Candidate Privacy Notice

This notice provides information on how FreshBooks processes personal information that it receives when you apply for a position, are referred as a candidate or are being considered for a role at FreshBooks.

1. Which FreshBooks entity is responsible for your personal information

The FreshBooks entity responsible for your personal information is the FreshBooks entity that would be responsible for your employment if you receive an offer. Please see the bottom of this notice for information about each entity.

2. What information we collect about you

2.1 INFORMATION YOU PROVIDE

This policy covers the types of personal information that FreshBooks may collect directly from you (which may include sensitive personal information, depending on the jurisdiction where you reside) which includes the following: 

Type of Information we collect	Example
Contact Information	Name, postal address, email address, and telephone number.
Other personal information	Date of Birth, nationality (except in Croatia), gender.
Recruitment information	Copy of resume or CV, references from previous employers, cover letter, details of professional accomplishments, current or previous roles, copy of education degrees or certificates obtained, university or other educational institution transcripts, and membership in professional bodies.
Preferences	Your preferences in respect of being contacted in the future regarding other job positions, which may be of interest to you.
Interview information	Any information that you provide during interviews.
Any special needs or information relating to accommodations and/or assistance	For example: Auditory or visual assistance needs; physical assistance requirements.

Please be informed that, without providing the personal information mentioned above, we are not able to assess your job application and we are not able to conclude an employment agreement with you.

2.2 INFORMATION FRESHBOOKS MAY COLLECT FROM OTHER SOURCES

FreshBooks may collect the following information from third parties (which may include sensitive personal information, depending on the jurisdiction where you reside)  as follows:

Type of Information we collect	Example	Source
Background Check Information, to the extent allowed by statutory law	Previous employment, criminal history.	Law enforcement agencies, educational institutions, third-party service providers, and social media or other online platforms where you have a publicly accessible profile.
When voluntarily supplied to a third party by the Candidate, Contact Information, Employment History, Education History	Candidate’s resume, recruiters’ notes from initial interview with a Candidate.	Recruitment agencies, LinkedIn
Information that is publicly available, such as work experience information and other data online	Work experience information and other information, such as your activity on professional or personal social media accounts or other sites that are publicly accessible.	Public-facing sites, such as LinkedIn
Referral information	If you’re being referred, we process information that the person referring you provides about you.	Referrer

2.3 INFORMATION FRESHBOOKS COLLECTS FROM CANDIDATES

If your application is successful, we also process the following personal data in addition to the personal data as specified in our internal privacy notice:

Type of Information	How we use it	Lawful basis
Contact information, physical address	To arrange to send a laptop and/or mobile phone to a Candidate prior to their first day.	The execution of the prospective employment agreement.
Information on Right to Work in Country of Hire	Copy of passport and/or other national identity documents, government identification number, work authorization documents, or visas, only to the extent required by statutory law in Country of Hire.	In order to comply with statutory requirements to which we are subject.

3. How do we use this information?

In general, and subject to applicable law, we may use your personal information for purposes linked to assessing your suitability for the role. The table below outlines what information is processed, the operational purposes for which FreshBooks processes your personal information, and the lawful basis for processing.

Type of Information	How we use it	Lawful basis
Contact Information, Information on Right to Work in Country of Hire, Preferences.	To communicate with you during the recruitment process; To communicate with you in relation to open role positions which may be of Interest to you (with your consent); To verify employment authorization/eligibility in the country of hire.	Pre-contractual necessity;  Legitimate Interest in communicating with potential candidates/communicating new opportunities to potential candidates; Compliance with a legal obligation (i.e., to ensure an employee has the right to work under applicable laws).
Contact Information, Employment History, Information on Right to Work in Country of Hire, Education History.	To evaluate your attributes, qualifications and skills to determine if you are eligible for the role; To prepare for interviews or screening discussions	Legitimate Interest in determining the skills and qualifications of a candidate or identifying candidates qualified for open roles.
Contact Information.	To conduct a reference check where lawful to do so.	Legitimate Interests in conducting reference checks to assess suitability of candidate for a role (or consent to the extent legally required).
Contact Information, Date of Birth, Education History, and any information or activity on social media profiles that are publicly accessible.	To verify identity and conduct a background check where lawful to do so and where such checks are determined to be relevant to the role.	Legitimate Interests in verifying the identity of a candidate and conducting background checks to assess suitability of candidate for a role (or express consent to the extent legally required).
Information on Right to Work in Country of Hire.	To verify employment authorization/eligibility in the country of hire.	Compliance with a legal obligation (i.e., to ensure an employee has the right to work under applicable laws).
Background check information (to the extent permitted by statutory law).	Previous employment, criminal history	Legitimate Interest to assess suitability of candidate for a role and to protect assets and other employees.

4. When and with whom we share your information?

FreshBooks uses a number of third party tools and service providers to help us operate and carry out the business purposes listed above. We may share your information with those service providers to support these efforts, as well as with other third parties. For example, we may share your information with:

Service Provider	Purpose	Types of Data
Other Entities of the FreshBooks Group	To provide services and support across the FreshBooks group for recruitment and onboarding purposes.	Contact Information, Right to Work in Country of Hire
Greenhouse (acting as a data processor)	When you apply for a position, are referred as a candidate, or are being considered for a role at FreshBooks, your information is stored in Greenhouse. We use this information to evaluate your candidacy for the posted position. We also store this information, and may use it in relation to future positions to which you apply, or which we believe may be relevant to you given your background.	Contact Information, Employment History, Information on Right to Work in Country of Hire, Education History, Potential of salary expectations, Reference notes, Interview notes, Job application history (internal/external applicants),  Demographic data – if you opt to provide this information to Greenhouse, it will be anonymized and access to it will be restricted. This information is not used to evaluate your candidacy.
Gem (acting as a data processor)	To engage sourced candidates. We use this information to evaluate your candidacy for the posted position. We also store this information, and may use it in relation to future positions to which you apply, or which we believe may be relevant to you given your background.	Contact Information, Employment History, Information on Right to Work in Country of Hire, Education History
Gem (acting as a data processor)	To perform recruiting analytics. We use this information for internal reporting on FreshBooks’ recruiting efficacy. Data is populated in Gem via integration with Greenhouse, is stored in Gem, in accordance with Gem’s Software Privacy Policy for Non-B2B Customers.	Contact Information, Employment History, Information on Right to Work in Country of Hire, Education History
Other Third Parties	FreshBooks might also share your information described in the ‘Information FreshBooks May Collect About You’ Section above with regulators, law enforcement, other government agencies, industry partners, our advisors, or other third party service providers if this is necessary to: 1) respond pursuant to applicable law or regulations, court orders, legal process, or government requests. For example, sharing with regulators, law enforcement, or other government agencies in response to legal requests or sharing with civil litigants pursuant to court orders; 2) protect the rights, property and safety of our company, our employees, or others, including to prevent death or imminent bodily harm. For example, sharing with law enforcement, in emergency situations where we learn that a person’s life is at risk.	Contact Information, Employment History, Education History, Address history (Provided for social/background checks through Certn acting as our data processor) – Collected and seen through third party but not received by FreshBooks
Docusign	To prepare offers of employment for candidates.	Contact information, offer of employment letter
Slack	To prepare offers of employment for candidates.	Contact Information (Name)

When we share your information with third party service providers, we impose contractual obligations on the third parties to use reasonable measures to protect your information.

We may also be legally required in certain circumstances to share information with third parties, for example if we receive a court order or subpoena requiring us to share information with law enforcement. For information about how we respond to such orders, please review our Privacy Policy under “Legal Requests and Business Transitions, Emergencies”.

FreshBooks does not sell the personal information of applicants, nor do we share it for purposes of cross-context behavioral advertising.

5. International Transfers

FreshBooks has employees and contractors working around the world, including in Europe. If you have applied for a position in Europe or the UK, your personal information is controlled by the FreshBooks entity you applied for a position with. We may transfer your data to Canada and the United States so that we can process all of our candidate information centrally, to facilitate the recruitment and onboarding process. When we send your information across borders, we take steps to protect your information.

Your information may be sent to other FreshBooks locations and to service providers who may be located in other regions, including Canada (where we are headquartered) and the United States. When we send your personal information outside of Europe, we do so in accordance with European law, including appropriate safeguards such as the Standard Contractual Clauses.

If you reside in Europe or the UK, when we send your personal information to Canada, it is protected under Canadian law, which the European Commission and the UK Government has found will adequately protect your information.

6. How long we retain your personal information

We store your personal information for as long as necessary for the purposes outlined in this privacy policy, including to fulfill our contractual obligations to you, to comply with our legal obligations and where it is in our legitimate interests to do so. To determine the appropriate retention period for personal information we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. If your application for employment is successful, personal data gathered during the recruitment process will be retained during your employment in accordance with our employee privacy notice. If you are unsuccessful in your application, usually we will retain your personal information for a duration of two months from the end of the application procedure. 

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer part of an application procedure we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

7. Automated decision making

We do not envisage that you will be subject to any decisions which will be taken solely through automated decision making, which produces legal effects concerning you or similarly significantly affects you.

8. Your rights

Under certain conditions you have the following rights with regards to your personal information: 

• You have rights to correct, update, and request access to your personal information and information about our processing of your personal information;
• request rectification of your personal information held by us;
• request that we cease or suspend the processing your personal information;
• request that we delete your personal information;
• request that we transfer your personal information to another service provider;
• request that we restrict our processing of your personal information (including limiting the use of sensitive personal information, as applicable);
• object to certain processing activities (e.g. profiling activities based on our legitimate interests, automated decision making, etc.);
• lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

When FreshBooks has obtained your consent to process your personal information, under applicable law your consent may be withdrawn at any time with future effect. If this applies and you withdraw consent, it will not invalidate (1) the lawfulness of any processing FreshBooks conducted prior to the withdrawal, or (2) FreshBooks’ continued processing of some or all of your personal information under other legal bases, where applicable.

Please note that we may need to verify your identity before facilitating or enabling you to exercise your personal information rights, and thus may request certain information from you when you submit any such requests. Under applicable law, you may also submit personal information requests through an authorized agent, in which case, we may request further information to verify the authenticity of the request and the agent’s authorization to act on your behalf.

If you have any questions about how we use or process your information, or if you would like to exercise your personal information rights (where applicable), please contact FreshBooks’s privacy team through privacy@freshbooks.com.

If you live in the European Economic Area or the UK, you have the right to lodge a complaint with FreshBooks lead supervisory authority, the Irish Data Protection Commission, or your local supervisory authority.

9. Changes to this notice

We reserve the right to update this Notice at any time, and we will provide you with a new privacy notice where reasonably possible (i.e. where we have your correct contact details etc.). when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

10. How you can reach us

If you would like to ask about, make a request relating to, or complain about how we process your personal information, please contact privacy@freshbooks.com, or mail us at one of the addresses below. If you would like to submit a legally binding request to demand someone else’s personal information (for example, if you have a subpoena or court order), please contact privacy@freshbooks.com.

10.1 FreshBooks Privacy Team

privacy@freshbooks.com
1655 Dupont St. Suite 250
Toronto, ON
M6P 3T1 Canada

10.2 FreshBooks Data Protection Officer (DPO)

Attn: Davina Furnish
dpo@freshbooks.com
1655 Dupont St. Suite 250
Toronto, ON
M6P 3T1 Canada

10.3 FreshBooks EU Representative

Attn: Andrew Gunner
eu-dpo@freshbooks.com
FreshBooks Netherlands B.V.
Nieuwezijds Voorburgwal 298 1012RT
Amsterdam, Netherlands

10.4 FreshBooks entities: