WK Kellogg Co Applicant Privacy Notice

Last Updated: August 28, 2023

This Job Applicant Privacy Notice (“Notice”) applies to the Personal Information that WK Kellogg Co and our subsidiaries and affiliates located worldwide (collectively “Company”, “WKKC”, “we”, “our”, or “us”) collect about individuals in our job application process, including our careers websites (and ) (“Applicants”).

Please note that certain regions or countries may have a regional country addendum, or related notice, policy, or document, to this Notice. See below.

“Personal Information” means any information that can identify you, including personal data. In some cases (as prescribed by applicable privacy laws), Personal Information does not include de-identified Information or publicly available information. We use Personal Information in a number of ways, as described in this Notice.

WK Kellogg Co, based in the United States, is the primary controller of your Personal Information for the purposes of administering your application. Further decisions regarding the processing of your Personal Information will depend on your location; for example, if you are applying for a job in Canada, the relevant local WKKC entity that has advertised the vacancy will be a separate data controller for purposes of considering your application and ultimate hiring decisions. Depending on the jobs you indicate you wish to apply for, WKKC will transfer your data to the relevant local entities who will process your data independently.

If you are a WKKC customer or consumer, please see our WK Kellogg Co Privacy Notice, which includes information about your interaction with WKKC, our websites and other online properties. If you are a WKKC employee, please see our Global Internal Privacy Notice for additional disclosures.

1. PERSONAL INFORMATION WE COLLECT, USE, DISCLOSE, AND OTHERWISE PROCESS

We may collect, use, disclose, and otherwise process (collectively referred to as “processing” in this Notice) the following Personal Information from Applicants as permitted or required by applicable law. Please note the type of Personal Information we process may vary depending on your interaction with us.

• Contact Information, including name, postal address, email, phone, other names (nickname, alias etc.), and social media handles
• Professional and employment-related information, including work experience, educational information, qualifications, skills, references, recommendations; other information included in a resume, CV, or application form; information provided in interviews and through behavioral or other screening questions; and information contained in any personal webpages or documents you choose to share with us
• Demographic Information, including age, gender, race, nationality, disability, and veteran status
• Preferences, including location, salary, and preferred positions (such as full-time or part-time)
• Account Details, including account names, passwords, and security questions
• Content of Communications, including application submissions (such as cover letters) and communications regarding the application process, such as by email or social media messaging capabilities
• Eligibility Documentation, including proof of work authorizations, citizenship, immigration, visa status, and government identification
• Internet or other electronic network activity information, including IP address, mobile network provider, and other network related information
• Device and Mobile Location, depending on your device and app settings, we also collect location data from your devices when you use our apps or online services
• New Hire and Onboarding Documentation, including background checks, tax and other government forms, and medical/drug test information‎

2. SOURCES OF PERSONAL INFORMATION

We may collect the above Personal Information about Applicants from the following sources.

• Directly from you.  We collect information from you when you visit or create a profile on our careers page, during the recruitment process and throughout your interactions with us as an Applicant, including through our information technology systems; company forms and processes where Applicants submit information to us (such as pre-employment forms); and surveys.
• Automatically when using our digital services or visiting our premises.  We collect Personal Information about you when you use our information technology services and when you access our facilities (such as closed-circuit images, photographs and video).
• Created by us.  We collect information about you that we create, such as interview notes, credentials for access to our recruitment systems, and inferences generated from other Personal Information we collect.
• Recruitment Agencies.  We collect information from recruitment agencies who provide your application materials and Personal Information about your candidacy.
• References and Verifications.  We collect Personal Information from third parties who provide references (such as former employers) and to verify your qualifications (such as universities or other organizations where you may have earned a degree or completed a certification).
• Public Sources.  We collect Personal Information through an internet search, your public social media presence (such as LinkedIn), or publicly available business sites (such as your current employer), and other online sources.
• Service Providers.  We collect Personal Information about you from certain service providers that provide information to help us perform recruitment functions and run our business (such as background check providers).
• Affiliates.  We receive Personal Information from our subsidiaries and affiliates located worldwide.
• Third parties.  We may receive Personal Information about you from other third parties when necessary to evaluate your candidacy or manage or operate our business.

Please refer to the Cookie Preference Center and our Privacy Notice in the footer of this webpage for details about how we collect your Personal Information through cookies and other tracking technologies when you visit our websites or other online properties.

3. USE OF PERSONAL INFORMATION

We collect, use, and disclose Applicant Personal Information for the following purposes.

• Recruiting and Applicant Management.  We use your Personal Information to open and maintain your application records; assess your eligibility for employment; communicate with you regarding your application and the recruitment process; and support our recruitment and diversity, equity, and inclusion programs and initiatives.
• Accommodations.  We may use your Personal Information to provide accommodations for your disability or health condition during the recruitment process (such as determining location for interviews).
• Work Authorization.  We may process your Personal Information to confirm your right to work in the relevant locality, whether Applicants are named on any restricted party listings, including Sanctions lists, and to fulfill other screening requirements based on the role applied for and location of the position.
• New Hire Onboarding.  If you are extended an offer of employment, we may  use your Personal Information to perform background checks (as permitted or required by applicable law and with additional disclosures), process your employment documentation, establish your credentials, and otherwise establish our employment relationship with you.
• Legal Obligations and Security.  We may process your Personal Information to prevent, investigate, identify, or take any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates or may violate applicable laws, regulations, or legal process and our policies.  We may process your Personal Information to comply with applicable laws, regulations, or legal processes as well as industry standards and our Company policies.
• Corporate Restructuring.  We may use your Personal Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
• Consent.  We may use your Personal Information for such other purpose you may consent to.

If you are located in the European Union or European Economic Area, the legal basis for processing your Personal Information is generally your consent in relation to taking steps to enter into a contract, reviewing your application materials, and making determinations about your suitability for employment. We may continue to process your Personal Information on the legal basis of consent to notify you about future job opportunities. Additionally, we may process your Personal Information for our legitimate interests of operating our business, meeting legal obligations, and protecting the security of our systems and personnel.

4. RETENTION OF PERSONAL INFORMATION

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. For example, in the European Union or European Economic Area, this may mean Personal Information is retained for a specific time period. This generally means holding the Personal Information for as long as one of the following apply:

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
• The Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

5. DISCLOSURE OF PERSONAL INFORMATION

We may disclose Applicant Personal Information with your consent; when you direct us to share it with others; to manage the recruitment process; or as otherwise necessary to operate our business, comply with our legal obligations, and protect the security of our systems and personnel. We may disclose your Personal Information for the purposes above to the following entities and individuals.

• Service Providers.  We disclose your Personal Information to service providers that help us perform recruitment functions and run our business (such as Oracle, who hosts our careers site). We ensure that all such service providers process Applicant Personal Information strictly under the terms of an existing contract and apply appropriate safeguards to protect your information
• Recruitment agencies, references, and verifications.  We may disclose Personal Information about you when we request information from recruitment agencies, individual references, and other parties that provide information related to your candidacy.
• Law enforcement agencies, courts, regulatory agencies, and other government agencies.  We may disclose your Personal Information to comply with reporting obligations (such as anti‐discrimination laws), legal processes (such as a court order or subpoena) or other legal requirements of any governmental authority, in connection with threatened or actual litigation, to protect our legal rights or property, to protect the legal rights or property or physical security of others, or for the prevention or detection of crime and such disclosure is lawful.
• Parties to corporate transactions.  As permitted by law, we may disclose your Personal Information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of a business or assets.
• To other countries as required by law described below in Section 10 Transfer Of Your Personal Information To Other Countries.

6. CHILDREN'S PRIVACY

We do not knowingly request or collect Personal Information from any person under 16 years of age through our application process. If we learn that we have received information directly from a child who is under the age of 16, we will delete the information in accordance with applicable law. In some jurisdictions, children are considered under the age of 18. In those jurisdictions, we do not knowingly request or collect Personal Information from any person under the age of 18 though our application process and if we learn we have received information directly from an individual under the age of 18 in those jurisdictions, we will delete the information in accordance with applicable law.

7. SECURITY

We strive to maintain appropriate administrative, technical, and physical safeguards that are designed to help protect Personal Information collected or received through our websites. Although we follow reasonable procedures to safeguard information, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect. You use our websites and provide us with your information at your own risk.

We implement security measures to protect your Personal Information, such as Captchas and Multi-Factor Authentication. In some cases, Personal Information may be required to implement these measures.

8. YOUR CHOICES

You can access, edit, or delete some of the Personal Information we have collected by logging into your account and accessing the information displayed in your profile or account settings by signing into your  Account.

A. Your Choices Generally.

Subject to applicable laws in your jurisdiction, and our data retention policies, we provide choices related to your Personal Information. You may make a request regarding your privacy rights through our privacy portal or contact us as described in the Contact Us section of this Notice.

Under applicable law and depending on the sensitivity of the Personal Information, we may need to verify your identity and the validity of the request before fulfilling your request. This may require you to provide your name, email address, and a government ID that we will match against our records to verify your identity.

In general, you may withdraw your consent to the use or disclosure of your Personal Information collected by us and may have the right to request that your Personal Information no longer be disseminated or processed. This may affect the services we provide to you and/or our ability to engage with you.

Under certain circumstances, we may not be able to fulfill your request, depending on the type of Personal Information and the nature of the request (for example, certain information about purchases you make must be kept for a specific period of time for our auditors and reporting obligations). We may process and store some of your Personal Information in a manner where it can no longer be used to identify you and, in these circumstances, we will not include such information in response to the request. In certain jurisdictions, such as the U.S., applicable law may require or permit us to decline your request. For example, without limitation, where the Personal Information is not maintained in a searchable or reasonably accessible format or we maintain the Personal Information solely for legal or compliance purposes. If we decline your request, we will tell you why, subject to legal restrictions. We will comply with all applicable legal requirements related to your request.

B. Access and Portability.

Subject to applicable law, you may have the option to access your Personal Information, including information about the categories and types of Personal Information we process, who we share your Personal Information with, and the specific Personal Information we maintain. You may be able to access this information through a registered account, if applicable. Additionally, subject to applicable law, you may be able to request a machine-readable copy of your Personal Information to you or an external party of your choice.

C. Revisions to Your Personal Information.

Subject to applicable law, you may have the option to revise (or request corrections to) your Personal Information to ensure its accuracy, such as when you are logged into a registered account through your account or profile settings or preferences.

D. Deletion.

Subject to applicable law, you may request that we delete your Personal Information. Once we receive and confirm your request, we will assess it and implement any deletion or erasure request we may be required to complete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Under some circumstances we may not be able to delete your Personal Information because we are required to keep it for other purposes, including to complete transactions and provide services you have requested or that are reasonably anticipated; for security purposes; for legitimate purposes, including maintaining business records; to comply with applicable laws and regulations; to exercise or defend legal claims; and to cooperate with law enforcement.

E. Non-Discrimination Rights.

We will not discriminate against you for exercising any of your privacy rights under applicable law.

F. Complaints

You have the right to submit a complaint with the applicable regulatory authority in your jurisdiction regarding the management of your Personal Information.

9. GLOBAL DISCLOSURES

A. European Union and European Economic Area Privacy Rights

If you are located in the European Union or European Economic Area,  WKKC will transfer your Personal Information to the relevant WKKC entity advertising the open position you have applied for. In such circumstances, local entities process your Personal Information as independent data controllers. You have certain rights regarding your Personal Information, which can be exercised through our privacy portal or by contacting us at.

Where we are processing your Personal Information based on your consent, you have the right to revoke your consent at any time. Any Personal Information we continue to hold on this basis will then be deleted.

You also have the following rights:

• The right to access your Personal Information held by us
• The right to the erasure of your Personal Information in certain circumstances
• The right to have any Personal Information we hold rectified if it is incorrect
• The right to apply for a restriction of the processing of your Personal Information in certain circumstances
• The right to object to the processing of your Personal Information in certain circumstances
• The right to portability of your Personal Information

You also have the right to lodge a complaint with the data protection supervisory authority.

B. California Privacy Disclosures and Rights

WK Kellogg Co, our subsidiaries, and our affiliates (collectively, “WKKC”) provides this California Applicant Privacy Notice (“California  Notice”) to explain our practices regarding the Personal Information we collect about California Applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”).

Unless otherwise noted, the information below that describes how and why we collect, use, and disclose your information also describes how we have collected, used, and disclosed information in the preceding twelve (12) months.

In the event of a conflict between any other policy, notice, or statement and this California Notice, this California Notice will control as to California Applicants.

Personal Information We Collect, Use, and Disclose for Business Purposes

Under the CCPA, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

We collect, use, and/or disclose the following categories of Personal Information about California Applicants from the sources described in the Sources of Information section above. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all the examples listed below.

• Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, passport number, or other similar identifiers
• Personal Information described in Cal. Civ. Code § 1798.80(e), including name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, and employment history
• Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements
• Geolocation data, including location data inferred from your device IP address
• Audio, electronic, visual, thermal, olfactory, or similar information, including closed-circuit images, photographs and video of you, and audio recordings as may relate to your application
• Professional or employment-related information, including skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; answers to behavioral or other screening questions in an application or interview; information contained in any personal webpages or documents you choose to share with us; Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; and information relating to membership in civic organizations
• Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education
• Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Sensitive Personal Information, including Social Security, driver’s license, state identification card, or passport number; account log-in, in combination with any required security or access code, password, or credentials allowing access to an account; Personal Information that reveals an Applicant’s racial or ethnic origin, religious or philosophical beliefs, or union membership; Personal Information collected and analyzed concerning a Applicant’s health (i.e., drug-screening information); and Personal Information collected and analyzed concerning a Applicant’s sex life or sexual orientation

We collect, use, and disclose for business purposes the above categories of Personal Information as described in the Personal Information We Collect, Use, Disclose, and Otherwise Process and Disclosure of Information sections above. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

We retain the above categories of Personal Information as described in the Retention of Information section above.

How We Share and Sell Personal Information

We do not sell or share for cross-context behavioral advertising, and within the past twelve (12) months, have not sold or shared for cross-context behavioral advertising the Personal Information of California residents that we collect in relation to applications for employment at WKKC. If you also interact with us as a consumer, please review the California Section of our  U.S. Privacy Notice  for more information about our practices in that context. We do not have actual knowledge that we sell or share the Personal Information of consumers or Applicants under 16 years of age.

Your California Privacy Rights

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through our Privacy Portal or call us at 1- 800-962-1413 (9a.m. -6p.m. ET). Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to provide a name, email address, and a government ID that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using our Privacy Portal or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

(1) The categories of Personal Information we have collected about you, including:

1. The categories of sources from which the Personal Information was collected.

2. Our business or commercial purposes for collecting, selling, sharing, or disclosing Personal Information.

3. The categories of recipients to which we disclose Personal Information.

4. The categories of Personal Information that we sold¹ or shared, and for each category identified, the categories of third parties to which we sold or shared that particular category of Personal Information.

5. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

6. The specific pieces of Personal Information we have collected about you.

(2) The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Personal Information. If you believe the Personal Information we maintain about you is inaccurate, you have the right to request that we correct such information.

Right to Opt-Out of Sales of your Personal Information. We do not Sell or Share the Personal Information of California Applicants, as defined by the CCPA. For this reason, this right is not applicable.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA. For this reason, this right is not applicable.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we may use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Because we do not use automated decision-making to evaluate Applicants, this right is not applicable.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

10. TRANSFER OF YOUR PERSONAL INFORMATION TO OTHER COUNTRIES

As a global entity, your Personal Information is typically stored in the United States and, where you apply for a position, the relevant country where the WKKC entity advertising it is based. These transfers may be to other Company entities or external data processors. If your Personal Information is transferred and processed elsewhere, we take steps to process such information in a lawful manner under applicable law, such as our instructions for the stated purposes under the terms of an agreement.

Please be aware that the data protection laws and regulations that apply to your Personal Information transferred to the United States or other countries may be different from the laws in your country of residence and different standards may apply to how your Personal Information is used and protected. We use appropriate safeguards in accordance with applicable legal requirements to ensure that Personal Information is adequately protected. Where applicable, we may use standard contractual clauses to safeguard your Personal Information, including the European Union approved Standard Contractual Clauses.

11. CONTACT US

If you have any questions or comments about this Notice, please contact us at HRDataPrivacy@wkkellogg.com.

Phone: 1-800-962-1413 (9a.m. - 6p.m. ET)

Postal Address:  WK Kellogg Co, Attention: Consumer Affairs – Privacy Office, 1 Kellogg Square, North Tower, Battle Creek, MI 49016

If you are located in the European Economic Area, European Union, or United Kingdom, you may contact us at the information provided above in Section 9 Global Disclosures to exercise your rights, or you can make a request regarding through our  Privacy Portal.

¹ We only “sell” Personal Information to third parties as defined in the CCPA for the purposes of cookies or other tracking technologies.