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IBM Talent Acquisition Privacy Notice

Privacy Notice—effective as of 1 August 2023

This Privacy Notice supplements the IBM Privacy Statement and describes data privacy information related to IBM's recruitment and hiring process.

IBM takes your personal information protection seriously and respects local data protection laws.

This Privacy Notice explains how IBM processes your personal information during the recruitment and hiring process to progress your application, which may culminate in the entering into a contract with you.

This privacy notice applies to IBM Corporation and IBM subsidiaries except where a subsidiary presents its own statement without reference to IBM’s.

We request that you read this Privacy Notice.

1. What personal information will IBM process about you?

1. Personal information you provide, although it will vary by the country and nature of the role for which you will be considered, which may include:

  • Your first name and last name, address, email address, phone number(s), education history, work experience, CV, resume, information about your primary country of residence and citizenship, additional countries of interest, the country you are applying to and the eligibility to work there, areas and communities of interest;

  • Whether you have ever worked for IBM or an IBM Business Partner, whether you have any government experience and if you signed any or accepted any agreement or are otherwise subject to any restriction with your current or former employers;

  • Depending on the country, criminal records information, observing the applicable laws and where an offer of employment has been made to you;

  • Depending on the country you are applying your disability, ethnicity, gender, race and religion;

  • Whether you require any accommodations or adjustments.

You will receive more information about the nature of the pre-employment verification checks before they begin.

2. Personal information processed during the recruitment process, although it will vary by the country and nature of the role for which you will be considered, which may include:

  • Any cover letter or personal statement you provide;

  • Any references you provide, or IBM takes up to validate the information you’ve provided;

  • Any interviewer or recruiter notes from their interactions with you or with the IBM employee who recommended you;

  • If during the recruitment process you complete a video-enabled assessment, we may store the video recordings of the assessment;

  • If during the recruitment process you complete a coding assessment, we will record and store any code created in response to the given exercises. Additionally, we will store one or more webcam photos of you completing the exercises;

  • Any other information you give us.

3. Personal information processed if you receive and accept an IBM offer of employment, such as your email address, first name, middle name, last name and IBM employee Talent ID may be used from the date of offer acceptance.

2. For what purposes IBM will process your personal information?

In response to your application or your interest in job positions, your information will be used by IBM as necessary to:

  • Verify your information and conduct relevant and appropriate legally permitted pre-employment and eligibility verification checks, and to assess your skills, qualifications and experience;

  • Comply with local, national or international laws, obligations and legal requirements;

  • Communicate with you about IBM events, career opportunities and the recruitment process including any interviews;

  • Contact you for other, future roles that may be of interest to you and aligned with your skillset;

  • Complete the selection process;

  • Conduct surveys and research activities with the objective of improving IBM’s recruiting process;

  • Perform analysis of our applicant pool to better understand who is applying to positions at IBM and how to attract top talent;

  • Where legally permissible, we may ask you to voluntarily disclose your disability, ethnicity, gender and nationality, to help IBM with its diversity and inclusion programs (such as to assess the IBM workforce, and promote benefits and inclusive policies for the related population);

  • Enable you to access the IBM On Boarding site and the Your Learning application which may help you to become familiar with the company, understand where and how you fit into the organizational structure and assist with your integration into the culture of the workplace.

By submitting your application, you authorize IBM to store your personal information in IBM’s recruitment tools for the secure storage of your data whilst your application is assessed and otherwise as set out above.

3. For how long will we retain your personal information?

If you are given and accept an offer of employment by IBM, the personal information collected during your pre-employment period may become part of your employment record on IBM’s personnel records Employment Data System, to be retained throughout and for a period of time after your employment with IBM (specific periods vary by country).

If IBM does not employ you, IBM will retain your personal information according to the document retention policy after which your personal information will be erased from the recruitment systems.

4. With whom and why we share your personal information?

Your information may be accessed by and shared with IBM recruiters, IBM Recruitment Process Outsourcing, IBM Talent Acquisition focals, and hiring managers of IBM in the relevant IBM subsidiaries, who are involved in the recruitment process on a need-to-know basis, as relevant and necessary for your application for the role you are being considered for. This includes IBM subsidiaries publishing job advertisements on a non-IBM website or the subsidiary’s website. Where an advertisement is posted on a non-IBM website or the subsidiary’s website, please refer to the Privacy Notice published on such website for further details regarding the processing of your personal information.

In some cases, IBM shares your personal information with third parties if legally required or allowed, to achieve the purposes informed above. Depending on the geography, these third parties are suppliers of human resource information systems, used by IBM, as well as suppliers related to occupational health and safety management services systems.

Your information may be accessed by government officials where legal reporting requirements may exist, or law enforcement agencies or private litigants in response to valid law enforcement processes (warrant, subpoena, or court order).

If your prospective management line is out of the country, we may transfer your personal information from the country to which you applied to other people within the same function in one or more IBM subsidiaries in other countries as applicable for the purpose of processing your application, ensuring that your data is processed according to local laws and IBM requirements.

IBM has implemented various safeguards to keep your personal information protected, wherever it may be, including:

  • Contractual Clauses, such as those approved by the EU Commission and accepted in several other countries. You can request a copy of the EU Standard Contractual Clauses (EU SCCs) here.

  • Binding Corporate Rules for Controllers (IBM BCR-C). We have BCR-C approved by the European Data Protection Authorities and the UK Information Commissioner’s Office. For more information, see IBM Controller Binding Corporate Rules (Employee Information).

  • IBM’s privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure the protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here (link resides outside ibm.com).

More information can be found here.

5. Your rights

You have certain rights when it comes to the handling of your personal information. Information regarding these rights, including information on how to make a complaint, can be found in the section “Your Rights”. You can contact us about your rights, ask questions about IBM’s Privacy Statements and privacy practices, submit data rights requests or submit a complaint using this form. You may also access and correct personal information you have submitted regarding your application online by logging into the IBM Careers portal (link resides outside ibm.com) or by contacting ibmopps@us.ibm.com.

Please be aware that depending on the circumstances, if you request us to delete or otherwise stop processing your personal information, we may not be able to proceed with your application, as it may depend on the analysis of such personal information.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our US-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request (link resides outside ibm.com).

6. Legal basis

In some jurisdictions, the lawful handling of personal information is subject to a justification, sometimes referred to as a legal basis. The legal bases that we rely on for the lawful handling of your personal information vary depending on the purpose and applicable law.

The different legal bases that we may use are:

  • Necessary for the performance of a contract with you

We rely on this legal basis to process your personal information for the purposes of preparing to conclude or concluding an employment contract with you.

  • Necessary for the purposes of IBM’s legitimate interest

We rely on our legitimate interests when processing your personal information for the purposes of sourcing suitable talent for IBM’s workforce.

  • Consent

The processing of your personal information is based on your consent where we request this.

  • Legal obligation

We rely on this legal basis to process your personal information due to obligations stemming from, for example, local labor or tax laws.

7. General

More information on how IBM handles your privacy and the identity of the Controller of your personal information can be found at https://www.ibm.com/privacy.

8. Declaration and confirmation

You declare and confirm that the information you have provided as part of your application is true and complete. You must promptly update any information you have provided as and when there are changes.

You understand that any misrepresentation or deliberate omission of fact may lead to IBM’s termination of your employment or consideration for employment.

We may change this policy from time to time. We will post any changes to this policy on this page.


In carrying out the purposes listed above, the information collected may be used and disclosed to entities inside and outside Australia (to countries including New Zealand, the United States of America and the Philippines).

IBM is required under the Australian Privacy Act 1988 (Cth) to inform you of the following before you can provide consent for us to transfer your personal information outside of Australia: the Australian Privacy Principle (APP) 8.1 requires the disclosing entity to take such reasonable steps to ensure that the overseas recipient does not breach the APPs. APP 8.1 would not apply to your personal information once you provide your consent. While the overseas recipient may be regulated by other data privacy legislations, it is not subject to the Privacy Act 1988 (Cth), and as such your rights and remedies under the Privacy Act 1988 (Cth) would not apply as against the overseas data recipient.

Where permitted by law, IBM may disclose the information to the relevant Australian Federal or State Government or other authorized parties at their request.



I agree IBM, to retain my personal data for 2 (two) years. I am aware that I am entitled to request any time information and to request correction or deletion of the personal data in accordance with the applicable legislation via: https://www.ibm.com/privacy. In case of violation of my rights regarding the protection of personal data, I have the right to submit a claim at the competent Bulgarian Commission for Protection of Personal Data (link resides outside ibm.com).


California residents, review our notice and your privacy choices.


AODA, AMA, and the Ontario Human Rights Code IBM are committed to compliance with the Accessibility for Ontarians with Disabilities Act (AODA) (link resides outside ibm.com), Accessibility for Manitobans Act (AMA) (link resides outside ibm.com) and the Ontario Human Rights Code (link resides outside ibm.com) in the recruitment process. If you are an individual with a disability that requires a reasonable accommodation or are unable or limited in your ability to use or access our recruitment tool as a result of your disability, you can request reasonable accommodations in the recruitment process by sending an email to recrops@ca.ibm.com.



We draw your attention that you can submit your claims on data handling which will be investigated and remedied as soon as possible but not later than 1 (one) month. In case of a breach in your personal information, you can submit a claim to the National Authority for Data Protection and Freedom of Information (link resides outside ibm.com) according to section 22 of the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information. Also, in case of a breach, you are entitled to claim reimbursement according to the Hungarian Civil Code. In case of such a request, we provide you with detailed information about the remedy options. You are further advised that your ID and password will be deleted 12 months from the time your application process concludes or the last time you had access to this tool. By applying to the specific position and/or sharing your CV with us, you are hereby confirming to be informed about and explicitly accepting the above terms.


In carrying out the purposes listed above, the information collected may be used and disclosed to entities outside New Zealand (to countries including Australia, the United States of America and the Philippines).

IBM is required under the New Zealand Privacy Act 2020 to inform you of the following before we can provide your consent for us to transfer your personal information outside of New Zealand: while the overseas recipient may be regulated by other data privacy legislations, it may not be subjected to the Privacy Act 2020. As such, the overseas recipient may not be required to protect your personal information in a way that, overall, provides comparable safeguards to those under the Privacy Act 2020.

Where permitted by law, IBM may disclose this information to the New Zealand Government or other authorized parties at their request.



Providing additional personal information during the application process (for example, photo) indicates your explicit, informed and freely given consent to the processing of any additional data contained in the application documents as per the guidance provided by the Urząd Ochrony Danych Osobowych.

Last updated: 1 August 2023