Helps Us Protect Safety and Lawful Interests – We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, if we believe it will assist in the investigation of suspected or actual illegal activity, or if we believe that the disclosure will help us protect the rights, property, or safety of Starbucks, our customers or our partners.
(e) When the Information Does Not Identify You – We may share your information in a way that does not directly identify you, such as via aggregated information for statistical analysis and other business purposes.
(f) When You Give Consent – We may share information about you with other companies if you give us permission or direct us to share the information, in accordance with applicable law.
Please note that there may be certain situations where you will be asked or have the option to share personal information directly with providers connected to Starbucks partner or Non-Partner services, where Starbucks does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such providers.
8. How We Protect Your Information
Starbucks protects your information using appropriate technical, physical, and administrative security measures, including pseudonymization, encryption and access controls, designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information.
However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Non-Partner Personal Information, is absolutely safe from intrusion or other unauthorized access by others. We ask that you be responsible in protecting your password(s) and maintaining the security of your devices.
9. Network and Device Usage Monitoring
Where permitted by law, Starbucks monitors some network and device usage, as we have an obligation to protect our workforce, assets, and facilities. Starbucks monitors its networks and devices for two purposes: (i) to protect the security of our workforce, data, networks, assets, facilities, reputation, and competitive interest; and (ii) to investigate suspected or confirmed misconduct under Starbucks policies or violations of law (including in support of litigation). This monitoring is consistently handled in compliance with Starbucks policies and relevant laws.
We also may monitor Starbucks office premises by security footage or badge scans.
Please note that any Non-Partner message, files, data, document, electronic communications, social media posts, or any other types of information transmitted to or from, received or printed from, or created, stored, or recorded on our IT and communications systems and assets (including company-issued devices) are presumed to be Starbucks Employer business-related, and we may monitor it in accordance with this Privacy Statement and other company standards, including in relation to the use of company equipment and infrastructure.
We recognize that any monitoring that we perform may impact our Partners’ and Non-Partners’ privacy. We strive to ensure that any monitoring we perform is proportionate to the limited and specific purposes needed and conducted as required or permitted by applicable law
10. Retention and Disposal of Your Information
10.1 Data Retention Purpose and Location. We store personal information as needed to accomplish the purposes identified in this Privacy Statement and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. This storage period may extend beyond the term of your job application process or engagement with Starbucks. Our retention of your personal information is subject to applicable law.
The personal information that you provide us is stored and processed on servers owned by Starbucks and other companies in the United States, Canada or elsewhere around the world, including locations that may be outside of the country or jurisdiction where you are located. Regardless of the entity or person who processes your information and where it is processed, we will take steps to transfer and protect your information through appropriate safeguards in accordance with applicable data protection laws and this Privacy Statement.
10.2 Retention Period. When personal information is no longer needed or, in any event, after legal authority to retain it has expired, personal information will be destroyed, in accordance with applicable law and pursuant to procedures established in relation to the relevant Starbucks system or process.
11. Transferring Your Information Overseas
Starbucks is a global business. As noted above, we and our service providers may collect, use, process, store or disclose your personal information outside your home country or jurisdiction, including in the United States and elsewhere that may have different data protection laws than the laws where you reside or work.
Please note that Starbucks only transfers Non-Partner Personal Information to another country (including to affiliates and subsidiaries within the Starbucks corporate group) in accordance with applicable laws and this Privacy Statement.
12. Your Privacy Rights
Generally our job application portals and self-service tools allow you to view and update the personal information that Starbucks holds about you. If we have Non-Partner Personal Information that you cannot access via these self-service systems, or if we have Non-Partner Personal Information that you believe is inaccurate or no longer relevant, and you would like us to correct or delete such data, then you may make a request as described in the “Contact Us” section below.
For information about our general approach to the California Consumer Privacy Act, please see the Starbucks Privacy Statement here. Current Starbucks Partners may also review additional privacy materials on the Global Privacy site on the Partner Hub.
13. Contact Us
If you have questions about this Privacy Statement or our Non-Partner Personal Information practices, please contact the Starbucks Global Privacy Department and Data Protection Officer at firstname.lastname@example.org.