Last Updated 8/7/2020

Axon respects the privacy rights of individuals and is committed to handling Personal Data responsibly and in accordance with applicable law. Axon is a Personal Data Controller. This means that we are responsible for deciding how we hold and use Personal Data about you. This Privacy Policy (“Policy”) describes how Axon Enterprise, Inc. and its group companies (“Axon“, “we,” “us” or “our“) collect and use Personal Data about you during and after the recruitment process, and the rights you have in connection with that data. It is important that you read all of this Policy carefully. 

Axon may occasionally update this Policy. When Axon posts changes, Axon will revise the "last updated" date at the top of this page. 

This Policy applies to anyone who (whether on a permanent or non-permanent basis): (1) applied for a job role; or (2) who otherwise seeks to work with or for us; or (3) who otherwise was previously or is currently being considered for a job role.

DEFINITIONS

• “Candidate” means anyone who (whether on a permanent or non-permanent basis): (1) applies for a job role; or (2) who otherwise seeks to work with or for us; or (3) who is being considered for a job role.
• “Data Controller” means the natural or legal person, public authority, or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data (as defined below).
• “Data Processor” means a natural or legal person, public authority or any other body which processes Personal Data on behalf of the Data Controller.
• “Data Exporter” means the Data Controller who transfers the Personal Data.
• “Data Importer” means the Data Processor who agrees to receive from the Data Exporter Personal Data intended for processing on Data Exporter's behalf after the transfer in accordance with the Agreement and who is not subject to a third country’s system ensuring adequate protection within the meaning of the General Data Protection Regulation (EU) 2016/679 of the European Parliament (“GDPR”)
• “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Sub-processor” means any processor engaged by the Data Importer or by any other sub-processor of the Data Importer who agrees to receive from the Data Importer or from any other sub-processor of the Data Importer Personal Data exclusively intended for processing activities to be carried out on behalf of the Data Exporter after the transfer in accordance with its instructions, the terms of the Clauses and the terms of the written subcontract.

WHAT PERSONAL DATA WE COLLECT

Axon collects and processes the following types of Personal Data about you in connection with our recruitment process.

• Contact details: such as your name, home address, email address, phone number;
• Information relating to your career: such as job history, academic background, qualifications, professional and personal competencies and skills, your job expectations;
• Where permitted, information about your history of remuneration & benefits and your salary expectations;
• Information relating to your employment references; 
• Information collected as part of the hiring process such as assessments and aptitude tests;
• Identification information, as part of the pre-hiring process: such as copies of identification documents, immigration status;
• Your video in case you conduct your interview using a tele-conferencing tool such as Zoom;
• Details of your visits to our Website including, but not limited to, traffic data, location data, the site that referred you to Axon’s Website and the resources that you access.; and
• Any other information you submit to us as part of the recruitment process.

Where permitted, we may also collect, store and use the following special categories of more sensitive personal data, which could include:

• Information about whether or not you have a disability for which we need to make reasonable adjustments as part of the recruitment process; 
• Information about criminal convictions and offences (where the nature of the job requires this); and
• Information concerning your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws or for government reporting obligations

HOW YOUR PERSONAL DATA IS COLLECTED

Personal Data may be collected in different ways: 

• It may be contained in your CVs or resumes, in your application form, your identification documents, or may be gathered from interviews or assessments you take during the recruitment process;
• In some cases, it may also be collected from third parties, for example from colleges for recruitment purposes or when seeking employment references or if we receive details of a certification or training you obtained;
• We may also receive your CVs or resumes from recruiters and the results of verification and vetting checks from background checking providers; and
• As part of our talent sourcing program, we often obtain your contact details and profile from various databases, Resume Books, LinkedIn, Social Media, or other available professional networking platforms or directories – some publicly available and others not. 

HOW YOUR PERSONAL DATA IS USED

Axon will use your Personal Data for the following purposes:

• Recruitment, selection, evaluation and appointment of job candidates (temporary or permanent) for the job for which you have applied;
• Communicate with you and to inform you of current status of your application and future opportunities (unless you have told us that you do not want us to keep your information for such purposes);
• General HR administration and management (in case you become an Axon employee);
• Carrying out satisfaction surveys (for example, to manage and improve the recruitment process);
• Application analysis such as verification of your employment reference(s) that you have provided, background checks and related assessments; and
• Compliance with corporate governance and legal requirements (for example, to monitor diversity requirements).

LEGAL BASIS UNDER WHICH WE PROCESS YOUR PERSONAL DATA 

If you are an individual in the European Economic Area, and Switzerland (“EEA”) or United Kingdom (“UK”), our legal basis for the collection and processing of your Personal Data is as follows:

• Axon’s legitimate interests, namely the recruitment, selection, evaluation and appointment of new employees and the management and administration of the recruitment and HR process, to the extent these activities do not prejudice or harm your rights and freedoms.
• Compliance with Axon’s legal obligations where employment law or other laws require the processing of your Personal Data (for example to the extent the law requires monitoring diversity requirements).
• Other legal grounds where applicable such as in your vital interests (for example, health and safety reasons if you attend an interview at our site).
• On your consent, when we ask you if you wish to hear about other jobs that maybe of interest to you, or when we process special categories of more sensitive personal data such as race, gender, and disability.   

AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

WITH WHOM WE SHARE PERSONAL DATA

We will disclose your Personal Data to the following types of entities or in the following circumstances (where applicable):

• Internally: to other Axon personnel involved in the recruiting and hiring processes;
• Service Providers: in order to administer services during the Axon hiring process. These service providers include technology service providers, travel management providers, human resources suppliers, background check companies, and employment agencies or recruiters, where applicable;
• Legal Compliance: when required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency;
• Litigation Purposes: to seek legal advice from our external lawyers or in connection with litigation with a third party;
• Business Transaction Purposes: in connection with a sale, purchase, or merger; and
• Where we have otherwise obtained your consent.

DATA RETENTION

Axon retains data for the duration of your recruitment and for a period of time thereafter to allow Axon, to analyze the data for Axon’s own operations, for historical/archiving, and as required by law. For more information on where and how long your Personal Data is stored, please contact us at recruitingops@axon.com. 

If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your personal file and retained during your employment. The periods for which your data will be held will be in accordance with the retention period applicable to employees. 

DATA SECURITY MEASURES

Axon is committed to help protect the security of your Personal Data. Axon has established and implemented policies, programs, and procedures that are commercially reasonable and in compliance with applicable industry practices, including administrative, technical and physical safeguards to protect the confidentiality, integrity and security of Personal Data against unauthorized access, use, modification, disclosure or other misuse.

Axon will take appropriate steps to ensure compliance with the data security measures by its employees, contractors and Sub-processors, to the extent applicable to the respective scope of performance.

INTERNATIONAL TRANSFERS

Your Personal Data will be stored in a range of different places, including in our recruitment files, in our HR system, and in other IT systems (including email systems).

Your Personal Data may also be transferred to other Axon companies, branches and service providers, including outside the EU and the UK and/or Switzerland and will be stored and processed manually and electronically through global systems and tools for the recruitment purposes described above.  Axon has appropriate safeguards in place to protect your Personal Data. These protections include, where applicable:

• EU standard contractual clauses.
• Axon may also rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Axon collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you or implementation of pre-contractual measures

To obtain a copy of the document being used to protect your Personal Data, please contact us using the information in the Contact Us section below.

YOUR RIGHTS

As a data subject, you have a number of rights. You can: 

• Access and obtain a copy of your data on request;
• Require Axon to change incorrect or incomplete data;
• Require Axon to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• Object to the processing of your data where Axon is relying on its legitimate interests as the legal ground for processing.
• Withdraw your consent in circumstances where consent is the legal basis for processing, for example if you no longer wish to hear about other jobs that maybe of interest to you.   

If you would like to exercise any of these rights or have any questions, please contact our Human Resources Department at recruitingops@axon.com. 

If you believe that Axon has not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner (“ICO”). Contact details for the ICO can be found at https://ico.org.uk/.

IF YOU CHOOSE NOT TO PROVIDE PERSONAL DATA 

You are under no statutory or contractual obligation to provide Personal Data to Axon during the recruitment process.  However, if you fail to provide Personal Data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further

HOW TO CONTACT US

Axon commits to resolve complaints about privacy. Complaints surrounding this Policy can be directed to your local Axon recruitment representative or privacy@axon.com. If you have any questions or concerns regarding privacy and security of your personal data, please contact privacy@axon.com.