Barry-Wehmiller Group
Career Privacy Notice – August 1, 2025

1. Introduction

This Privacy Notice describes how Barry-Wehmiller Group, Inc., and its subsidiaries, affiliates and related companies (together “the Company”, “we” or “us”) processes Personal Data of applicants (“Candidates”) in recruitment. In addition to Candidates, this Privacy Notice also includes referrers who support the Candidate’s application. Separately, the Team Member Privacy Notice describes how we process Personal Data of Candidates who have become employees.

In this Privacy Notice, Personal Data refers to any information relating to an identified or identifiable person. The primary “data controller” is the legal entity that intends to employ the Candidate. The list of Barry-Wehmiller Group, Inc.’s subsidiaries and affiliates, and relevant contact details can be found here: www.barry-wehmiller.com/business. This Privacy Notice covers all processing of Personal Data of Candidates, regardless of whether Personal Data is in paper or digital format.

We collect Personal Data directly from Candidates. We may also proactively conduct research about Candidate’s educational and professional background. Further, we may receive Personal Data from other sources, including for example recruitment agencies, Candidate’s referrers, previous employers, or other parties providing information related to background checks or assessments.

2. What Personal Data is Collected and How It Is Used

The following list describes the typical purposes that Personal Data is used for, and the typical categories of Personal Data that may be processed for those purposes. Other categories of Personal Data may also be processed if necessary for those purposes, and in compliance with applicable law.

The purposes and the categories of Personal Data that are processed vary depending on local practices and local law.¹ In practice, in most countries only some of the categories listed below are processed. Both the purposes as well as the categories must be in compliance with applicable law.

2.1 Categories of Personal Data

Categories of Personal Data may typically include the following:

• Name and contact details;
• Cover letter, profile in LinkedIn or other corresponding platform, CV/resume;
• Information about education, skills, assessments, qualifications, professional certificates, experience and job history;
• Type of employment sought, desired salary and working hours, willingness to relocate or travel, and other possible job preferences;
• Depending on local practices, Candidates may also provide their date of birth, photo, marital status or other information related to Candidate or their family;
• Gender, nationality, eligibility to work, immigration status, work visas and related information;
• Information related to background checks, including, for example, reference checks, job history validation or verification of driver history (when required for the role);
• Careers site login and usage details;
• Referrer names and contact information. By providing these, the Candidate confirms that referrers are aware and consent to their Personal Data being provided to us;
• In compliance with applicable law, in some countries the following information may also be collected: ethnicity, disability, veteran status, drug tests results or criminal background checks.

2.2 How Personal Data is Used

Personal Data is used for Recruitment related activities, including the following:

• Assessing Candidate’s skills, qualifications and interests against our career opportunities;
• Verifying Candidate’s information, carrying out reference checks, and conducting background checks;
• Communicating with the Candidate about the recruitment process and the application, as well as informing the Candidate of other potential career opportunities with us;
• Creating and submitting reports as required under applicable law;
• Assisting the Candidate to obtain an immigration visa or work permit, where required;
• Analyzing and developing our recruitment process and practices as well as the Careers site;
• Fostering our diversity and inclusion programs and practices, in compliance with applicable law;
• Complying with applicable laws, regulations, legal obligations and enforceable governmental requests, and protecting our rights and property.
• Based on Candidate’s consent, retaining Candidate’s Personal Data longer in our Candidate Pool, in order for the Candidate to be considered for future opportunities.

3. Sharing and Transfer

3.1 Internal Sharing within the Company

Personal Data may be shared within the Company when necessary. Personal Data may be accessed and processed, when necessary for the purposes described above, by our relevant team members. Typically these include the following:

• The Recruitment team and other relevant team members within the People team;
• Hiring leader and approver(s);
• Interviewers;
• IT administrators.
  

3.2 External Sharing

When necessary, Personal Data may also be shared with external parties or third-party service providers, including, for example, recruiting software and cloud providers, skill assessment vendors or background check vendors, in order to process Personal Data on our behalf.

3.3 International Transfers

4. Legal Basis and Retention

Processing of Personal Data is mainly based on the following bases: in order to take steps prior to entering into an employment contract or agreement between the Candidate and the legal entity that will be the Candidate’s employer; for compliance with legal obligation; for legitimate interests of the Company (especially in relation to sharing within the Company);; or, with consent.³

Personal Data that can be regarded as more sensitive in some regions, such as special category data and/or sensitive data (e.g. ethnicity, disability, veteran status, drug tests results or criminal background checks), is not processed unless considered necessary, and permissible under applicable law.⁴

Personal Data will be retained in accordance with the attached retention schedule, or as long as reasonably necessary for the purposes in accordance with applicable legislation, whichever is longer. The criteria used to determine our retention periods include:

• The length of time there is an ongoing relationship with the Candidate, and the length of time thereafter during which we may have a legitimate need to reference personal information to address issues that may arise;
• Whether there is a legal obligation to which we are subject to (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

5. Information Security

We implement and maintain industry standard technical and organizational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, access or unauthorized disclosure. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and the nature, scope, context and purposes of processing of Personal Data.

6. Privacy Rights

Candidates may exercise the following privacy rights, subject to applicable legislation:

• obtain confirmation from the Company as to whether or not personal data concerning them are being processed, and, where that is the case, obtain access to the personal data (right to access);
• update, amend and/or correct their personal data (right to rectification);
• obtain from the Company the erasure of personal data concerning them without undue delay (right to erasure);
• where applicable, receive the personal data concerning them, provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company to which the personal data have been provided (right to portability);
• withdraw their consent at any time, where provided.
• object to the processing on grounds relating to their particular situation (right to object).
• obtain from the Company the restriction of the processing, if applicable e.g. where the accuracy of personal data is contested or the processing is unlawful (right to restriction on processing);
• lodge a complaint with a supervisory authority in the member state of their habitual residence or place of work regarding how their Personal Data is used by the Company. In case the applicable supervisory authority is in Europe, the contact details can be found here: https://edpb.europa.eu/about-edpb/board/members_en; https://ico.org.uk/ and www.edoeb.admin.ch/en. The contact details for California are available here: https://cppa.ca.gov/webapplications/complaint .  Individuals located outside of these jurisdictions are encouraged to check with their country/state governments to retrieve the contact details of the relevant authorities.

7. More Information

If a Candidate has given their consent to retain Personal Data longer in the Candidate Pool, but wishes to withdraw their consent, that can be done at any time by logging onto the Careers site.

For recruitment related inquiries, Candidates should contact their recruiter.

For formal requests under applicable data protection legislation, Candidates may contact the Company in the following ways:

• Via email: dataprotection@barry-wehmiller.com
• Via post: Group Data Protection Officer
  Legal Team
  Barry-Wehmiller Group
  8027 Forsyth Blvd
  St. Louis, MO  63105
  United States of America

8. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. Any changes will be communicated in the Careers site.

APPENDIX 1: RETENTION SCHEDULE

Retention schedule applicable to Personal Data collected on or after 2^nd August 2021.

APPENDIX 2: CALIFORNIA

1. Introduction

This California Addendum to the Barry-Wehmiller Group, Inc. (the “Company”) Career Privacy Notice describes the Company’s practices regarding the collection, use, and disclosure of the personal information of applicants in recruitment who are California residents (“California Candidates”), and/or, in accordance with the official language of the California Consumer Privacy Act, “Consumer” and/or "Customer"),  describes the rights of California Candidates under the California Consumer Privacy Act (“CCPA”), and explains how California Candidates may contact the Company to exercise their rights, if applicable (the “Addendum”).  This Addendum supplements the Barry-Wehmiller Career Privacy Notice above.

Individuals who have a disability may be able to use a screen reader or other assistive device to review the contents of this Privacy Notice. If you require additional assistance, contact the recruiter responsible for your selection process, and advise of a request for disability assistance.

2. Personal Information Collected

Within the last 12 months, we have collected the following categories of personal information from California Candidates:

• Identifiers: an individual’s name, contact details, IP address
• Customer records: California Candidate’s contact details
• Protected classification characteristics: characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression). This information will be collected only if provided directly by California Candidates within the selection process.
• Internet or other similar network activity: login details, log data and information about the usage of systems and other devices, for example our career portal.
• Geolocation data: IP address
• Professional or employment-related information: current or past job history
• Inferences: information from assessment tests
• We do not use or disclose sensitive Personal Information to “infer” characteristics as defined under the CCPA, or for any purpose other than that which is necessary to assess your viability as a Candidate.

3. Sales and Sharing of Personal Information

We do not sell your Personal Information, including within the preceding 12 months.

We may share your personal information for purposes of cross-context, targeted behavioral advertising, including with the preceding 12 months.

4. Retention Periods

• Personal Information will be retained in accordance with applicable records retention policies of the Company (please, consult Appendix 2 of this Career Privacy Notice), or as long as reasonably necessary for the purposes in accordance with applicable legislation, whichever is longer.  The criteria used to determine our retention periods include:
• The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

5. Your Rights and Choices

The CCPA provides you, as California residents, with specific rights regarding your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

• Right to Know: In certain circumstances, you have the right to request the Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months.
• Right to Delete: You may have the right to request the Company delete your Personal Information that we collected from you and retained, subject to certain exceptions.
• Right to Correct: You may have the right to request the Company to correct any inaccurate Personal Information we may hold about you.  We will use commercially reasonable efforts to correct inaccurate Personal Information, taking into account the nature of the Personal Information and the purpose for our processing.
• Right to Non-Discrimination: We will not discriminate against your for exercising any of your rights.
• Right to Opt-Out of Targeted Advertising - You may opt-out of the processing your personal information obtained from your activities on nonaffiliated websites for the purposes of targeted advertising. To opt-out of targeted advertising, you must toggle “off” the Targeting Cookies in our center for managing consent preferences or enable global privacy control settings on your browser. Note that this right to opt-out does not apply where we have appropriately limited our partners to be our “service providers” or “processors” as these terms are defined under the CCPA.  

6. Exercising Your Rights

To exercise the right to opt-out of targeted advertising, please visit the “Do Not Sell or Share My Personal Information” section, to learn more about and to exercise this right.

To exercise the rights described above, please submit a request to us by one of the following methods:

• Via email: dataprotection@barry-wehmiller.com
• Via post: Group Data Protection Officer
  Legal Team
  Barry-Wehmiller Group
  8027 Forsyth Blvd
  St. Louis, MO 63105
  United States of America

7. Changes to this Addendum

We may update this Addendum from time to time.  Any substantive changes will be notified to you via the Careers site.

8. Questions About This Notice

If you have any questions about this Addendum, the ways in which the Company collects and uses your information described in this addendum  and in the Barry-Wehmiller Career Privacy Notice above, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact via email at dataprotection@barry-wehmiller.com or via post as noted above.

¹ Providing Personal Data is necessary in order to take steps before entering into an employment contract. Without Candidate’s Personal Data, the Company won’t be able to properly process Candidate’s application.

² Transfers of Personal Data to third countries, in the context of the activities of an establishment of a Data Controller or a Data processor in the European Union, are mainly based on either adequacy decision under art. 45 EU Reg. n. 2016/679 (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en )  and/or standard data protection clauses under art. 46.2. (c) EU Reg. n. 2016/679  (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.)

³ Processing personal data of Team Members in the context of the activities of an establishment of a data controller or a data processor in the European Union is based on art. 6.1. (a), 6.1 (b), art.6.1. (c), or art 6.1. (f) EU Reg. n. 2016/679.

⁴ Processing of sensitive data by the Company is mainly based on the following legal bases: processing of sensitive data is necessary for the purposes of carrying out the obligations and exercising the specific rights of the Company or of the Candidate in the field of employment and social security and social protection law in so far as it is authorised by law or by a collective agreement providing for appropriate safeguards for the fundamental rights and the interests of the Candidates; or; processing of sensitive data by the Company is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the Candidate, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services under the law or pursuant to contract with a health professional. Processing of special categories data of Candidates in the context of the activities of an establishment of a data controller or a data processor in the European Union is based on art.9.2 (b) or art 9.2. (h) EU Reg. n. 2016/679.