STARBUCKS JOB APPLICANT AND NON-PARTNER PRIVACY STATEMENT

STARBUCKS JOB APPLICANT AND NON-PARTNER PRIVACY STATEMENT

At Starbucks, we put people first, including you—our job applicants, professional service providers, contingent workers, and prior full-time and part-time Starbucks employee (together, “Non-Partners”). We seek to respect and maintain your trust, including in relation to your privacy. Grab a cup of coffee and learn more below.

STARBUCKS JOB APPLICANT AND NON-PARTNER PRIVACY NOTICE

Last Revised: January 02, 2024

Overview

This Starbucks Job Applicant and Non-Partner Privacy Notice describes the types of personal data (which we will be calling “your information” or your “personal information”) that we collect from Non-Partners, how we use it, how and when it may be shared, and how to exercise your rights with respect to your information.

Our goal is to clarify how and why we process your information and to provide you with points of contact, should you have any questions about our policies or procedures. Thank you for taking the time to read and understand our data and privacy-related practices.

Contents

  1. Applicability and Scope
  2. Updates to this Privacy Notice
  3. Information We Collect
  4. Sensitive Personal Information
  5. Sources of Information
  6. How We Use Your Information
  7. How We Disclose Your Information
  8. How We Protect Your Information
  9. Network and Device Usage Monitoring
  10. Retention
  11. Transferring Your Information Overseas
  12. Your Rights
  13. Contact Us

1.   Applicability and Scope

This Starbucks Job Applicant and Non-Partner Privacy Notice (“Privacy Notice”) applies to the information collected from job applicants, professional service providers, and contingent workers (together, “Non-Partners” or “you”) during the course of your applying to work at Starbucks (as a Partner or Non-Partner job applicant) or during your placement with Starbucks (for professional service providers and contingent workers). This Privacy Notice also applies to information collected from prior full-time and part-time Starbucks employees during their course of employment at Starbucks. This Privacy Notice applies to your relationship with Starbucks Corporation and its respective subsidiaries and affiliated companies (“Starbucks,” “we,” or “us”).

This Privacy Notice provides a standard for Starbucks with respect to its protection of information. The jurisdiction where you reside may require different levels of protection. Therefore, we will handle your information in accordance with applicable laws and regulations at the place where the information is collected and processed. Where applicable local law provides a lower level of protection than that established by this Privacy Notice, we will still strive to meet the requirements of this Privacy Notice.

This Privacy Notice does not cover your use of Starbucks products or services (e.g., a Starbucks website) as a customer or any collection of information outside of the job application process or your Non-Partner engagement with Starbucks, which is governed by the Starbucks Privacy Notice which be found by visiting your local Starbucks website.

This Privacy Notice does not cover current full-time or part-time Starbucks employee (“Partners”). Starbucks Partners may access the Employment Privacy Notice found on “My Partner Info” or the “Partner Hub” to read about personal information collection and use in the employment context.

2.   Updates to this Privacy Notice

We may update this Privacy Notice from time to time. When we make material changes to this Privacy Notice, we will notify you and will update the Last Revised date on this Privacy Notice. We encourage you to look for updates and changes to this Privacy Notice on the site from which you accessed it to learn about any updates to this Privacy Notice.

3.   Information We Collect

Subject to applicable law requirements, the categories of information that we may collect, store, and use about you include:

  • Identifiers , such as your real name, postal address, date and place of birth, usernames, personal email address, and home or wireless phone number.
  • Government-issued identification numbers , such as driver’s license number, passport number, or national or state IDs.
  • Demographic information and characteristics of protected classifications , such as race or ethnicity, nationality, languages spoken, marital status, religion/religious beliefs, veterans status, and gender.
  • Employment-related information , such as:
    • effective dates and years of service, work location, current/prior work record, and other career history information;
    • information required for compliance and risk management, such as disciplinary records, garnishments, background check reports and security data; and
    • employment eligibility information, including right-to-work, alien registration status, refugee status, work permits, and residence status.
  • Education information such as your educational status, certificates and licenses, degrees earned, vocational records and in-house training attendance, including as part of resumes/CVs;
  • Internet and other electronic network activity , in particular your usage of Starbucks’ assets such as its computers and telecommunication systems (“IT”), and traffic generated on the Internet, including emails sent and received, building and information system access, and Starbucks device/system/application usage when accessing and using Starbucks buildings, networks, company-issued devices, and/or assets, and information related to a Starbucks website’s “live help” chat feature;
  • Audio, electronic, and visual information , such as photographs and video footage, subject to applicable law requirements.
  • Geolocation information about your location of your device, such as information derived from your device (e.g., based on a browser or device’s IP address) if your Bluetooth is turned on and your device settings allow for this or if your WiFi is on.

If we ask you to provide any other information not described above, then we will make clear to you what specific information we need and the reason(s) why we ask you to provide it.

We also may collect information automatically from you. For instance, when you apply to a position using the application portal on our website, we may gather information from using cookies and other tracking technologies. To learn more about our use of these technologies, please visit the “Cookies, Web Beacons, and Similar Technologies” section in the Starbucks Privacy Notice by clicking HERE.

Please note that if you decline to provide certain information when requested, we may not be able to fulfill our responsibilities (e.g., paying you or providing a benefit), or we may be prevented from complying with our legal obligations (e.g., safeguarding the health and safety of Non-Partners present in our facilities). Therefore, if you do not provide certain information, we will not be able to enter into a contract with you or accept your engagement.

4.   Sensitive Personal Information

Certain types of information may be subject to additional requirements under applicable laws. Data protection laws around the world may use varying terminology in naming these categories of sensitive data (such as “Special Categories of Personal Data” or “Sensitive Personal Information”), and also set requirements for companies to follow in their processing of such sensitive data.

Further, Starbucks may also internally identify certain categories of Sensitive Personal Information as “SPI.” Starbucks defines SPI to be any information relating to an identifiable person that includes or implies race, ethnicity, political views, religion, health, sexual orientation, genetic or biometric data, union membership, information about criminal convictions and offenses, and other categories of information defined as sensitive information under applicable laws.

  • Precise Geolocation Information – Starbucks may collect information about the precise location of your device (e.g., GPS latitude and longitude), consistent with your device settings. We may collect this location information or derive it from your GPS, WiFi, Bluetooth or other location-based technology for purposes of facilitating our services, such as to provide you with information about stores near you, to enable you to remotely order and pay for our products and services, or so that you may have certain Starbucks products delivered to you by a third-party vendor.
  • Company-Related SPI Only – Starbucks prohibits Non-Partners’ use of SPI for personal purposes on Starbucks networks and devices (e.g., sharing SPI via email, on company message boards, through company-issued devices). The only permitted use of SPI is company-related. This means that Starbucks processes and uses your SPI in two ways:
    1. as required for business and employment purposes (e.g., providing you with health benefits, recording work disabilities or injuries, etc.); and
    2. based on your consent if you use company-sponsored services or platforms that might gather SPI (e.g., a company-approved health and wellness application).

With this in mind, Starbucks processes Sensitive Personal Information to provide you with company benefits, comply with applicable laws or a valid request from law enforcement or courts, and/or to protect your data from cybersecurity threats. If you have questions about what Sensitive Personal Information is, and/or how Starbucks handles such data, please contact the Starbucks Global Privacy Department as described in the “Contact Us” section.

5.   Sources of Information

In addition to the information we receive from you, we also receive the categories of information described above from other sources, including from government entities, data analytics providers, internet service providers, social networks, background verification providers, recruiters, agencies, market research companies, and business and service providers.

6.   How We Use Your Information

(a) Business Purposes – Starbucks requires your information to allow us to perform our duties as an employer and to enable us to comply with our legal obligations. We use your information in compliance with applicable laws, and we do so primarily to manage our relationship with you for the following business purposes:

  • To administer the Non-Partner relationship or other commitments we have made to you, including to assess qualifications for a particular job or task or to communicate with you about your application or engagement;
  • To administer pay , such as monitoring salary details and processing payment account details, and other compensation, and payroll administration (e.g., salary, tax withholding, etc.);
  • For workforce development , talent management, education, training and certification;
  • For business management and operations , such as to generate business analytics, to interact with you through a Starbucks website’s “live help” chat feature, and to conduct fraud prevention;
  • For professional issues resolution , such as in relation to grievances, auditing, conflict of interest reporting, or to gather evidence for disciplinary action or ending an engagement;
  • To identify a contact point in the event of an emergency , to further the health and safety needs for our workforce;
  • For accounting, financial reporting and business planning ;
  • To ensure the safety and the security of Starbucks-held information, including as part of business continuity planning and disaster recovery, and risk and security incident management;
  • As required or expressly authorized by laws or regulations applicable to our business or by government agencies that oversee our business, or as part of legal proceedings and government investigations, including preservation of relevant data; and
  • For any other business purposes that are reasonably required by Starbucks in connection with application for and during the course of your application process or engagement with Starbucks.

(b) Compatible Purposes – We use your information as reasonably necessary for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose and there is a legal basis for further processing, if required.

(c) Accuracy – It is important that the information we hold about you is accurate and current. Please keep us informed if your information changes during your working relationship with Starbucks.

(d) Specific Consent – Depending on the location in which you reside, local laws may require that you provide specific consent for the collection, use and disclosure of your information for some of these purposes. Where required, you may be asked to provide your consent by appropriate and permitted means.

7.   How We Disclose Your Information

Starbucks disclose your information as needed to fulfill the purposes described in this Privacy Notice and as permitted by applicable law. The circumstances for which we may disclose your information include the following:

(a)   When We Work Together – We may share information between and among Starbucks Corporation, its subsidiaries, and affiliated companies for purposes of management and analysis, decision making, and other human resources and employment-related business purposes.

(b)   When We Work with Service Providers & Other Third Parties – We may share identifiers, commercial information, electronic and network activity, geolocation and precise geolocation information, audio and video information, and inferences, as described above, for a variety of business purposes, such as such as payroll services and administration, IT services and website hosting, health and safety compliance, facilities management, email and postal delivery, and to and enable a Starbucks website’s “live help” chat feature.

(c)   When We Work on Business Transactions – If we become involved with a merger, reorganization, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.

(d)   When Sharing Helps Us Protect Safety and Lawful Interests – We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, if we believe it will assist in the investigation of suspected or actual illegal activity, or if we believe that the disclosure will help us protect the rights, property, or safety of Starbucks, our customers or our partners.

(e)   When You Give Consent – We may share information about you with other companies if you give us permission or direct us to share the information, in accordance with applicable law.

Please note that there may be certain situations where you will be asked or have the option to disclose your information directly with providers connected to Starbucks Partner or Non-Partner services, where Starbucks does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such providers.

Starbucks has not sold and will not sell any Non-Partner information or share any Non-Partner information for purposes of cross-contextual behavioral advertising.

8.   How We Protect Your Information

Starbucks uses reasonable technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. However, no security system is perfect, and due to the inherent nature of the internet, we cannot guarantee that data, including your information, is absolutely safe from intrusion or other unauthorized access by others. We ask that you be responsible in protecting your password(s) and maintaining the security of your devices.

9.   Network and Device Usage Monitoring

Where permitted by applicable law, Starbucks monitors some network and device usage, as we have an obligation to protect our workforce, assets, and facilities. Starbucks monitors its networks and devices for two purposes: (a) to protect the security of our workforce, data, networks, assets, facilities, reputation, and competitive interest; and (b) to investigate suspected or confirmed misconduct under Starbucks policies or violations of law (including in support of litigation). Any and all telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by a Non-Partner on any Starbucks-managed electronic device or system, including but not limited to hardware such as computers, laptops, tablets, mobile devices, key fobs, video or audio recording devices, GPS units and/or Starbucks -licensed and approved software, may be subject to monitoring at any and all times and by any lawful means. This monitoring is consistently handled in compliance with Starbucks policies and relevant laws, including the EU General Data Protection Regulation (2016/679), on the basis of legitimate interest.

We also may monitor Starbucks office premises by security footage or badge scans.

Please note that any Non-Partner message, file, data, document, electronic communications, social media posts, or any other types of information transmitted to or from, received or printed from, or created, stored, or recorded on our IT and communications systems and assets (including company-issued devices) are presumed to be Starbucks Employer business-related, and we may monitor it in accordance with this Privacy Notice and other company standards, including in relation to the use of company equipment and infrastructure. Therefore, you should have no reasonable expectation of privacy with respect to your use of our IT and communications systems and assets.

We recognize that any monitoring that we perform may impact our Non-Partners’ privacy. We strive to ensure that any monitoring we perform is proportionate to the limited and specific purposes needed and conducted as required or permitted by applicable law.

10.   Retention

(a)   Data Retention Purpose and Location – Starbucks stores your information as reasonably necessary and proportionate to accomplish the purposes identified in this Privacy Notice based on criteria such as the length of time of your employment, and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. This storage period may extend beyond the term of your job application process or engagement with Starbucks. Our retention of your information is subject to applicable law.

The information that you provide us is stored and processed on servers owned by Starbucks and other companies in the United States, Canada or elsewhere around the world, including locations that may be outside of the country or jurisdiction where you are located. Regardless of the entity or person who processes your information and where it is processed, we will take steps to transfer and protect your information through appropriate safeguards in accordance with applicable data protection laws and this Privacy Notice.

(b)   Retention Period – When your information is no longer needed or, in any event, after legal authority to retain it has expired, your information may be destroyed, in accordance with applicable law and pursuant to procedures established in relation to the relevant Starbucks system or process.

11.   Transferring Your Information Overseas

Starbucks is a global business. As noted above, we and our service providers may collect, use, process, store or disclose your information outside your home country or jurisdiction, including in the United States and elsewhere, that may have different data protection laws than the laws where you reside or work.

Please note that Starbucks would only transfer non-partner information to another country (including to affiliates and subsidiaries within the Starbucks corporate group) in accordance with applicable laws and this Privacy Notice.

12.   Your Rights

(a)   Non-California Residents

Generally, our job application portals and self-service tools allow you to view and update the personal information that Starbucks holds about you. If we have certain information about you that you cannot access via these self-service systems, or if we have information about you that you believe is inaccurate or no longer relevant, and you would like us to correct or delete such data, then you may make a request as described in the “Contact Us” section.

(b)   California Residents

If you are a California resident, you are entitled to certain rights with respect to your information, as described below.

  • Right to Know – You may have the right to know what information Starbucks has collected about you, including the categories of information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it. This information is provided in this Privacy Notice.
  • Access and Data Portability – Subject to certain exceptions, you may have the right to request a copy of the information that we collected about you during the 12 months before your request.
  • Deletion – You have the right to request that we delete information that we collected from you and retained, subject to certain exceptions.
  • Correct Inaccurate Information – You may have the right to request that we correct inaccuracies in the information we maintain about you.

Non-Partners who are California residents may submit a request through this form HERE or by calling 1-800-STARBUC (782-7282). Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may be entitled to submit a request through an authorized agent. To designate an authorized agent to exercise your rights, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

Privacy Rights Metrics (January 2023 – December 2023)

Right to Know

  • 31 Requests received
  • 8 Requests complete
  • 23 Requests unable to be completed*
  • 37 days Average completion time

Right to Delete

  • 25 Requests received
  • 5 Requests complete
  • 20 Requests unable to be completed*
  • 31 days Average completion time

*Requests may be unable to be completed due to factors such as inability to verify the customer, duplicate requests, or no information found.

13.   Contact Us

If you have questions about this Privacy Notice or our personal information practices, please contact the Starbucks Global Privacy Department and Data Protection Officer at privacy@starbucks.com.