Applicant privacy notice
At Solventum, our affiliates, and subsidiaries (collectively “Solventum”, “we”, “our” or “us”), are committed to ensuring the privacy and security of your personal and sensitive information in accordance with applicable data privacy and cybersecurity laws and regulations. This Applicant Privacy Notice (“Applicant Notice”) describes how we collect, use, store, process and protect (collectively “process”) your Personal Data when you submit applications for jobs (or submit information for future positions) at SpinCo (each an “Applicant” or “you”). Where required by applicable law, we will not collect, use, or disclose your Personal Data without first obtaining your consent. For a list of Solventum data controllers and contact details by country, please click here. In this Applicant Notice, when we use the term “Personal Data”, we mean any information relating to an identified or identifiable individual, or as related terms, such as "personal information", are defined under applicable law.
Scope
This Applicant Notice applies to Personal Data that we process about Applicants, in the context of processing their applications or otherwise considering them for a position with us. If required under applicable law, we may provide Applicants with additional privacy notices about other relevant data processing activities.
Unless you are in a jurisdiction where this is not permitted, your use of our website or submission of an application or other information through this website is subject to our Terms of Use, which include terms governing limitations on liability and the resolution of disputes; our Terms of Use are incorporated by reference into this Applicant Notice.
Personal Data We Collect
We may collect various types of Personal Data when you submit an application for employment including, but not limited to:
- Contact Information, including your full name, residential address, personal e-mail address, and home or mobile telephone number.
- Candidate Information, including biographical data, CV; data from your public LinkedIn profiles and similar platforms; education and degree information; professional licences, certifications and memberships and affiliations.
- Application Information, including position applied for, with date of application and related data; correspondence with you and others, such as recruiters, references.
- Current and Past Employment Related Information, including dates of employment, position and job title information and work history information.
- Online and Technical Information, including IP address; data from devices that connect to our networks; system logs, including access logs; records from technology monitoring programmes, such as suspicious activity alerts. Please read our Solventum Global Website Privacy Statement and Solventum Cookie Policy for additional information.
- 3M Business Communication Records, including email exchanges, text details, and chat contents and logs from your communications with us, which we may keep as records of those conversations.
- Health Information, including vaccination status, drug testing and fitness to work examinations, and disability information, for accommodation of disabilities.
- Audio and Visual Information, including work related photographs; video images and videoconference records.
- Inferred and Derived Data, including advancement potential and success scores.
- Compliance Data, including employment eligibility verification records, background screening records, and other records maintained to demonstrate compliance with applicable laws, such as right to work laws and privacy laws; security clearance information.
- Other information you voluntarily provide to us, such as your race or ethnicity, gender, age, date of birth, nationality, and demographic information.
Sources of Personal Data
In general, we may collect the categories of Personal Data identified above from the following categories of sources:
- Directly from you (including automatically when you interact with us online);
- Recruiters and recruiting platforms;
- Referrals and references;
- Employers (including former employers);
- Publicly available information and sources (e.g. LinkedIn or your current employer’s website);
- Educational institutions;
- Social media platforms;
- Service providers, representatives and agents; and
- Affiliates and subsidiaries.
How We Use Your Personal Data
We use your Personal Data as necessary for compliance with a legal obligation, for entering into or performance of a contract, and/or for legitimate business purposes, including:
Management of Applicant Relationship. To manage our relationship with Applicants, including identifying candidates; reviewing information provided, and otherwise evaluating Applicants; negotiating
the terms of offers; maintaining Applicant Personal Data for future consideration; identifying and contacting Applicants about other positions in which they may be interested; and supporting our equal opportunity employment policy and practices.
Business Operations and Related Services. For our business operations, including related to auditing and assessing performance and business operations; satisfying reporting and auditing obligations, including workforce reporting; and facilitating communications in furtherance of the foregoing.
Security and Monitoring. To monitor and secure our resources, network, premises and assets, including detecting, preventing, investigating and responding to security and privacy incidents; managing physical and technical access controls; and promoting the security and functioning of our systems and assets, offices and premises, including through the use of electronic access systems and video monitoring.
Health and Safety. For health and safety purposes, such as to comply with Solventum’s health and safety programmes; to determine accommodation for disabilities; to monitor environmental health and safety; for contact tracing; or to conduct appropriate screenings of Applicants prior to entering or accessing certain locations or premises (e.g. for disability accommodations, ability to work).
Mergers & Acquisitions and Other Business Transactions. To facilitate a merger, acquisition, asset sale or transfer, joint venture or collaboration, assignment, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy, reorganisation or other similar business transaction or proceeding) or similar transaction, including, but not limited to the planning, due diligence and implementation of such business transactions.
Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties; to respond to legal claims or disputes, including in the context of anticipated or actual litigation with third parties.
Compliance with Legal Obligations. To comply with applicable legal obligations or perform a contract with you, as well as assessments, reviews and reporting relating to such legal obligations, including under employment, labour laws and other applicable laws, regulations and legal requirements.
Disclosures to Services Providers and Other Entities
We may disclose your Personal Data to the recipients below for the purposes described in this Applicant Notice. In each case, we will take appropriate steps (including obtaining your consent where required by applicable law) to protect your Personal Data.
Solventum Affiliates. Our SpinCo affiliates will use your Personal Data in a manner consistent with this Applicant Notice and applicable laws.
Service Providers. We may disclose your Personal Data to contractors, service providers and others we engage to perform support services for us, such as hosting providers, recruiting services providers, and IT and information security services provider. These companies may only use the data as permitted by our contracts with them.
In connection with business transfers. We may disclose your Personal Data to third parties (including potential or prospective buyers, sellers, lenders and their respective affiliates, agents, advisers and representatives) in connection with the actual or contemplated sale, purchase, merger, reorganisation, liquidation, dissolution or other disposal of assets or interests of Solventum or a Solventum business unit.
With your consent. We may disclose your Personal Data with your permission or at your request.
To comply with law or to protect you and/or your rights. We may disclose your Personal Data to others when we have a good faith belief that disclosure is necessary:
- To comply with a law, regulation, court order, or other legal process;
- To detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of Solventum websites, apps, products or services;
- to protect the health, safety, welfare, rights, or property of you, our customers, the public, Solventum or others; or
- Under similar circumstances.
In an aggregated/de-identified format. To the extent permitted by applicable law, Solventum may share anonymised, aggregated or de-identified information internally and with third parties for any purpose. Such information will not identify you individually, and we will maintain and use the information in deidentified form and will not attempt to reidentify the information.
Your Rights
Depending on applicable law and subject to certain conditions and exceptions, you may have certain rights with respect to your Personal Data. We will not discriminate against you for exercising any of your rights.
- The right to access, correct, update, or request deletion of your Personal Data.
- The right to know certain information about the Personal Data that we process about you, including specific pieces of your Personal Data that we collect.
- The right to object to, limit or restrict our processing of your Personal Data.
- If we are processing your Personal Data based on your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of our processing before your withdrawal.
- The right to request a copy of the Personal Data in a portable (i.e. structured, commonly used, machine-readable, user-friendly) format.
- The right to complain to us or a data protection authority about our collection and use of your Personal Data.
You (or your authorised agent) may exercise your rights by completing our request form. We may, after receiving your request, require additional information from you (or your authorised agent) to honour your request and verify your identity.
Cross-Border Data Transfers
Solventum operates in many countries and your Personal Data may be transferred across international borders to other Solventum affiliates and third parties (as described in this Applicant Notice) located outside of the country where you live. Regardless of where your Personal Data is processed, we will always take reasonable steps to protect the privacy and security of your Personal Data. This may include implementing appropriate agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your Personal Data outside of your jurisdiction with your prior consent.
Protecting Personal Data
We implement appropriate technical, physical and organisational measures designed to protect the confidentiality, security and integrity of your Personal Data. Data protection measures include, but are not limited to, adoption of encryption tools and access controls.
Retention
We retain your Personal Data for as long as reasonably necessary or permitted in light of the purposes for which it was collected, and as described in this Applicant Notice or as otherwise disclosed to you at the time of collection. The retention period varies and depends on criteria that may include:
- The dates of your application for employment with Solventum and the date of your last interaction with us;
- Whether retention is necessary or advisable due to applicable statutes of limitations, litigation, or other legal, regulatory, accounting or reporting obligations; and
- Any relevant retention requirements under applicable laws or in agreements with you or others.
If your Personal Data is either (i) no longer necessary or relevant for the purposes for which it was collected, or (ii) no longer required to be retained by applicable laws, then we will take reasonable steps to have it deleted, destroyed, or, if permitted by applicable law, aggregated, made anonymous, or de-identified.
If you have questions about our retention policies, please contact us at Privacy@solventum.com.
Changes to this Applicant Notice
We reserve the right to amend this Applicant Notice at any time. If we make changes to this Applicant Notice that materially affect how we process your Personal Data, we will endeavour to notify you, for example, by posting an updated Applicant Notice on our careers page and listing the effective date of such updates.
Contact Us
If you have questions or concerns regarding this Applicant Notice or how we process your Personal Data, please contact us at: Privacy@solventum.com