Bechtel Applicant Privacy Statement


1. INTRODUCTION

This careers website is operated by and on behalf of Bechtel Corporation - including its affiliates, divisions, business units and subsidiaries ("Bechtel").

Bechtel is committed to protecting the privacy of anyone who applies for employment or other engagement with Bechtel ("Applicants").

We set out below information regarding Bechtel's collection, analysis, disclosure and other use of Applicants' personal information. If you accept employment with or are otherwise engaged by Bechtel we will, of course, collect more information about you and make other uses of your information – this will be explained to you at the commencement of your employment.

2. PROCESSING OF PERSONAL DATA

What is Processing?

The term '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.

What are the Processing General Principles?

Bechtel respects the privacy rights and interests of Applicants and adheres to the following general principles when Processing Personal Data:

  • Personal Data will be Processed fairly and lawfully, in a transparent manner in relation to the relevant Applicant and in accordance with this Privacy Statement.
  • Personal Data will be collected for specified, explicit and legitimate purposes (including the purposes identified below) and not further Processed in a manner that is incompatible with those purposes.
  • Personal Data will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
  • Personal Data will be accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that Personal Data that is inaccurate, having regard to the purposes for which it is Processed, is erased or rectified without delay.
  • Personal Data will be kept in a form which permits identification of Applicants for no longer than is necessary for the purposes for which the Personal Data is Processed.
  • Personal Data will be Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

    • Legitimacy / Legal Basis of Processing

    Bechtel will not usually Process Personal Data unless it has concluded that the Processing is necessary for the purposes of legitimate interests pursued by Bechtel or a third party. Even then, it will consider whether those interests are overridden, in the circumstances, by the privacy-related interests or fundamental rights and freedoms of the relevant Applicants and will not engage in the Processing if it concludes that they are.

    If Bechtel concludes that this "legitimate interests condition" is not met, Bechtel will only Process Personal Data in the following limited circumstances:

  • where the Processing is necessary for a Bechtel Company to take steps at the request of the Applicant before entering into an employment or other contract with the relevant Applicant (the "contract performance condition");
  • where the Processing is necessary for compliance with a legal obligation arising under the laws of the European Union, an European Economic Area (the “EEA”) member state, or other countries to which the relevant Bechtel Company is subject (the "legal obligation condition");
  • where the relevant Applicant has given specific, freely given, informed and unambiguous consent to the Processing of their Personal Data for one or more specific purposes;
  • where the Processing is necessary to protect the vital interests of an Applicant or another natural person; or
  • where the Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the relevant Bechtel Company.

    • Generally, Bechtel takes the view that its Processing of Personal Data as described in this Privacy Statement meets the legitimate interests’ condition, although it will also in some circumstances meet the contract performance condition and/or the legal obligation condition. In particular, Bechtel considers that it has a legitimate interest in pursuing the purposes set out below, and that, provided the requirements of this Privacy Statement are met, those interests will not be overridden by the privacy-related interests, rights or freedoms of Applicants.

    Bechtel does not rely on Applicants' consent to justify its Processing of Personal Data except as required by law or as discussed below or otherwise on an occasional basis, where the Processing is genuinely optional. In those circumstances, Bechtel will (i) inform the Applicant that they can withhold or subsequently withdraw their consent without suffering any adverse consequence; (ii) if consent is granted, make available a straightforward means through which the Applicant can withdraw their consent at any time; and (iii) keep an appropriate record of the consent.

    Sensitive Personal Data

    Bechtel will not usually Process Sensitive Personal Data except:

  • where necessary for the purposes of carrying out or exercising its (or an Applicant's) obligations or specific rights in the field of employment or social security or social protection law;
  • where necessary for reasons of substantial public interest, including to ensure equality of opportunity or treatment between groups of people (only ever to the extent permissible under, and subject to the specific requirements of, local law); or
  • with the explicit consent of the relevant Applicant (in those jurisdictions where consent is required to collect such data).

    Transparency

    Before Bechtel collects (or subsequently Processes) Personal Data, Bechtel will provide the relevant Applicant with the following information (unless they already have it):

  • the identity and contact details of the Bechtel Company controlling the Processing of their Personal Data (unless informed otherwise, this will be Bechtel Global Corporation);
  • the purposes of the Processing for which the Personal Data are intended;
  • the legal basis for the Processing;
  • where the Processing is justified on the basis of the legitimate interests’ condition, the relevant legitimate interests pursued by Bechtel or by a third party;
  • where Bechtel is not collecting the Personal Data directly from the Applicant but from a third party, the categories of Personal Data concerned;
  • the recipients or categories of recipients of the Personal Data, if any;
  • where applicable, the fact that Bechtel intends to transfer Personal Data to a country outside the EEA, the United Kingdom (the “UK”), or outside the country where the job is located, together with information as to:
      • (for personal data originating in the EEA or UK) whether the relevant country has been determined by the European Commission to ensure an adequate level of protection for Personal Data; or
      • (for personal data originating in other countries with data privacy laws restricting cross border transfers) whether the relevant country has laws that provide the same or more protection for personal data as the originating country;

        •     and

      • where this is not the case, and if Bechtel justifies transferring the Personal Data to that country on the basis that it has put in place adequate safeguards to protect the transferred Personal Data, the nature of those safeguards and how to obtain a copy and/or if Bechtel justifies transferring the Personal Data based on consent (in those jurisdictions where consent is a lawful basis to transfer such data);
  • the period for which the Personal Data will be stored, or if that is not possible, the criteria used to determine that period;
  • the existence of the right to request from Bechtel access to and rectification or erasure of Personal Data or restriction of Processing concerning the Applicant or to object to Processing as well as the right to data portability;
  • the right to lodge a complaint with a data protection authority;
  • where Bechtel is collecting the Personal Data directly from the Applicant, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the Applicant is obliged to provide the Personal Data and the possible consequences of failure to provide the Personal Data;

        and

  • detailed information about any automated decision-making techniques that may be used.

    Much of this information is provided in this Privacy Statement but, where necessary, Bechtel will supplement that information with specific information provided in relation to particular Processing operations.

    Bechtel will only withhold the information referred to in this Section in the limited circumstances permitted by applicable law.

    Bechtel will provide information to Applicants under this Privacy Statement in a concise, transparent, intelligible and easily accessible form – usually in writing or by electronic means.

    Profiling / Automated Decision-Making

    Profiling occurs when organisations hold data sets about individuals and make inferences about them. This occurs in organisations as they seek to evaluate candidates for recruitment; Bechtel also undertakes profiling in relation to certain of the purposes set out below. Where it does so, Bechtel employs safeguards to ensure this Privacy Statement standard is met, including restricting access to any such profiles, ensuring the relative accuracy of inferences is understood and protecting against bias.

    Bechtel does not generally make decisions having legal effects on Applicants, or similarly significantly affecting them, solely on the basis of automated processing of their Personal Data.

    3. INFORMATION COLLECTED FROM APPLICANTS

    Where do you collect information from?

    Bechtel collects information about Applicants in the course of the recruitment process. Some of this information is collected directly from you (for example, in forms that you are asked to complete, or in interviews or through the completion of tests). Other information is generated automatically when you use or otherwise interact with Bechtel's systems (for example, our website logs IP addresses, the type of operating system that your computer uses, the type of browser software you use, and the pages you access); or provided to us by third parties (for example, recruitment agencies, referees and educational institutions), including by third party service providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.

    What types of information do you collect?

    The information we collect about Applicants includes:

  • basic information about yourself, such as name, contact details and gender, image and information provided to verify your identity
  • information regarding your employment and educational history, any role or roles for which you are applying or being considered and your relevant personal interests, attributes and career aspirations and plans
  • other information about yourself that you provide in a CV or similar document
  • subject to applicable law, information collected for the purposes of diversity or equal opportunities monitoring. The types of data collected may vary across jurisdictions but may include data regarding self-identified gender, racial or ethnic origin, age, religious or other philosophical beliefs, sexual orientation and disability, etc. (“Diversity Data”)

    What is the purpose of Processing?

    Generally, you should assume that, if we ask you for information, we need it for our recruitment purposes. In some cases, we may not be able to consider your application if you cannot provide information that we request. There may be occasions where we need information to comply with a legal obligation, or conversely where provision of information is entirely optional and would not affect your application – we will let you know if this is the case.

    4. OUR USE OF YOUR INFORMATION

    How do you use the information you collect about me?

    We use Applicant information in accordance with applicable law to manage the recruitment process and assess you for employment or other engagement, to monitor and improve our recruitment processes and for related purposes (including equality of opportunity monitoring), compliance with law and regulation, ensuring the security of our business and purposes relating to legal claims made by or against us. We do not sell your personal information to any third parties.

    What happens if my application is unsuccessful?

    If you are unsuccessful in your application, we may also retain your Applicant information and use it to assess your suitability for future positions and roles within the organization (see section 5 for further details), with your consent or where required by applicable law.

    Will you ask for my consent?

    We are entitled to use, disclose and otherwise process Applicants' (and former Applicants') information as described in this notice because we need to do so for the purposes set out above. We do not rely on Applicants' consent to collect, use or otherwise process their personal information other than in exceptional circumstances where our processing is genuinely optional (for example, collection of certain information for equality of opportunity monitoring in certain jurisdictions as described in section 6)– in those circumstances we will ask for your consent if the job is located in a jurisdiction that requires consent for the information being requested.

    5. DISCLOSURE OF APPLICANT INFORMATION

    Who do you disclose my information to?

    Bechtel may disclose Applicant information, where reasonably necessary for the various purposes set out above, to:

  • recruitment agencies working with us in relation to your potential recruitment
  • other service providers processing Applicant information on our behalf in the course of supporting our business and operations
  • a person who takes over our business and assets, or relevant parts of them
  • other Bechtel entities
  • third parties to whom Bechtel is required to disclose information by law or regulatory requirement (including litigation counterparties)
  • competent regulatory and prosecuting authorities


    If you give us names of potential referees, we may disclose the fact that you are applying to work with us to them when we ask them for references.


    All of these transfers will be made only where permitted by applicable law and where Bechtel has conducted appropriate data security due diligence and obtained contractual assurances from the third party that they will treat Personal Data consistently with this Privacy Statement and applicable law.

    6. DIVERSITY DATA AND MONITORING

    Bechtel is an equal opportunity employer whose core values include a diverse, inclusive, fair, equitable and collaborative work environment. Diversity or equal opportunities monitoring – understanding the composition of our job applicant pool and workforce – is an important tool in creating such an environment. It measures how we are performing against our diversity goals and helps shape our strategy for becoming a more inclusive, bias-free workplace for all employees. Such monitoring requires Applicant and employee sharing of the relevant information needed to analyse the demographics of our applicant pool and workforce. Where permissible under local laws, the Company collects Diversity Data for the following purposes:

  • Developing a more accurate and complete picture of our applicant pool and workforce composition (reports to management will be in an aggregated and anonymized form so that individual data is not disclosed)
  • Identifying areas of under-representation or absence of equality of opportunity or treatment in our applicant pool and workforce
  • Developing strategies to attract, promote and retain individuals in under-represented groups through consideration of Diversity Data against recruitment and talent acquisition, employee engagement, retention/attrition, performance and training
  • Assessing the impact of our diversity policies and initiatives, including on recruitment
  • Identifying and removing barriers to entry and career development for under-represented individuals
  • Ensuring compliance with laws prohibiting workplace discrimination, harassment, retaliation and victimization


    There is an option for Applicants to opt out of providing this information in the application sections relating to Diversity Data. If an Applicant does not feel comfortable disclosing certain data, they can select this option. There will be no consequences for Applicants who refused to provide Bechtel with Diversity Data.


    Diversity Data will be stored securely, in a confidential manner and protected in accordance with this Privacy Statement and applicable data privacy laws. Diversity Data is transferred to Bechtel Human Resources database servers located in the United States in accordance with an Intergroup Data Processing and Transfer Agreement modelled on the EU standard contractual clauses which safeguard the integrity of the Diversity Data and the privacy rights of the applicant whom the Diversity Data concerns. Access to Diversity Data is restricted to certain of Bechtel’s personnel on a need-to-know basis, who will access the Diversity Data for the purposes set out above. The Diversity Data will be kept separately from your application and will not be seen by anyone involved in hiring decisions.


    Bechtel may share Applicant Diversity Data with third parties (see Section 5) for the purposes of collating the Diversity Data, performing analytics and reporting back to Bechtel on an aggregated and anonymised basis. Adequate contractual protections will be put in place in the agreement between Bechtel and any third party. The third party would provide the information back to Bechtel in an aggregated format, such that it no longer constitutes Personal Data at that point. This may involve sharing Applicant Diversity Data with third parties based outside of the EEA, UK or other countries with data privacy laws restricting cross border transfers, but only where appropriate safeguards have been implemented and in accordance with Section 8 below.


    Diversity Data is processed in accordance with Bechtel’s legitimate interest of identifying steps Bechtel wishes to take to promote diversity and inclusion in the workplace. Where the Diversity Data also constitutes Special Category Data in the relevant jurisdiction, the Diversity Data will be collected in accordance with the employment condition and substantial public interest condition, specifically equality of opportunity or treatment. Bechtel also process Diversity Data as necessary to comply with its legal obligations, particularly in the area of labor and employment laws.


    As access to the data is limited and the information is not shared with anyone involved in your hiring experience, please note that any information you provide in respect of any disability will not be used for the purpose of assessing any reasonable accommodations or adjustments you may need during the application process or any resulting employment. If you consider you may require reasonable accommodations or adjustments or would like to make the recruitment team aware of any disability, you will need to disclose your disability separately.


    A job applicant may request in writing to the Bechtel Chief Privacy Officer at privacy@Bechtel.com that the Company amend, delete and/or no longer process their Diversity Data. If the company receives such a request, it will promptly amend or delete the Applicant’s Diversity Data unless required by law to retain it.

    7. SECURITY AND CONFIDENTIALITY

    Bechtel is committed to taking appropriate technical, physical and organizational measures to protect Personal Data (including Sensitive Personal Data) against: unauthorized or accidental destruction, alteration or disclosure; accidental loss; unauthorized access; misuse; unlawful processing; or damage.


    These measures include equipment, application and information security, access security and training of Bechtel employees who are required to process Applicants’ Personal Data about this Privacy Statement and the appropriate Processing of Personal Data.


    Applicants who become aware of any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data should immediately notify the Bechtel Chief Privacy Officer - privacy@Bechtel.com and Security Operations Center (SOC) - soc@Bechtel.com. Bechtel will inform affected Applicants without undue delay of any such breach of security which is likely to result in a high risk to their privacy (or other rights or freedoms), providing them with appropriate information about the breach including all information required by applicable law. Bechtel may also be obliged to inform data privacy authorities of such breaches of security.

    8. INTERNATIONAL DATA TRANSFERS

    Transfers of personal information to other countries

    If your personal information is collected or processed by a Bechtel entity within the EEA, the UK, or another country with data privacy laws restricting cross border transfers of personal data, you should be aware that the disclosures described above may include transfers of your personal information to recipients outside these areas or countries, including recipients in countries (such as the United States) which do not have data privacy laws as strict as those in the EEA and the UK. Where your personal information is transferred to other Bechtel entities (including those in the United States), or to third party service providers, in countries without strict data privacy laws, the information will be protected by data transfer agreements in the appropriate form approved for this purpose by the European Commission – if you would like further information about these agreements, or to see a copy of any of them, please contact us at privacy@Bechtel.com.

    EU-US Data Privacy Framework and UK Extension to the EU-US Data Privacy Framework

    Bechtel complies with the EU-US Data Privacy Framework and the UK Extension to the EU-US Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information that is transferred from the European Union and the UK to the United States ("DPF"). Bechtel has certified to the U.S. Department of Commerce that it adheres to the DPF Principles with respect to such information ("DPF Principles").[1] To learn more about the DPF program, and to view Bechtel's certification page, please visit the Data Privacy Framework site. If there is any conflict between the terms in this privacy policy and the DPF Principles, the Principles shall govern.


    The U.S. Federal Trade Commission (“FTC”) has jurisdiction over Bechtel's compliance with the DPF, Bechtel is subject to the investigatory and enforcement powers of the FTC regarding transfers made under the DPF. Bechtel is responsible for any subsequent onward transfers of this data to third parties acting as an agent on its behalf and shall remain liable if its agent processes such personal data in a manner inconsistent with the DPF Principles (unless it is proven that Bechtel is not responsible for the event giving rise to the damage).


    Bechtel commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and UK individuals with inquiries or complaints regarding this privacy policy should first contact Bechtel at privacy@Bechtel.com


    In compliance with the DPF, Bechtel commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) regarding unresolved complaints concerning our handling of personal data received in reliance on the DPF. In the event we are unable to satisfactorily resolve your complaint, you may contact the following organizations to assist you in resolving your complaint: ICO or the EU Data Protection Authorities.


    Under certain conditions, individuals may be able to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. For more information, please visit the Data Privacy Framework ANNEX I introduction.


    9. RETENTION AND DELETION

    How long will you retain my information?

    We will retain information about you throughout the recruitment process and while your Career Opportunities account remains active with us (for three years following the last activity in the account) in case you apply to work for us again or so that we may contact you if another suitable position within the Bechtel group becomes available. You may delete your account earlier if you do not want us to retain your personal data for future job opportunities. Subject to applicable law, some information may be retained after your account is deleted, either because your application was successful and you are employed or otherwise engaged by us or, if your application is withdrawn or unsuccessful, because a recruitment-related dispute arises between us. Subject to applicable law, we will delete, anonymize, or restrict/discontinue the processing of your personal data when it is no longer needed in accordance with our policies and applicable law.


    As a general principle, we do not retain Applicant information (except in anonymized / statistical form) for longer than we need it, given the purposes for which it is held.


    You may contact Bechtel at privacy@Bechtel.com for more information on our record retention periods.


    10. RIGHTS AND QUESTIONS

    What rights do I have in respect of the information you hold about me?

    Applicants have various rights under applicable data privacy law in relation to Bechtel's Processing of their Personal Data. In particular, they can:

  • request access to their Personal Data and various other information about its Processing;
  • request that their Personal Data is corrected (if it is inaccurate) or deleted;
  • object to the Processing of their Personal Data, or (in some circumstances) require the Processing of their Personal Data to be 'restricted' (so that the data is not deleted, but its active use is suspended); and
  • in some very limited circumstances, require some of their Personal data to be 'ported' to them.


    Bechtel will honor such requests as required by applicable law. An Applicant wishing to exercise any of these rights should contact the Bechtel Chief Privacy Officer.

    Who do I contact about this notice?

    If you wish to exercise any of these rights, would like to see copies of any of the agreements referred to in section 8 or have other questions about our Applicant information processing or related policies, please contact privacy@Bechtel.com.

    Can I make complaints to the data protection authority?

    In certain jurisdictions (including in the EEA and the UK), you also have the right, at any time, to lodge a complaint about our processing of your personal information with its or your local data protection authority, for example the Information Commissioner’s Office in the UK (found at ico.org.uk). If you are unsure whether you have this right in your jurisdiction or require details of your local data protection authority, please contact privacy@Bechtel.com.

    11. CALIFORNIA CONSUMER PROTECTION ACT (“CCPA”)

    This statement applies solely to Applicants who are residents of the State of California (“California residents”) and supplements the information above describing the categories of personal information we collect, or have collected, through the job application process, the categories of sources from which personal information is collected, the purposes for which such personal information may be used, and the categories of third parties to whom personal information may be disclosed.

    Categories of Personal Information we collect

  • Identifiers. Examples include name, telephone number, postal and email addresses, IP address and other similar identifiers.
  • Internet/Network information. Examples include browsing history, search history, and information regarding your interaction with the Bechtel.com website and Careers portal.
  • Professional or employment-related information. Examples include information contained on an Applicant’s resume or CV or that an Applicant submits in a job application.
  • Education information. Examples include information contained on an Applicant’s resume or CV or that an Applicant submits in a job application.

    Sources of Personal Information

    Personal information you provide

    Bechtel collects personal information about Applicants in the course of the recruitment process when Applicants specifically and knowingly provide such information for purposes disclosed or otherwise known to them when they provide the information. This includes, for example, when you provide your resume or CV, or in forms that you are asked to complete, or in interviews or through the completion of tests to apply for a job with Bechtel.

    Automatic collection of your personal information

    Other information is generated automatically when you use or otherwise interact with Bechtel's Careers website and other systems (for example, our website logs IP addresses, the type of operating system that your computer uses, the type of browser software you use, and the pages you access) or when you visit our premises. For more information, please see the Privacy Policy on the Bechtel.com homepage.

    Collection of your personal information from third party sources

    We may also obtain information about you from third parties (for example, recruitment agencies, referees and educational institutions), including by third party service providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.

    Use of your Personal Information

    We may use the information we collect about you for the purposes set forth in Sections 4 through 6 above. We do not sell or share your personal information as those terms are defined by the CCPA.

    If you have any questions about the CCPA, please submit your question to privacy@Bechtel.com. or call 1-800-BECHTEL (1-800-232-4835).

    Your CCPA Rights

    California residents have the following rights regarding their personal information:

    Right to Delete.You have a right to request that Bechtel delete your personal information from its records and direct any service providers to delete your personal information from their records, subject to certain exceptions.
    Right to Correct. You have a right to request that Bechtel correct any inaccurate personal information that it maintains about you.
    Right to Know and Right to Access. You have a right to request that Bechtel disclose the following to you: (1) the categories and specific pieces of personal information Bechtel has collected about you; (2) the categories of sources from which your personal information is collected; (3) the business or commercial purpose for collecting your personal information; and (4) the categories of third parties to whom Bechtel discloses your personal information.
    Right to Know What Personal Information is Sold or Shared. Bechtel does not sell or share your personal information.
    Right to No Discrimination or Retaliation. Bechtel will not discriminate or retaliate against you for exercising your CCPA rights.
    To exercise any of these rights, please submit a request to privacy@Bechtel.com or call 1-800-BECHTEL (1-800-232-4835). You must describe your request with enough detail so we can understand and respond to it. A verifiable consumer request under the CCPA is one made by an individual who is: (i) the consumer who is the subject of the request; (ii) a consumer on behalf of the consumer’s minor child, or (iii) by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer. We may request that you provide us with information to verify your identity and/or authority to act on behalf of a consumer. Personal information collected to determine whether your request is a verifiable consumer request will not be used for any other purpose. We will respond to your request within 45 days of its receipt, unless we notify you that we need more time.

    Updated April 2024

    [1]In addition to Bechtel Corporation, the following other Bechtel companies adhere to the DPA Principles: American Bechtel, Inc.; Bechtel Energy, Inc.; Bechtel Energy Technologies & Solutions, Inc.; Bechtel Enterprises, Inc.; Bechtel Equipment Operations, Inc.; Bechtel Global Corporation; Bechtel Global Services, Inc.; Bechtel Group, Inc.; Bechtel Infrastructure and Power Corporation; Bechtel Infrastructure Corporation; Bechtel International Systems, Inc.; Bechtel International, Inc.; Bechtel Manufacturing & Technology, Inc.; Bechtel Mining & Metals, Inc.; Bechtel National, Inc.; Bechtel Power Corporation; Bechtel Supplier Quality and Expediting Inc.; and BNT International Corporation.


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