Colombia Privacy Policy

PRIVACY STATEMENT FOR JOB APPLICANTS AND SUCCESSFUL CANDIDATES - COLOMBIA

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Our company, UnitedHealth and the companies listed in the “Contact Information” section (collectively, the “Company”), strives to properly address applicable data protection and privacy legal requirements.

The primary data controller in respect of your Job Applicant and/or Successful Candidate Data (collectively, "Candidate Data") is the entity with which you are applying for employment as listed below in the “Contact Information” section.

SCOPE

This Privacy Policy for Job Applicants and Successful Candidates' Data (“Privacy Policy”) provides the individuals who apply for employment with and/or who have been offered employment by the Company in Colombia ("Job Applicants" and "Successful Candidates" respectively) with certain important information about how the Company handles their personal information. This Privacy Policy does not apply to job applicants or successful candidates located outside of Colombia.

TYPES OF CANDIDATE DATA COLLECTED

Candidate Data is provided by Job Applicants and Successful Candidates, and includes (among others) the following types of data:

Name
Date of Birth
Address
Email Address
Telephone Number (landline and mobile)
Curriculum Vitae
Employment history
Education history
Referee contacts
National Insurance Number/social security number/national identification number
Residency status, national identification, passport or visa number;
Gender
Nationality
Place of Birth
Marital Status
Language skills
Disability-related information
Health screening
Race or ethnicity

Some of the above information may also be considered sensitive personal information, such as information related to screening for certain positions, pre-employment health screens, a disability status when applicable for eligibility for certain programs, voluntary information a Job Applicant or Successful Candidate may provide to us related to their race or ethnicity in support of a diverse and inclusive workforce, or voluntary information workers may provide us about minors related to administration of benefits. Job Applicants and Successful Candidates are not required to provide consent to processing of sensitive personal information and such processing will occur as set out in this policy and as required or permitted by applicable local law.

PURPOSE OF COLLECTION AND USES, LEGAL BASES, AND DISCLOSURES OF CANDIDATE DATA

The Company will only use and otherwise process Candidate Data:

of Job Applicants for recruiting and job placement purposes including notification of future job opportunities and opportunities in UnitedHealth companies and the companies listed in the “Contact Information” section;
of Successful Candidates for on-boarding purposes and background screening, including enrollment in payroll and applicable employee benefit schemes, preparation of employment contract, and other administrative purposes necessary for the Successful Candidate to commence employment with the Company;
of Job Applicants or Successful Candidates for communicating with them via phone and electronic channels (e.g., email) and post; and
of Job Applicants or Successful Candidates for promoting equality, diversity and inclusion.

Company’s legal bases to use and process Candidate Data is your consent. The Company’s processing is necessary for:

compliance with Company’s legal obligations, such as accounting, compliance, and tax requirements and sanctions screening;
the performance of the employment contract between the Company and Successful Candidates; and
for the purposes of carrying out the obligations and exercising rights under employment law.

Job Applicants or Successful Candidates, may subsequently withdraw at any time by contacting us via the information in the “Contact Information” section, without affecting the lawfulness of processing before its withdrawal.

As necessary in connection with these purposes, authorized processors and limited members of the Human Resources department, the Finance department, the IT department, and immediate superior Company managers may access and otherwise process Candidate Data in connection with their job responsibilities. Some of these personnel may be located at various global locations outside of Colombia, including in countries that may not provide the same level of data protection as the home country of the Job Applicant and Successful Candidate. The Company takes appropriate steps to ensure that such personnel are bound to duties of confidentiality with respect to Candidate Data, and the Company implements measures such as data protection clauses to ensure that any transferred Candidate Data remains protected and secure. The processing of Candidate Data are only for the purposes outlined in this policy and in accordance with applicable law.

USE OF CANDIDATE DATA FOR BACKGROUND CHECKS AND WHO WE COLLECT DATA FROM

Offers of employment with the Company may be subject to and conditional upon the completion of certain background checks which are permitted by applicable laws including searches of the following databases:

databases relating to serious and organised crimes, databases managed by regulatory and compliance authorities, web and media databases, and global sanctions and watch lists managed by financial regulatory bodies and law enforcement agencies);
standard sanctions databases (UN, EU, U.S. lists, etc.) in compliance with economic sanctions laws throughout the world; and
for Employees who may work on government programs, including, but not limited to United States Federal or State government programs, United States Federal and/or State debarment or exclusion lists or other such lists required by law or contract.

Candidate Data provided by the Successful Candidate following an offer of employment may be used to facilitate the conduct of Background Checks. No Background Checks will be undertaken prior to an offer of employment being made. a

Successful Candidates may be requested to provide information related to their family members who hold government positions in order for the Company to assess potential conflicts of interest. When providing this information, it is the responsibility of the Successful Candidate to obtain the family member’s permission to disclose such information to the Company.

Due to the nature of the Company's business, it will carry out regular and ongoing screenings of the databases listed above during the course of employment to ensure that the Successful Candidate remains suitable for a position with the Company and are permitted without exception to provide services to all of the Company's clients and in particular to organisations who prohibit excluded or debarred individuals from working on their account. Any offer of employment will be strictly conditional on passing these screenings during the course of employment. Further information in relation to these screenings may be found in internal Company policies.

Conduct of the Background Checks may involve the collection of additional information about the Successful Candidate from educational institutions, government agencies, previous employers, information in the public domain and law enforcement agencies at the international, national or local level so far as is permitted by applicable law. If a Successful Candidate's prior employers and/or other referees are contacted, the report may include information obtained through personal interviews.

In so far as permitted under applicable local law, the information collected may include, but is not limited to, educational and professional achievement/qualifications, employment references, information freely available in the public domain, and criminal history records including enhanced disclosure where required by law for a particular position (the "Background Check Data"). If Job Applicants and Successful Candidates provide the Company with data of third parties (such as former employers, referees, etc.), it is the responsibility of Job Applicants and Successful Candidates to ensure that the communication of such data to the Company and further processing by the Company according to this Privacy Policy is lawful.

TRANSFER OR TRANSMISSION TO THIRD PARTIES

The Company uses third party vendors for certain services, including:

the online recruitment portal in which Job Applicants enter and submit their application; and
the conduct of the Background Checks described above.

Your personal information may be transmitted or transferred to the companies listed in the “Contact Information” section and UnitedHealth companies operating in countries inside or outside of your home country. In addition, service providers with whom information is shared may be based outside of your home country. Data protection laws may or may not apply in jurisdictions outside of your home country or may not be as stringent as those in your home country. The Company will address any applicable requirement to assure that the operation is in accordance with applicable law, such as adequacy decisions. In any case, the Company will implement appropriate contractual measures to ensure that the relevantUnitedHealth companies and third parties outside your home country provide an adequate level of protection to your personal information as set out in this policy and as required by applicable local law.

RETENTION OF CANDIDATE DATA AND BACKGROUND CHECK DATA

Candidate Data and Background Check Data will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

When a Successful Candidate enters employment with the Company, his or her Candidate Data and relevant Background Check Data may be transferred to an employee personnel file and may be processed and retained in accordance with applicable law or the Company's Data Protection Policy from time to time in force, a copy of which is available on the Company intranet or at offices.

DATA SECURITY AND DATA INTEGRITY

The Company maintains reasonable security measures to safeguard Candidate Data from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction. The Company also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

The Company has tools to oversee the sharing of information that takes place through platforms, email, systems, etc., which it uses for the purpose of avoiding inadequate treatment, unsafe or illegal practices for which it reserves the right to access, monitor, and oversee by any means, the information, data packet, content, systems, services and equipment that share or are connected to the Company’s computer network (“Security Monitoring”).

RIGHTS

Job Applicants and Successful Candidates are entitled to request access to, updates, rectification, correction, or amend of their own Candidate Data, erasure of their own Candidate Data, to be informed and know about the processing of their own Candidate Data, evidence of their consent to processing, withdraw consent, and to cease processing of personal information in accordance with applicable law and Company policy. Requests should be submitted in writing (an email message is acceptable), to the Data Protection Officer using the information below in the “Contact Information” section.

If a Job Applicant or Successful Candidate is aware of changes or inaccuracies in his or her Candidate Data of which the Company is not aware, he / she should inform the local Human Resources department of such changes so that the Candidate Data may be updated or corrected, using the information below in the “Contact Information” section.

Candidate Data from Job Applicants will be retained on file, to be used for future employment opportunities, subject to applicable law on retention of personal information. If at any point before a Job Applicant is offered employment they wish to have their application information removed from the recruitment database, the Job Applicant should send a written request to the local Human Resources department with the subject line "Please remove me from your Recruitment database" using the information below in the “Contact Information” section. Notwithstanding such a request, certain information may be retained as required by applicable law. Inactive job applicant profiles will be deleted after one year.

Should you make a request to access the information we hold about you, we may require that you provide us with further information so that we can be satisfied of your identity, subject to any applicable local restrictions.

Job Applicants and Successful Candidates may lodge a complaint with a supervisory authority if they consider that Company’s processing of their Candidate Data infringes applicable law.

DISCLOSURES REQUIRED OR PERMITTED BY LAW Regardless of any other provisions in this Privacy Policy, the Company may disclose or otherwise process Candidate Data in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by law or required for the purposes of any regulatory audit to which the Company may be subject from time to time.

INFORMATION

Job Applicants and Successful Candidates can raise any issues or exercise individual rights regarding their Candidate Data with their local Human Resources department or our Data Protection Officer by contacting the company with which you applied:

Colmédica S.A.

Nit. 800.106.339-1

Address: Calle 93 # 19-25

Tel.7565656

Bogotá, D.C.

www.colmedica.com

Email: direcciondegestionhumana@colmedica.com

Aliansalud EPS S.A.

Nit. 830.113.831-0

Address: Calle 63ª # 28-71

Tel. 756 80 00

Bogotá, D.C.