Kenya Candidate Privacy Policy and Terms & Conditions

Last Updated: August 2020

Candidate Privacy Policy (career site)

The Cigna Group^SM Corporation and its affiliated entities (together “The Cigna Group,” “we,” “our” or “us”) value your trust and are committed to the responsible management, use and protection of personal information. As a global business, The Cigna Group operates in many different countries. Some of these countries have laws related to the collection, use, transfer and disclosure of the personal information of individuals, including job applicants.

This Careers Site Privacy Policy (“Policy”) is applicable to all the information collected by The Cigna Group to facilitate your application for a job within The Cigna Group, including your use of our Careers site located at jobs.cigna.com (the “Careers Site”), and explains what personal information we collect, use, transfer and disclose, and why we do so. Personal information submitted elsewhere on our website and our affiliates’ web sites will be used in accordance with our general online Privacy Policy (located at cigna.com).

Please read this Policy carefully.

Personal Information We Collect From You

We collect personal information from you in connection with your application, including:

• Name and contact information, including your address, telephone numbers and email address;
• Log-in and password;
• CV, résumé, cover letter, previous work experience and education information;
• Professional and other work-related licenses, permits and certifications held;
• Language and other relevant skills;
• Awards and professional memberships;
• Eligibility to work in country where the job applied for is located, available start date;
• Information relating to references; and
• The correspondence you have with us and other information you have chosen to provide (e.g., employment preferences, willingness to relocate, desired salary, how you heard about the Careers Site).

From the information we collect about you, we may also derive or generate further information such as job candidate profiles.

As discussed in the “Diversity” section below, in certain cases we will ask questions about race/ethnic origin, gender, and disability of our applicants, for monitoring equal opportunity. We may also inquire about criminal records where permitted by applicable law.

Otherwise, we ask that you avoid submitting information which may qualify as sensitive information under applicable law, except where such information is legally required. Sensitive information includes race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, veteran status, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings.

Any information you submit through the Careers Site must be true, complete and not misleading. Should the information provided be inaccurate, incomplete, or misleading, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been employed. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you intend to provide us with details of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the personal information to us.

Personal Information We Collect From Other Sources

We may obtain information about you from other sources (where permitted by law) such as:

• Publicly available registers;
• Social media sites;
• Your referees;
• Prior employers;
• Background check providers; and
• Recruitment agencies.

How We Use Personal Information and the Basis on Which We Use It

The Cigna Group will use the personal information on your application, as permitted by local law, to:

• Process your application and assess your capabilities and qualifications for a job. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests.
• Conduct reference checks. We will engage in these activities to comply with a legal obligation or based on our legitimate interests.
• Provide you with any services available on the Careers Site from time to time, respond to your inquiries and communicate with you about your application, and send you information regarding the Careers Site and changes to our [Terms and Agreements]. We will engage in these activities to manage our prospective contractual relationship with you.
• Comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with a legal obligation or based on our legitimate interests.
• Conduct background checks (including disclosure and financial checks) (in accordance with applicable law) if you are offered a job. We will engage in these activities to comply with a legal obligation or based on our legitimate interests.
• Support our other legitimate interests, such as to perform business management activities including performing audits, assessments, maintenance and testing or troubleshooting activities related to the recruitment system; to monitor and record services, whether provided by a The Cigna Group company or a third party; to operate, evaluate and improve the recruitment system, our application tracking and recruitment activities and communications (including analyzing our job applicant base, our hiring practices or trends, identifying qualifications or skills shortages, and using information to match candidates and potential opportunities); and as generally required to conduct our business within The Cigna Group.

If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us at seeyourself@cigna.com.

The information about you will be added to our international candidate database and can be retained and used to consider you for opportunities at The Cigna Group and its affiliates other than the one(s) for which you apply. If you do not wish us to do this, please contact us at seeyourself@cigna.com.

If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become an employee, any personal information that you submit can become part of your employee file and can be used for other employment/work-related purposes, and at that stage we will explain to you how we use your employee personal information.

The provision of personal information on the Careers Site is voluntary. Failure to provide sufficient information, however, may result in The Cigna Group being unable to consider your employment application or, if you are hired, your subsequent promotion, transfer or relocation.

International Transfers and Sharing of Personal Information With Third Parties

The Cigna Group shares personal information with affiliates that are involved in evaluating candidates for a given position. You can consult the list and location of our affiliates by contacting us at seeyourself@cigna.com. We will limit access to personal information to The Cigna Group employees or agents who have a business need to access such personal information, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.

We also share your personal information with unaffiliated third parties, including:

• Service providers, such as companies that assist The Cigna Group with the operation of the Careers Site, IT systems suppliers and support, background check providers, and other service providers that help to facilitate the provision of services to the relevant The Cigna Group entity; and
• Professional advisors in all of the countries in which The Cigna Group operates in relation to the Careers Site.

Third party service providers and professional advisors are expected to protect the confidentiality and security of personal information, and only use personal information for the provision of the services to The Cigna Group, and in compliance with applicable law.

Due to the global nature of our operations and policies (such as HR, IT, accounting, legal, internal audit and security measures), The Cigna Group discloses personal information to personnel, other departments throughout The Cigna Group family of companies, and third party service providers to fulfill the purposes described in this Policy. This includes transferring personal information to the United States and other countries (including countries that have a different data protection regime than is found in the country where you are based).

Additional Information for the EEA

If you are located in the European Economic Area (the “EEA”) we may transfer your information to countries outside of the EEA. Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards. For transfers from the EEA to other countries, we have put in place adequate measures (such as contractual commitments) in accordance with applicable legal requirements to protect your information. For more information on the measures in place, please contact us at privacy.europe@cigna.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may lodge a complaint with a supervisory authority for your country or region, or in the place of the alleged misconduct. You can contact our data protection officer at privacy.europe@cigna.com.

Other Uses and Disclosures of Personal Information

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable laws, which can include laws outside your country of residence.
• To respond to requests from public and government authorities, which can include authorities outside your country of residence.
• To cooperate with law enforcement, for example, when we receive law enforcement requests and orders.
• For other legal reasons, such as to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Data Retention

We will retain personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include (but are not limited to): (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; and (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

We may remove personal information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, The Cigna Group can delete personal information about you (including your CV/résumé) from our database at any time and without providing any reason. Therefore, please retain your own copy of the personal information provided to us.

Cookies and Similar Technology

We and our service providers may use “cookies” and similar technologies on the Careers Site. Please see our Privacy Policy for more information on how we use cookies.

Access and Choices

If you choose to register on the Careers Site, you may access, review, and change some of the personal information collected about you and stored in the Careers Site by logging into the Careers Site and updating your account information. The updated profile will be used as the default the next time you apply for a job using your account; however, some information from the original application may still be visible to The Cigna Group. To change personal information that you already have submitted for consideration for a specific position, please resubmit your application for that position and include the updated personal information about you in the application. We encourage you to promptly update your personal information if it changes or is inaccurate.

If you have any questions or concerns about how we process personal information please contact us at seeyourself@cigna.com.

If you wish to request to access, correct, update, suppress, restrict, delete, object to processing, or receive your personal information in a usable electronic format and transmit it to a third party (known as the right to 'data portability'), to the extent such rights are provided by applicable law, please contact us at seeyourself@cigna.com with any such requests. Some personal information may be exempt from such requests in whole or in part, pursuant to applicable data protection laws or other laws and regulations.

For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will comply with your request in accordance with our obligations under applicable law.

Security

We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

The Cigna Group hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Careers Site.

Links to Other Websites

The Careers Site may contain links to other websites. The operators of those other websites may collect information about you, including through cookies or other technologies. If you link to another website, you will leave the Careers Site and this Policy will not apply to your use of and activity on those other sites.
Links on the Careers Site to other websites are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site. We encourage you to read the legal notice posted on those sites, including their privacy policies. We have no responsibility or liability for your visitation to, and the data collection and use practices of, other sites.

Diversity

The Cigna Group is an equal opportunity employer, which means we offer equal treatment to all applicants. The Cigna Group does not discriminate, either directly or indirectly, on the grounds of race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment. In some countries we ask for information on the ethnic origin, gender and disability of our applicants for the purpose of monitoring equal opportunity.

Law Applicable to Job Application

This Careers Site allows you to benefit from our centralized global recruitment function, while applying for jobs world-wide. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the U.S. and will be subject to U.S. laws. However, if we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.

About Children

The Careers Site is not intended for minors under the age of 18.

Current Workers of The Cigna Group 

If you currently work for one of our business units, you must be eligible to apply for a position in a different business unit within The Cigna Group to use the Careers Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

The Careers Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.

Changes to the Policy

You may request a copy of this Policy from us using the contact details set out below.

We may modify or update this Policy at any time in order to address future developments of The Cigna Group, the Careers Site or changes in industry or legal trends. You can determine when the Policy was revised by referring to the "Last Updated" legend on the top of this Policy.

Contact Us

If you have questions or requests about this Policy, please feel free to contact us at seeyourself@cigna.com.

You can contact our data protection officer at privacy.europe@cigna.com.

Acknowledgement

I acknowledge that I have received, reviewed and understood this Policy.

Terms & Conditions

In order to be considered for employment at The Cigna Group you will be required to:

• Provide proof of Kenyan citizenship or the authorization to work for The Cigna Group or its affiliates in the Republic of Kenya under the Kenya Citizenship and Immigration Act (No. 12 of 2011) and Regulations thereunder;
• Successfully pass a background check, any consideration of the background check will be tailored to the requirements of the job.
• The Cigna Group reserves the right to test any employee for the illegal presence of drugs or alcohol.

The types of checks may include, but are not limited to, criminal, verification of residence, credit, motor vehicle and state insurance records. Should The Cigna Group decide to offer you a position, you would be required to sign an Authorization for Release form. Your actual employment would depend on satisfactory reports from these checks.

Clicking "Submit" on the following page grants The Cigna Group permission to contact your schools, professional organization and previous employers (including current employer), and releases them from any liability resulting from providing the information requested.

Should you become an employee of The Cigna Group and receive any overpayment of salary or benefits (including short-term disability), The Cigna Group may, to the extent allowed by law, recover overpayments by taking deductions from future paychecks or any unused vacation days.

If you are subject to any agreement with any current or previous employer, including but not limited to, any non-solicitation or non-compete agreement or policy, you represent that it will not prevent your becoming an employee of The Cigna Group nor prevent you from performing all the duties and responsibilities of the position with The Cigna Group for which you applied, or to which you are assigned, if hired. You further agree that if any agreement(s) with any current or former employers prevent you from performing any tasks or duties as assigned to you by The Cigna Group, that you will immediately bring such to the attention of The Cigna Group. If The Cigna Group determines that any agreement(s) interfere with your ability to perform any assigned duties or tasks, The Cigna Group reserves the right to re-assign you to a different position within The Cigna Group or conduct disciplinary proceedings.

During your employment with The Cigna Group, you will have access to our proprietary and confidential information and are reminded that this valuable information is to be used for the exclusive benefit of The Cigna Group and, without proper and appropriate authorization in writing from The Cigna Group, may not be disclosed, used or reproduced.

We also want to remind you of your obligation to preserve the trade secrets and confidential information of your current and prior employers. In this regard, you must not bring any such materials to The Cigna Group or otherwise use such materials as part of your work for The Cigna Group.

I understand that if hired by The Cigna Group, nothing in this application and nothing at any time communicated to me about my rights as an employee, regardless of source, limit in any way my right to resign from my employment with The Cigna Group company at any time for any reason or my employer’s right to withdraw an offer of employment, or to terminate my employment in compliance with the Kenyan Employment Laws.

I agree that in return for being considered for employment and/or receiving an offer of employment, I will resolve any dispute about my candidacy for employment, employment or cessation of employment exclusively through the internal and external employment dispute resolution process of my employer, which includes final and binding arbitration with a neutral arbitrator, I understand that my employer also agrees to follow the dispute resolution processes and that copies of the policies and procedures describing the dispute resolution processes are available to me.

I agree to fulfill all of the requirements listed above and understand that any misrepresentation or omission of facts on this employment application is sufficient cause for disciplinary proceedings under the Kenyan Employment Laws.

I understand that The Cigna Group routinely delivers information, including important notifications, electronically, and I agree to accept these notifications electronically.