Global Privacy Notice for Staff

Effective from: 1 July 2020
Last updated: 1 July 2020

Who does this Notice apply to?

This Notice applies to the United States, India and Canada for any prospective, current and former staff members (including candidates, employees, apprentices, agency workers and independent contractors) who work for, have worked for or have applied to Bright Horizons. 

A separate United Kingdom and Netherlands Privacy Notice for Staff  {hyperlink to Staff and Supplier Privacy Notice on the BH.co.uk website} applies to staff in the United Kingdom and the Netherlands.

For simplicity throughout this Notice, ‘we’, ‘us’ and ‘our’ means Bright Horizons and ‘staff’ or ’staff member’ includes employee, apprentice, agency worker or independent contractor and ’you’ or ’your’ means staff or staff member.

Who controls your personal information?

Bright Horizons Family Solutions LLC is the entity responsible for processing your personal information. Bright Horizons’ Global Privacy Officer can be contacted at dataprivacy@brighthorizons.com.   

When do we collect personal information?

There are a variety of contexts under which we will collect your personal information.

  • When you apply for a role with Bright Horizons as a prospective staff member, we will collect your personal information when:
    • You create or update an account on our job application system.
    • Your recruitment agency shares your personal information with us.
    • You provide personal information necessary for your job application.
    • You contact us for information about the role or your job application.
    • You visit any of our websites or engage with us on an app or social media.
    • We obtain personal information about you from third parties to process your job application, such as references, qualifications and criminal background checks.
  • During your on-going relationship with Bright Horizons as a staff member, we will collect your personal information when:
    • We create your Bright Horizons’ employee account and you update your information.
    • You or we complete electronic and paper forms, assessments and other documentation that processes your personal information.
    • You download or install one of our apps that processes your personal information.
    • You visit any of our websites or engage with us on an app or social media.
    • We monitor your IT use on Bright Horizons’ digital devices, technology and systems.
    • Where Bright Horizons uses your image (either as a photograph provided by you or taken by us), either internally or externally.
  • When you access Bright Horizons’ premises, we will collect your personal information when:
    • You sign into our visitor log and provide the requested information.
    •  For locations with CCTV cameras, we may take CCTV images.   

What personal information do we collect?

If you are a prospective staff member of Bright Horizons, we will collect the following categories of personal information about you:

  • All personal information that you provide to us.
  • Details of your visits to our websites, apps, and social media, as well as information we gather from the use of cookies in your web browser.  Learn more about how we use cookies and similar technologies
  • Information from third parties about your suitability for your role including, if applicable, disqualification from childcare roles, criminal background records, references and training/qualifications.
  • For locations with CCTV cameras, images may be captured.
  • Other information as necessary to process your application.
  • Sensitive personal information which could include:
    • information about your race or ethnicity; religious beliefs; sexual orientation (for equal opportunities monitoring purposes);
    • information about your health as relevant to your role; and
    •  criminal background records. 

If you are a current or former staff member, we will collect the following categories of personal information about you: 

  • All personal information that you provide to us during the course of your employment. 
  • Details of your visits to our websites, apps, and social media, as well as information gathered by the use of cookies in your web browser.  Learn more about how we use cookies and similar technologies
  • Employment records that could include, for example, compensation and benefits details, payroll records, tax status information, performance/disciplinary/grievance information, absences for sick and other types of leave, dates of employment, reason for leaving, location(s) of employment, training/qualifications and other general HR and business administrative records.
  • Information obtained through electronic means such as digital devices, swipe card records and key fob access records.
  • Photographs and biometric data. 
  • For locations with CCTV cameras, images may be captured.
  • Records of employee contractual and statutory rights.
  • References about you either given by us or obtained from third parties.
  • Information that enables us to respond to and defend legal claims or to pursue legal claims.
  • Personal information provided to us in order to meet our legal obligations. 
  • Sensitive personal information could include: 
    • information about your race or ethnicity; religious beliefs; sexual orientation, gender (for equal opportunities monitoring purposes);
    • information about health or medical conditions to manage our employment law obligations for sick leave/absences, disabilities, and suitability to perform your role;
    • occupational health advice and other information about your health as relevant to your role; and
    • criminal background record checks.

Why do we collect personal information?

We limit the collection of personal information to what’s necessary.  Below we have highlighted the main reasons for collecting your personal information:
  • Respond adequately to your requests for information.
  • Comply with laws, and government regulations/standards.
  • Comply with our contractual obligations to you.
  • Support with education, training, communication, administration, and record keeping.
  • Fulfill tax, reporting, and other financial requirements and obligations.
  • Prevent or detect unlawful acts.

How do we protect your personal information?

We utilize appropriate technical, organizational, and physical safeguards to protect your personal information we process in both physical and electronic formats. We provide adequate and appropriate data protection, privacy and security training and conduct internal periodic quality assurance audits to ensure we maintain these standards. 

However, please note that no computer system or information can ever be fully resilient against every possible hazard or risk.  We do maintain appropriate levels of security in accordance with data protection, privacy and security laws and regulations in the territories we operate and keep these under review.

You also play a valuable part in protecting the security of your personal information. You should never share with anyone your password to access any accounts that you created or which are created for you by Bright Horizons (such as your employee account details). 
When using a browser to access your account, after you have finished you should log out and exit your browser to prevent unauthorized users from returning to your account. 

If you believe that someone has improperly used your account or provided information about you that you didn’t authorize, please contact us immediately at dataprivacy@brighthorizons.com

Will this Notice change?

This Notice is subject to change in order to remain compliant with data protection and privacy laws in the territories in which we operate. We will post revisions to this Notice on our BrightWeb intranet site and application websites. Please check back periodically, especially before you provide any personal information. This Notice was last updated in July 2020.

Any Questions?

We hope this Notice has been helpful in setting out the way we process your personal information. If you have any questions that we have not covered by this Notice, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com