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US Candidate Privacy Notice

Introduction

Crowell & Moring LLP, ( “Crowell & Moring”, “we”, “us”, or “our”) is committed to protecting the privacy and security of your personal data. This privacy notice describes how we collect and use personal data about you during and after the recruitment process.

You are being sent a copy of this privacy notice because you are a candidate applying for a role with us (whether as a partner, an employee, a worker or a contractor). Please read and retain a copy, together with any other privacy notice we may provide to you on specific occasions when we collect or process personal data about you. This notice does not form part of any contract of employment or other contract to provide services.

Personal Data We Hold About You

Personal data includes any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include data where the person's identity has been removed (anonymous data).

In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you (further details are included in Appendix 1):

(i) Identity and Contact Data; (ii) Date of Birth Data; (iii) Insurance Data; (iv) Salary and Benefits Data; (v) Employment Commencement Data; (vi) Workplace Location Data; (vii) Verification Data; (viii) Recruitment Data; (ix) Lateral Partner Questionnaire Data (to the extent relevant); (x) Employment Data; (xi) Compensation Data; (xii) Background Data; and (xiii) Education Data, (xiv) Health Data, (xv) Criminal History Data.

How We Collect Your Personal Data

We collect personal data through the application and recruitment process, either directly from candidates or sometimes from third parties.

Relevant third parties include: (i) employment or recruitment agencies, (Identity and Contact Data, certain Recruitment Data, Compensation Data, Employment Data and Education Data); (ii) background check providers, who may collect certain personal data from other third parties, such as the Disclosure and Barring Service and credit reference agencies, (certain Background Data and certain Criminal Offence Data); (iii) former employers, (certain Recruitment Data and certain Employment Data); (iv) named referees, (certain Recruitment Data); and (v) LinkedIn (Identity and Contact Data, Workplace Location Data, Recruitment Data and Education Data).

Purposes of Processing

We need all of the categories of personal data detailed above primarily to enable us to take steps at your request prior to entering into a contract with you and to comply with our legal obligations.

We will use the personal data we collect about you to:

Assess your application, including your skills, qualifications, and suitability for the role, including through the conduct of interviews.
Make decisions about your selection, recruitment or appointment.
Conduct criminal records checks and other background and reference checks, in each case where applicable, if you are offered a role.
Check that you are legally entitled to work in the US.
Decide the terms on which you work for us.
Decide whether your engagement is deemed employment for certain purposes.
Communicate with you about the recruitment process, including through offer letters or rejection letters.
Create and maintain records related to the application and recruitment process.
Consider whether any appropriate adjustments in respect of any health condition are required during the recruitment process, for example whether adjustments need to be made during an interview, and put in place any appropriate adjustments.
Generate a summary of background information about you using our in-house generative artificial intelligence tool, (“Crowell AI”) for internal administrative purposes only. Such information is to be used by interviewers as part of the recruitment process (this information will be subject to human review prior to being shared with interviewers).
If you are a partner candidate, generate a first draft of a sponsorship memorandum about you using Crowell AI for internal administrative purposes only. Such memorandum is to be used to present you as a candidate to our Management Board and/or Executive Committee and (in a slightly modified form) to all partners (this information will be subject to human review prior to being shared with any of these bodies or individuals).

Appendix 2 includes further details of (i) the purposes for which we plan to use your data, and (ii) which types of personal data are used for which purpose.

Failure to Provide Personal Data

If you fail to provide certain personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for the role you apply for and you fail to provide us with relevant details, we will not be able to take your application further.

Automated Decisionmaking

While we may use automated tools to assist us in evaluating your candidacy, we do not use such tools without human involvement. Thus, such tools do not qualify as Automated Decisionmaking under applicable law as Automated Decisionmaking takes place when an electronic system uses personal data to make a decision without human involvement.

Internal Personal Data Sharing

We share your personal data internally on a “need-to-know” basis. Based on this principle, your personal data will be processed, as appropriate, by the following internal teams and individuals:

Management individuals and teams, such as office managing partners, practice group leadership and the Legal Development Committee.
Other partners.
Professional Support Teams, such as personal assistants, and the Records Team.
Compliance Functions, such as the Office of the General Counsel, the Compliance Team and the Conflicts Team.
Global HR Teams.
Global IT Teams.
Global Finance Teams and Payroll Teams.

Personal Data Sharing with Third Parties

We will also share your personal data with certain third parties, including third-party service providers, contractors, designated agents and other group entities, for the purposes of processing your application, to achieve the purposes outlined above, and/or where required by law. Access to personal data is limited to those third parties who have a business need to know. They will only process personal data on our instructions and are subject to appropriate confidentiality obligations.

Third Party Service Providers

We will share your personal data with the following categories of third-party service providers and their sub-processors for the purposes set out above:

IT services providers.
Communications platform providers.
HR services and workforce management solutions providers
Payroll and benefits services providers.
Background check services providers.

All third-party service providers and other group entities are required to take appropriate security measures to protect personal data in line with our policies and to process it in accordance with applicable law. Third-party service providers are not permitted to use your personal data for their own purposes and may only process such data for specified purposes in accordance with our instructions.

Other Crowell & Moring Entities

We will share your personal data with other Crowell & Moring entities: (i) as part of our regular reporting activities on company performance; (ii) for business reorganisation or restructuring exercises; (iii) for system maintenance support and hosting of data; and (iv) where required, as part of our regular communications with other Crowell & Moring entities, (e.g., by email).

Other Third Parties

We may share your personal data with other relevant third parties, for example in the context of the possible sale or restructuring of the business but will share anonymised data prior to completion to the extent possible. Post completion, we will share your personal data with the other parties to the extent required under the terms of the transaction. We may also need to share your personal data with a regulator or to otherwise comply with the law.

Data Retention

We will retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including to satisfy any legal, accounting or reporting requirements.

We will retain your personal data on file, including your application, and we may use this data to consider you for opportunities that may arise in future. If you do not wish to be considered for future opportunities and would like to opt out, please notify our Privacy Officer at dataprivacy@crowell.com.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you , and we may use that data without further notice to you.

Rights In Your Personal Data

Under certain circumstances, by law you have the right to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party.

If you want to exercise any of these rights in respect of your personal data, please contact us as set out in the “How to Contact Us” section of this notice below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the data (or to exercise any of your other rights).

Right to Withdraw Consent

If you have provided consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To do so, please contact us as set out in the “How to Contact Us” section below. Once we receive notification that you have withdrawn consent, we will no longer process your data for the purpose originally agreed to, unless we have another lawful basis for doing so and, subject to our Personal Data Retention Policy, we will dispose of your personal data securely.

How to Contact Us

If you have any questions or complaints about this privacy notice or how we handle your personal data, please contact our Privacy Officer at dataprivacy@crowell.com. You can also contact us by sending a letter to the following address:

Privacy Officer Crowell & Moring LLP
1001 Pennsylvania Ave. NW Washington, DC 20004-2595

Changes to This Privacy Notice

We reserve the right to update this privacy notice at any time. The current notice will be available on our website at www.crowell.com/en/US-Candidate-Privacy-Notice.

Additional Privacy Notice for California Residents

Firm Personnel who are residents of California may have certain additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and as set out in the accompanying regulations (collectively, the “CCPA”). For the purposes of this section, Personal Data has the meaning given to it in the CCPA.

This Privacy Notice describes the Personal Data we collect or process about candidates who are California residents in connection with their employment application, as well as how we use, share, and protect that Personal Data. This Privacy Notice also outlines the rights you have with respect to such Personal Data that we collect or process.

Supplemental Disclosures for Purposes of the CCPA:

In the past 12 months, we have collected Personal Data discussed above in section 2 and Appendix 1. The chart below sets forth the categories of third parties to which we disclosed Personal Data for our business purposes within the preceding 12 months.

Please note that some of this Personal Data qualifies as Sensitive Personal Data under the CCPA. Specifically, in the past 12 months, we may have collected and/or disclosed the following categories of Sensitive Personal Data:

Social security number, driver’s license number, state identification card, passport number;
Financial account information; and
Racial or ethnic origin.

We do not use or disclose Sensitive Personal Data for purposes other than that which is necessary and proportionate to accomplish the objectives set forth in Cal. Code Regs. Tit. 11, §7027(m).

Crowell & Moring also does not sell or share Personal Data as those terms are defined by the CCPA.

Your CCPA Rights (in addition to the rights already outlined in this Notice)

Right to Disclosure of Information: You have the right to request that we disclose certain information regarding our practices with respect to Personal Data. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction as required by the CCPA:

The categories of Personal Data we collected about you in the last 12 months.
The categories of sources from which we collected Personal Data about you in the last 12 months.
Our business or commercial purpose for collecting Personal Data.
The categories of Personal Data we disclosed for a business purpose.
The categories of third parties to which we disclosed Personal Data.
The specific pieces of Personal Data we collected about you.

Right to Non-Discrimination: You have the right not to be discriminated against for the exercise of your California privacy rights described above.

How to Exercise These Rights

If you wish to submit a request to exercise one or more of the rights listed above, you can do so by emailing us at dataprivacy@crowell.com.

Please include your questions or concerns in your email to us. We will respond to verified requests for disclosure or deletion of Personal Data free of charge, within 45 days of receipt.

In order to protect your privacy and the security of your information, we verify consumer requests by requesting identification documents and other documentation necessary to confirm your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent. In addition, we may require the individual on whose behalf you are making the request to verify their own identity or your permission to submit the request.

Appendix 1

We will collect, store, and use the following categories of personal data about you:

Personal identification and contact details such as name, salutation or title, role, home address, work address, telephone numbers (including personal, work and mobile) and email addresses (including personal and work), (“Identity and Contact Data”).
Information about your age, race, sex, citizenship, marital status, medical condition, veteran or military status, physical or mental disability, and pregnancy or childbirth and related medical conditions (“Demographic Information”).
Social security number (“Government Identification Information”).
Date of birth, (“Date of Birth Data”).
Insurance Data, (“Insurance Data”).
Salary, annual leave, pension and benefits information and details of professional expenses, (“ Salary and Benefits Data”).
Start date and, if different, the date of your continuous employment, (“Employment Commencement Data”).
Location of employment or workplace, (“Workplace Location Data”).
Passport number, driver’s license number, and/or state identification number (“Verification Data”).
Recruitment information (including copies of right to work documentation, references, information and submissions from recruitment consultants and head-hunters, areas of expertise and practice profiles, evaluation data, offer letters, sponsorship memoranda, information included in website biographies, professional information included on LinkedIn, information included in business plans, information included in feedback from interviewers, details of the names and relationships of candidates’ relatives who have a relationship with Crowell and other information included in a CV or cover letter, or obtained as part of the application or interview process (including information included in feedback from interviewers)), (“Recruitment Data”).
Data collected in connection with the Lateral Partner Questionnaire, (“Lateral Partner Questionnaire Data”).
Employment records (including job titles, work history, working hours, holidays, training records, professional memberships), (“Employment Data”).

Compensation history, (“Compensation Data”).
Bank account information (“Financial Information”)
Results of employment status checks, other background checks and details of your interest in and connection with the intermediary through which your services are supplied, (“Background Data”).

Education-related data (including details of academic institutions attended and qualifications, professional qualifications and grades obtained), (“Education Data”).

Appendix 2

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your persona l data.

Purpose/Use	Type of Data
Assessing candidates’ applications, including skills, qualifications and suitability for the role they have applied for, including through the conduct of interviews.	Identity and Contact Data; Recruitment Data; Verification Data; Education Data; Background Data; and Lateral Partner Questionnaire Data
Making decisions about candidates’ selection, recruitment or appointment (regarding solicited and unsolicited applications), including through the internal approvals process, the partner hire process, if relevant, (including completion of the Lateral Partner Questionnaire, if applicable and sponsorship memoranda) and the issuing of offer and rejection letters.	Identity and Contact Data; Recruitment Data; Verification Data; Education Data; Background Data; and Lateral Partner Questionnaire Data
Conducting criminal records checks and other background and reference checks, in each case where applicable, if candidates are offered roles.	Personal Data Identity and Contact Data; Date of Birth Data; Recruitment Data; Verification Data; and Background Data Criminal History Data Criminal History Data
Checking that candidates are legally entitled to work in the U.S.	Identity and Contact Data; Date of Birth Data; Insurance Data; Employment Commencement Data; Workplace Location Data; Verification Data; and Background Data
Determining the terms on which candidates work for us.	Identity and Contact Data; Employment Commencement Data; Workplace Location Data; Recruitment Data; Lateral Partner Questionnaire Data; Background Data; and Education Data
Communicating and corresponding with candidates in respect of the recruitment process.	Identity and Contact Data; Recruitment Data; Verification Data; Education Data; Background Data; and Lateral Partner Questionnaire Data
Creating and maintaining records in respect of the application and recruitment process.	Personal Data Identity and Contact Data; Date of Birth Data; Employment Commencement Data; Workplace Location Data; Salary and Benefits Data; Insurance Data; Recruitment Data; Verification Data; Education Data; Background Data; and Lateral Partner Questionnaire Data Criminal History Data Criminal History Data
Considering whether any appropriate adjustments are required during the recruitment process, (e.g. whether adjustments need to be made during an interview) and implementing any appropriate adjustments.	Personal Data ID and Contact Data and Workplace Location Data Special Category Data Reasonable Adjustment Data
Generating summaries of background information about candidates for internal administrative purposes only, such information to be used by interviewers as part of the recruitment process (where AI tools are used, this information will be subject to human review prior to being shared with interviewers).	Identity and Contact Data; Recruitment Data; Employment Data; and Education Data
Generating first drafts of sponsorship memoranda about partner candidates for internal administrative purposes only, such memoranda to be used to present candidates to the Management Board and/or Executive Committee and (in a slightly modified form) to all partners (where AI tools are used, this information will be subject to human review prior to being shared with any of these bodies or individuals).	Identity and Contact Data; Recruitment Data; Employment Data; Education Data; and Lateral Partner Questionnaire Data