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Job Applicant Privacy Notice

California, EMEA – Job Applicants/Candidate Notice

Last updated: November 19, 2025

If you are applying to work for Covington (the “Firm”), either in the legal or professional side of the firm, this notice describes how and why we collect your personal data, along with how it will be used in connection with our recruitment and hiring activities.

This notice does not apply to information that we collect outside the recruitment and hiring context. If you are engaged for a position, then the processing of your personal information will become subject to our employee privacy notice. For more information about how we collect, use, and disclose personal data in other contexts, please visit https://www.cov.com/en/privacy-policy.

Personal Data We Collect About You

We may collect the following categories of personal data about you, including directly from you, at various stages throughout the recruitment process. This may vary depending on jurisdiction and may include:

  • Name and contact information, such as name, postal and electronic address, phone number, and other contact details, including emergency contacts.
  • Copies of governmental identification documents and national or government identifiers, such as driver’s license, passport, social security number, residency and work permit status, and other identification documents and numbers.
  • Professional or employment-related information, such as Curriculum Vitae (“CV”), resume, professional qualifications, professional licenses, work experience, professional areas of interests, performance and learning and skills information, and employment contract details (if applicable).
  • Education information, such as educational history, academic qualifications, and academic transcripts.
  • Assessments and interview information, such as interview notes and recordings, assessment feedback, test results, and, where permitted by law, background check information.
  • Demographic data, which may include protected classifications under applicable law, such as age, gender, marital status, military or veteran status, race, ethnicity, national origin or nationality, visa number or immigration details, or information relating to proof of eligibility to work and details of any work permit application.
  • Internet and electronic network activity information, such as sign-in, account, and device information, including online and device identifiers, and information about your interactions with the Firm’s websites or social media pages.
  • Information about your activity within the Firm or Firm events, such as a log of your access to facilities, images or footage obtained from closed circuit televisions (“CCTV”) cameras and photographic images and other information we collect for badge issuance and other security and compliance purposes.
  • Financial information, including bank account and billing address.
  • Geolocation information, such as your address or zip code.
  • Inferences drawn from any of the information we collect about you, including inferences that reflect your preferences, characteristics, or abilities.
  • Other information we collect or process in connection with our recruitment process, including travel information and feedback and survey information.

In jurisdictions where a legal basis is required in order to process personal data in connection with our recruitment process, we may rely on the fact that the relevant processing serves a legitimate interest of the Firm, is the product of a legal obligation applicable to the Firm, takes place with your consent or the performance of a contract. The legitimate interests served may include the processing of personal data to assess your suitability for the role and fit for the firm, to plan and administer events, and to secure the Firm’s workplace, assets, personnel, and data.

Some of the above categories of personal data may be considered sensitive personal data or special category data under applicable law. We only use sensitive personal data only in accordance with applicable law, such as to address your request for an accommodation.

How We Collect Your Personal Data

We may collect your personal data from the following sources:

  • Directly from you, such as when you submit an application or otherwise interact with us or provide us with your personal data.
  • Recruiters, recruitment agencies, job boards, platforms or websites.
  • Publicly available sources such as LinkedIn and other social media sites.
  • Prior employers (e.g. for references).
  • Educational institutions.
  • Credentialing and licensing organizations.
  • Third party sources that may include data brokers as a result of background, screening, reference checks. This may include criminal background checks, or government and military clearance.

How We Use Your Personal Data

We may process your personal data for the following business purposes to the extent permitted by applicable law, such as:

  • Determining your eligibility for current and future positions within the Firm, such as processing your application or assessing your eligibility and qualifications for positions.
  • Conducting Firm business, including to manage travel, expense reimbursements, and conflicts of interests, manage Firm resources and Firm resource groups, and plan and manage marketing, alumna and other events we host or run.
  • Managing professional development and performance, including to evaluate performance and determine eligibility and qualifications for current and future positions within the Firm.
  • Assessing and promoting equality of opportunity, as permitted by law. For example, the Firm may ask for your demographic information to understand the demographics of Firm applicants.
  • Ensuring the safety and the security of the Firm’s workplace, workers, data, and Systems, including by managing, monitoring, protecting, and improving our Systems, administering background checks as permitted by applicable law, protecting against other malicious or illegal activity, and prosecuting those responsible. We also may need to process your information in connection with preventative and occupational medicine and emergency situations, such as to monitor and prevent the spread of communicable diseases in the workplace, administer first aid, or contact your emergency contact in the event of an emergency.
  • For other legal and compliance purposes, including those relating to tax and anti-discrimination laws, to exercise and defend against legal claims, and to comply with our other legal obligations.

How We Disclose Your Personal Data

We may share your personal information among our various offices and as required by our business needs. In addition to uses and disclosure of your personal data within the Firm, we may disclose your personal data with certain third parties including, but not limited to, insurers, service providers, public bodies, or in the event of a corporate transaction modifying the structure of the Firm. For example, your personal data may be disclosed to the following categories of recipients for the following reasons:

  • Authorized Third Parties and Service Providers: We may disclose your personal data with entities that provide services to us, including companies that help us provide and manage job applications.
  • Other Parties for Legal, Contractual, or Compliance Purposes: We may make personal data available to third parties to comply with our legal obligations, government clearances, or contracts or respond to a court order, administrative or judicial process, such as in the event of a subpoena, government audit or search warrant, lawful request by public authorities, or to seek legal or professional advice from external professionals. For example, we may provide demographic and reporting information to government agencies or as otherwise required by law.
  • Other Parties in Connection with Business Transactions: We may disclose your personal data in connection with a merger, acquisition, or similar corporate transaction, or in the event of insolvency, bankruptcy, or corporate reorganization.
  • Other Parties with Your Consent: In addition to the disclosures described in this Employee Notice, we may disclose information about you with other third parties when you consent to or direct such disclosures.

International Transfers

We may transfer your personal data to recipients located outside your resident jurisdiction, such as when we share information with Covington offices in other countries. These recipients may be in countries that offer a lower level of privacy protection than your home country. Within Covington, we have implemented measures, such as standard data protection contractual clauses, to ensure that transferred information remains protected and secure to the same standard no matter which of the Firm's offices your data is processed or accessed from. With respect to other parties, we implement various safeguards and controls to protect your personal data, including as appropriate contractual controls, where required by law.

Retention of Your Personal Data

We will retain your personal data collected as part of recruitment and hiring, including sensitive personal data, for as long as necessary to fulfil the business purposes described in this notice.

To determine the appropriate retention period for your personal data, we will consider the following criteria: (i) the amount, nature, and sensitivity of the personal data, (ii) the potential risk of harm from unauthorized use or disclosure, (iii) the purposes for which we process your it and whether we can achieve those purposes through other means, and (iv) any applicable legal requirements.

Children’s Information

We do not knowingly collect or store personal information from children under the age of 18, unless permitted by law or at your direction. If we learn that we have collected personal information from a child under age 18, we will delete that information.

Your Rights

Depending on where you live, you may have the following rights subject to the exceptions allowed by law:

  • To access your personal data or other information about our data processing practices, such as a copy of our transfer clauses
  • To rectify or update your personal data
  • To erase your personal data
  • To receive a copy of your personal data
  • To object to or restrict the processing of your personal data, including for marketing purposes
  • To withdraw your consent, such as where we have relied upon your voluntarily consent to process your personal data
  • To lodge a complaint with the supervisory authority, Attorney General or similar authority for data protection, or privacy in your country or state

For purposes of California law, we do not “sell” or “share” (as those terms are defined by the CCPA) the personal data of job applicants.

To exercise your privacy rights, including your right to appeal a decision we made on your request, please email us at privacy@cov.com, call us at 1-888-678-5231, or contact us at the address listed at the end of this notice. In order to protect your personal data from unauthorized access or deletion, we may ask you to provide additional information so that we can verify your identity. You may also designate an authorized agent to exercise these rights on your behalf in which case we will require documentation attesting that the person acting as your agent is authorized to act on your behalf. You may also appeal a denial of your request by contacting us at privacy@cov.com or at the address listed below.

We will not retaliate against you for exercising these rights.

Changes to this Privacy Notice

We may update this notice at any time, and we will make an updated copy of any such notice available on our website.

Further Information

If you have a concern or a question relating to this notice, please contact privacy@cov.com.

Further information about Covington offices can be found here.