Candidate Privacy Notice

Last updated: 10 June 2020

Introduction

Cognizant Technology Solutions Corporation and its affiliated companies (“Cognizant” “w e” or “us”) are firmly committed to
protecting your privacy. This Candidate Privacy Notice ("Notice") explains w hat w e do w ith Personal Information w e collect
during and after the recruitment process through the Careers portal on the Cognizant w ebsites ("Site") or by any other
means. This Notice applies to individuals w ho apply for employment (w hether fulltime or on contract basis), internship or
assignment w ith Cognizant, including those individuals w ho attend a Cognizant recruitment event.

As a global company, Cognizant has a number of legal entities in different jurisdictions w hich are responsible for the Personal
Information w hich they collect. The data controller for Personal Information collected during the recruitment process is the
Cognizant company in your jurisdiction to w hom you submit your application (all Cognizant companies can be found via this
link: Cognizant Worldw ide). If you are unsure as to w hich Cognizant company is applicable to you, please contact us (see
Contact Us section below ).

In some cases, local law s and regulations that apply to the Processing of Personal Information may be more restrictive than
this Notice. Where this is the case, the more restrictive requirements w ill apply. Where required by local law s, Cognizant w ill
provide you w ith additional privacy notices or information. In addition, this Notice may be supplemented from time to time
w ith more specific privacy information or notices.

Please note that the Site is hosted by Phenom People Inc..

The Site (and recruitment process) is not intended for minors under the age of 16.

What are w e going to tell you in this notice?

How w e collect and use your Personal Information

Why w e need to collect your Personal Information
Who w ill have access to your Personal Information
International transfer of your Personal Information
How long w e retain your Personal Information
How w e protect your Personal Information
What are your rights
Contact Us

Capitalized terms are defined at the end of this Notice, in the Definitions section.

How w e collect and use your Personal Inform ation

Types of Personal Information

We may collect the follow ing general types of information about you:

Personal Inform ation – During the recruitment process, w e collect information from you in connection w ith your application.
Information w e collect includes:

• Name, address, telephone number, email address and other contact information
• Information you submit in resumes/CV’s/letters, including but not limited to employment history, academic
qualifications, professional qualifications and skills;
• Whether or not you w ere previously employed by Cognizant, including employee ID

Cognizant Candidate Privacy Notice

10 June 2020
 • Other relevant information, such as employment preferences, w illingness to relocate, current salary, desired salary,
aw ards or professional memberships, professional and other w ork related licenses, permits and certifications;
• Information generated by interview ers and recruiters, based on their interactions w ith you, e.g. via a recruitment or
campus hiring event, or basic Internet searches;
• Information provided by third-party recruiters, staffing companies or executive search agencies, w here applicable;
• Recommendations provided on your behalf by others;
• Documentation required under immigration law s;
• Personal Information submitted or generated as a result of psychological, technical or behavioural assessments
undertaken (including the involvement of remote video proctoring); you w ill receive more information about the
nature of such assessments before your participation in any of them;
• Personal Information submitted or generated as a result live video interview s; you w ill receive more information
about the nature of such interview s before your participation in them.
• Your Public LinkedIn profile, if you choose to import your profile to get personalized job recommendations;
• Username and passw ord (if available on the Site).

Should you be successful for a role, w e w ould then ask you to provide information about third parties, such as references
or contacts that you provide to us. You are responsible for ensuring that you have permission to submit any such information
and that such individuals are aw are that their information w ill be available to Cognizant or its clients for the purposes of
taking up references.

Sensitive Personal Inform ation - We do not require you to provide any Sensitive Personal Information during the
recruitment process. Nonetheless, should you be successful for a role, w e –w here permitted by applicable law - may then
ask you to provide some Sensitive Personal Information and/or identification numbers to enable us to comply w ith legal
requirements at a national level (e.g. in relation to equal opportunities legislation).

In addition, you may also be subject to a background check, w here justified by the particular role you are applying to and
subject to the applicable law s of the country you are located in. The content of background check information varies by
country to comply w ith local requirements, but may include information gathered from publicly available sources, your former
employers or colleagues, schools you have attended, credit reporting agencies, and criminal records databases. You w ill
receive more information about the nature of such a background check before it begins and no such checks w ill be
undertaken w ithout your express prior consent, w here this is required by applicable law .

Otherw ise w e ask that you avoid submitting information w hich may qualify as sensitive information under applicable law,
except w here such information is legally required.

Aggregated inform ation - This is information that is aggregated and therefore not uniquely personal to you, but w hich
refers to selected population or geographic characteristics, age, gender, occupation, preferences, and interests in
accordance w ith applicable law s.

Behavioural inform ation - We and our service provider (Phenom People Inc) use “cookies” and similar technologies on
the Site. For more information and to manage your settings, please see the Career Site Cookie Policy and the Cognizant
Cookie Notice.

Any information you submit must be true, complete and not misleading. Submitting inaccurate, incomplete or misleading
information may make you ineligible for employment.

Sources from which the Personal Information originates

We may collect information about you directly from you or from other sources (w here permissible and in accordance w ith
applicable law ):

• From you directly or from your use of the Site

• From referrers, referees and former employers.
• From conversations w ith recruiters and other Cognizant associates or representatives, as w ell as from internet
searches that these individuals may perform, or data that they may obtain from job search or professional
netw orking w ebsites (e.g. LinkedIn, etc) w here you may have made data about yourself publicly available;

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 • From third party recruiters, staffing companies or executive search agencies that are contracted by Cognizant;
• From background checks, as applicable. Where permitted by law , w e may contract w ith a third party to perform a
pre-employment background screening. You w ill receive more information about the nature of such a background
check before it begins and no such checks w ill be undertaken w ithout your express prior consent, w here this is
required by applicable law .

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Why w e need to collect your Personal Inform ation

Purposes

We w ill process your Personal Information (including, w ithout limitation and w here permitted, your Sensitive Personal
Information) for our recruitment, management and planning purposes, including:

• assessing your suitability for the role for w hich you are applying as w ell as future roles that may come available;
• management and administration of your application;
• facilitate communication, responding to your queries;
• verifying eligibility to w ork;
• perform data analytics, including of our candidate pool, to improve our recruitment process and the Site;
• notifying you about opportunities (if you signed up);
• to comply w ith or monitor compliance w ith applicable law .

We may collect and aggregate data from your Personal Information to enable us to monitor and improve our services.

Legal basis for processing

Cognizant w ill Process Personal Information w here it is required by law , necessary for the prospective employment contract,
or w here it has a legitimate interest (w hich is not overridden by your data protection interests or fundamental rights and
freedoms, particularly taking into consideration the safeguards that w e put in place).

Cognizant w ill Process Sensitive Personal Information w here it is necessary for the purpose of carrying out a legal obligation
or exercising your specific rights or those of Cognizant w ith respect to your prospective employment w ith Cognizant.

Cognizant w ill obtain your consent to Process your Personal Information w here it is required to do so by local law , and w here
required, for any new or additional purpose. For example, w e w ill obtain your prior consent, if this is required under applicable
law , for certain types of processing regarding Sensitive Personal Information and Personal Information regarding criminal
offences and convictions. Under local law , to the extent that Processing is based on consent, you may be entitled to w ithdraw
consent to the Processing of their Personal Information. If you w ish to w ithdraw consent you can contact us (see Contac t
Us section below ).

The primary legal basis is set out in the table below :

Purpose of Use Legal Reason for Processing

To assess your suitability for employment for the role • Necessary for Cognizant’s legitimate interests to ensure
for w hich you are applying (excluding background that it recruits the appropriate employees.
checks), as w ell as future roles that may become • To take steps prior to entering in an employment contract
available. w ith you, w here you are considered for employment.

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 To manage and administrate your application. • Necessary for Cognizant’s legitimate interests to ensure
that it recruits the appropriate employees.
• To take steps prior to entering in an employment contract
w ith you, w here you are considered for employment.
To facilitate communication. • Necessary for Cognizant’s legitimate interests to ensure
proper communication w ith you and w ithin the
organization.
• To take steps prior to entering in an employment contract
w ith you, w here you are considered for employment.

Verifying eligibility to w ork (excluding background • To take steps prior to entering in an employment contract
checks). w ith you, w here you are considered for employment.
• Necessary for Cognizant’s legitimates interests to comply
w ith applicable immigration and/or employment law s and
regulation.

Perform data analytics, including of our candidate pool, • Necessary for Cognizant’s legitimate interests to ensure
to improve our recruitment process and the Site. that it improves its recruitment processes.

If you register/sign up on the Site, w e w ill enter you in • Necessary for Cognizant’s legitimate interests to ensure
a database to receive job alerts and/or information on that it recruits the appropriate employees.
job events.

To comply w ith or monitor compliance w ith applicable • Necessary to comply w ith Cognizant’s legal obligations as
law or regulation. a business entity
• Necessary for Cognizant’s legitimate interest to protect
the rights and interests of Cognizant, our employees ,
candidates and others.

If w e ask you to provide Personal Information to comply w ith a legal requirement or to perform a contract w ith you, w e w ill
make this clear at the relevant time and advise you w hether the provision of your Personal Information is mandatory or not
(as w ell as of the possible consequences if you do not provide your Personal Information).

If you have questions about or need further information concerning the legal basis on w hich w e collect and use your Personal
Information, please contact us at dataprotectionofficer@cognizant.com.

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Who w ill have access to your Personal Inform ation

In general, access to your Personal Information w ill be restricted to the relevant people in Cognizant w ho need it for the
purposes set out in this Privacy Notice (e.g. your potential future managers and direct colleagues, recruitment, HR and IT).

We w ill not sell your Personal Information, but may disclose your Personal Information, as required and in accordance w ith
applicable law s, as follow s:

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  Third party service providers: We use a third party service provider (namely Phenom People Inc.) w ho is located
in the United States (300 Brookside Avenue, Building 18, Suite 200, Ambler, PA 19002) to assist us in managing
our Site and w ho may have access to your Personal Information. We also use another third party service provider
(Talview Inc.) w ho is located in the United States (2033 Gatew ay Place, San Jose CA 95110) to assist us in the
recruitment process and w ho may have access to your Personal Information. Your Personal Information may also
be shared w ith other third party service providers w ho have been retained to provide services on behalf of
Cognizant, such as for the storage of data or the maintenance of our Site.
 Cognizant Affiliates: Due to the global nature of Cognizant’s business, Personal Information may be shared,
disclosed and transferred betw een the various Cognizant Affiliates w here such transfers are required for legitimate
business reasons, e.g. recruiters, hiring managers, talent managers and administrative and IT functions may be
located in other countries than the country w here the position you are applying for is based.
 Clients: w here applicable, your Personal Information, such as your CV, may be shared w ith the relevant client for
project related purposes.
 Potential m ergers or acquisitions: Follow ing an acquisition of any or all of Cognizant’s business operations ,
w hether by w ay of acquisition of shares or stock, merger, consolidation or asset purchase and regardless of any
possible new company name, w e w ill notify you about any changes in the data controllership.
 Insolvency proceedings: If Cognizant becomes the subject of insolvency proceedings, w hether voluntary or
involuntary, Cognizant or its liquidator, administrator, receiver or administrative receiver or similar officer may
transfer, license or otherw ise dispose of your Personal Information in a transaction approved by the court of
competent jurisdiction. We w ill notify you of any relevant sale of our business operations by a posting on the Site
or via email.
 Legal obligations: We may disclose your Personal Information w here required to comply w ith our legal obligations ,
including w here necessary to abide by law , regulation or contract, or to respond to a court order, administrative or
judicial process, including, but not limited to, a subpoena, government audit or search w arrant.
 Public bodies and authorities: We may disclose your Personal Information pursuant to a request from a
governmental or regulatory entity/body or if w e believe in good faith that such disclosure is necessary to (1) comply
w ith legal or regulatory requirements or for the purposes of compliance w ith legal process; (2) prevent crime; (3)
prevent any terrorist activity or threat to national security; (4) protect the personal safety or w ellbeing of users of
the Site or any other person.
 Legal proceedings: Cognizant may disclose your Personal Information to the extent permitted by appropriate law
w here necessary to establish, exercise or defend against potential, threatened or actual legal claims.
 Vital interests: We may disclose your Personal Information w here necessary to protect your vital interests or those
of another person.

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International Transfers of your Personal Inform ation

As further detailed above under the section ‘Who w ill have access to your Personal Information’, due to the global nature of
Cognizant’s business, Personal Information may be shared, disclosed and transferred betw een the various Cognizant
Affiliates and third parties w here such transfers are required for legitimate business reasons. Such companies may be
located outside your country of residence. The level of protection for Personal Information is not the same in all countries;
how ever, w e w ill take reasonable steps and implement measures as described in this Notice to keep your Personal
Information secure. In addition, w e w ill ensure that any international transfers of your Personal Information w ill take place in
accordance w ith the requirements of applicable law .

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In particular, unless otherw ise notified to you, any transfers of your Personal Information from w ithin the European Economic
Area (EEA), Sw itzerland and/or the United Kingdom (UK) (as applicable) to Cognizant Affiliates or third parties located
outside the EEA, Sw itzerland and/or the UK (as applicable) w ill be based on an adequacy decision or governed by the
Standard Contractual Clauses.

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How long w e retain your Personal Inform ation

We w ill retain Personal Information for the period necessary to fulfil the purposes outlined in this Notice, unless a longer
retention period is required or permitted by law . The criteria used to determine our retention periods are (i) the duration of
the application process, (ii) as long as w e have an ongoing relationship w ith you, (iii) as required by a legal obligation to
w hich w e are subject; and (iv) as advisable in light of our legal position (such as in relation to statutes of limitations, litigation
or regulatory investigations).

If you become an employee of Cognizant, your Personal Information w ill be retained in accordance w ith the Associate
Privacy Notice.

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How w e protect your Personal Information

Cognizant implements appropriate security measures designed to prevent unlaw ful or unauthorized Processing of Personal
Information and accidental loss of or damage to Personal Information. Cognizant maintains w ritten security management
policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the
confidentiality, integrity, availability, or security of your Personal Information. These policies and procedures assign specific
data security responsibilities and accountabilities to specific individuals, include a risk management program that includes
periodic risk assessment and provide an adequate framew ork of controls that safeguard your Personal Information. Where
w e contract w ith third parties to provide services that may enable them to access your Personal Information w e require them
by contract to have similar security controls in place.

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What are your rights

To the extent these rights are provided to you by applicable law , you may:

• request access to your Personal Information or to correct, update or request deletion of your Personal Information.
You can do so by contacting us at SAR@cognizant.com.

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• object to processing of your Personal Information, ask us to restrict processing of your Personal Information or
request portability of your Personal Information. Again, you can exercise these rights by contacting us at
SAR@cognizant.com.

• If w e have collected and process your Personal Information w ith your consent, then you can w ithdraw your consent
at any time. Withdraw ing your consent w ill not affect the law fulness of any processing w e conducted prior to your
w ithdraw al, nor w ill it affect processing of your Personal Information conducted in reliance on law ful processing grounds
other than consent.

• You have the right to com plain to a data protection authority about our collection and use of your Personal
Information or to initiate a law suit due to the breach of your Personal Information at the regional court w ith geographical
jurisdiction based on your residence or based on the seat of the data controller. Follow ing are the contact details for
data protection authorities in:

 the European Economic Area – Click here;

 the UK - Click here;
 Sw itzerland - Click here;

We respond to all requests w e receive from individuals w ishing to exercise their data protection rights in accordance w ith
applicable data protection law s. Complying w ith all or part of your request may be denied or limited by Cognizant if it w ould
violate another person's rights and/or as otherw ise permitted by applicable law .

Before responding to a request, w e reserve the right to verify and authenticate your identity and the information that your
request relates to.

If an archival copy of your Personal Information is required to be retained by applicable law after receiving a request for
deletion or closure of your account, w e w ill follow the statutory term for such a retention.

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Contact Us

If, at any time, you have questions or concerns about the operation of this Notice or believe that w e have not adhered to this
Notice, please email us:

Asia Pacific : Careers-APAC@cognizant.com

India : talentattractteam@cognizant.com

Continental Europe : ChireSupportEurope2@cognizant.com

Latin America : CareersLatmSupport@cognizant.com

North America : CareersNA2@cognizant.com

UK & Ireland : careersuki@cognizant.com

In addition, you may submit concerns or complaints about Cognizant’s privacy practices to the Data Protection Officer at
DataProtectionOfficer@cognizant.com.

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Changes to this Notice

We reserve the right to m ake changes to this Notice at any tim e. Any changes to this Notice w ill be posted on this
page thus m ake sure to read this Notice before subm itting your Personal Inform ation. Substantial changes w ill be
highlighted on the Site or m ay be em ailed to you.

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Definitions

• “Candidate” means any prospective employee, individual contractor or other member of personnel of
Cognizant.

• “Cognizant” means Cognizant Technology Solutions Corporation, a public limited company incorporated in
Delaw are, United States w ith a registered address at 500 Frank W Burr Blvd, Teaneck, NJ 07666 USA, and
its global affiliates and subsidiaries, including the Cognizant company to w hom you have applied for a job.

• “Personal Inform ation” means any information or combination of information, in any form or medium, that
can identify an Associate. Examples include name, email address, physical address, phone number, date of
birth, age, home address, personal preferences, behavioural information, government issued IDs, IP address,
hardw are identifiers, etc.

• “Sensitive Personal Inform ation” means Personal Information, w hich if lost, compromised, or disclosed
w ithout authorization, could result in substantial harm, embarrassment, inconvenience, or unfairness to an
individual. Examples of Sensitive Personal Information in various jurisdictions may include social security
numbers, driver’s license numbers, passw ords, passports, tax IDs, financial account and credit card numbers,
health information (including Protected Health Information (PHI)), biometric identifiers, racial or ethnic origin,
and information about political opinions, religious beliefs, trade union membership, criminal history, sexual
orientation or blood group.

• “Process/Processed/Processing” means any operation or set of operations w hich is performed on Personal

Information or on sets of Personal Information, w hether or not by automated means, such as collecting,
recording, storing, deleting, view ing, accessing, amending, using or disclosing the Personal Information.

• Note, w here w e have used w ords such as “include,” “including,” “for example,” or “such as” in this Notice these
are meant to be examples and not exhaustive lists.

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