Employee and Applicant Privacy Policy and Notice at Collection

Article author
Jason
  • Updated

Last Updated: 29 May 2026

This Privacy Policy (“Policy”) describes how Scribd, Inc. (“the Company”, “we,” “our,” “us”) collects, uses, and discloses and otherwise processes information of its employees, former employees, job applicants, contractors, officers, directors or owners (“you” or “your”) who are subject to the California Consumer Privacy Act of 2018 (“CCPA”), the European Union or United Kingdom’s General Data Protection Regulation (“GDPR”), or other similar laws concerning the processing of such individuals’ personal information. 

If you have questions about this Policy or wish to exercise your rights and choices, please contact us as set forth in the section entitled “Contact Us” below.

Personal Information We Collect 

We collect personal information at different stages of your relationship with Scribd, Inc., including when you apply for a role, during onboarding, and throughout your time with the Company. We collect, and in the past 12 months have collected, the following categories of personal information:

  • Identifiers, including name, postal address, email address, social security number, government issued identification (such as driver’s license number or passport number), telephone number, emergency contact information, device identifier and unique personal identifier.
  • Protected Classes, including race, age, gender, sex, citizenship status (evidence of the right to work), nationality, medical conditions and disabilities (physical or mental to provide assistance), marital status and veteran status.
  • Professional and Education History, including CV or resume, qualifications, work experience, compensation history where permissible under applicable law, language abilities, areas of expertise, education and training history, professional membership, awards and prizes, and references.
  • Background Check and Screening Information, such as, in compliance with legal obligations, education verification, criminal records and driver’s license checks.
  • Employment Information, including job title, date of commencement of employment, working hours, electronic corporate device tag or registration numbers, employee number, photograph, performance assessments, records of roles performed and applied for, appraisal and evaluation records, disciplinary and accident information, absence and leave records, compensation, incentive details, professional memberships, special work environment requests, government forms and records in relation to employment and related taxes and job profile, and termination information.
  • Geolocation data, including location-enabled services such as WiFi and GPS.
  • Financial Information, including bank account number and 401(k) details (for payroll and 401(k) contributions), salary, payroll, equity and other compensation information, tax information, expenses, and business credit card information and usage.
  • Health & Benefits Information, health, vision, and dental insurance policy number and information such as details about spouses and dependents, absences from work, disability information, allergies and intolerances, medical and ongoing health conditions. We also receive aggregate information regarding employees’ access to health benefits, but not individual usage information (which is collected and controlled by such vendors).
  • Work device and system activity such as use of the Company’s networks, information systems, and communication systems, including user IDs, passwords, IP addresses, device IDs, web logs, audit trails of system access, and copies of documents sent from Scribd, Inc. networks and Company-issued devices, as well as browsing and search history on Company computers or mobile devices, and interactions with career-related aspects of our websites or mobile applications.
  • Audio or visual information, such as CCTV footage, and other information relating to the security of our premises; recorded presentations in which you participate; and photographs.

Certain types of information above may be considered sensitive under relevant applicable law, such as social security number, and certain demographic information such as race and ethnic origin. As described below and in compliance with law, we only use such information as necessary for our business purposes and for our legal obligations.

How We Use Your Personal Information

We use your information for internal, lawful purposes that are compatible with the context in which it was provided. The following are the business purposes for which Scribd, Inc. uses your information:

To hire and onboard you. 

We process your information for Human Resources, and records management and related administration, including to:

  • evaluate your qualifications, including verifying references
  • provide access to systems, networks, and services
  • administer compensation, benefits, expenses, and travel
  • support budgeting and maintain business directories
  • monitor compliance with policies and assess performance
  • assign, manage, and administer workflows
  • maintain employment records, including emergency contact information
  • provide IT support, including helpdesk services
  • manage grievances and workplace issues
  • communicate updates related to your employment
  • protect systems and networks from unauthorized access

To support and improve our business operations. 

We use information to operate and improve our business, including to provide and monitor IT systems for lawful purposes; maintain accounts and internal directories; support occupational health and safety and crisis management; conduct internal analyses, audits, and business and financial planning (including succession planning); participate in due diligence activities; and administer equity grants.

To support our security operations

We use information to detect, investigate, and respond to security incidents; debug and repair errors; prevent unauthorized access to our systems and communications; prevent fraud, malicious activity, and malware distribution; and monitor and control access to our premises (including through CCTV).

To fulfill your requests or act with your consent. 

We may use or disclose your information where you request it or provide consent, including sharing information with third parties at your direction.

To comply with legal obligations and exercise our legal rights. 

We use your information to administer payroll, taxes, and benefits; assist with immigration services; respond to legal requests such as subpoenas or court orders; and support legal claims, including litigation, arbitration, or similar proceedings.

Certain information we collect may be “sensitive personal information” under applicable law. We collect and process such information only for our legitimate business purposes and do not process such information for purposes for which the “right to limit” applies under California law. We use such information as necessary to conduct our relationship with you and in accordance with our legal obligations. For example:

  • Social Security number or passport information for legal compliance, payroll, benefits, tax, and immigration purposes;
  • Health information, which may include disability status, to manage workplace benefits, provide reasonable workplace accommodations and manage absences, for workplace health and safety purposes, and for compliance with applicable law and contracts or to exercise rights thereunder; and
  • Racial/ethnic origin, sexual orientation, and/or disability status for equal opportunity and compliance with applicable law or to exercise rights thereunder.

California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (“CCPA”). We do not “sell” or “share” the personal information covered by this Policy.

Legal Bases for Processing

Where required by law, the legal basis for processing your personal information depends on the type of data and the context in which it's processed.

Our legal bases for processing personal information as described above are 

  1. performance of a contract (e.g., to administer payroll and benefits); 
  2. where the processing is in our or another party’s legitimate interests (e.g., monitoring compliance with internal policies, managing IT security, accounting or business and financial planning); 
  3. to comply with a legal obligation (e.g., to comply with laws and regulations related to minimum wage, working time, tax, health and safety or anti-discrimination); 
  4. to protect your vital interests or those of another person; or 
  5. in some cases, to the extent permitted by law, where you have consented to the processing. Depending on the jurisdiction in which you live, there may be other applicable legal bases that are not listed here.

Who We Disclose Your Personal Information To

We may disclose your information:

  • as part of normal business operations to service providers or vendors in connection with HR and compensation and payroll-related tasks (e.g., banks, insurance companies and other employee benefit providers (such as health providers), travel providers, expense reporting, human resources suppliers, background check companies, and employment businesses (in relation to contractors or agency workers), as well as in connection with governance, risk, compliance, and security management;
  • to service providers or vendors in connection with information technology support (e.g., software maintenance and data hosting, remote management of IT infrastructure and applications, development and maintenance of applications and global service desk operations) and in connection with accounting and financial reporting.
  • in the event that we are sold or integrated with another business, to our advisers and any prospective purchaser and their advisers;
  • for business operations to provide another entity (such as a potential or existing business counterparty or customer) with a means of contacting you in the normal course of business, for example, by providing your contact details, such as your phone number and email address;
  • to seek legal advice from our external lawyers or in connection with litigation;
  • to government authorities and/or regulatory or law enforcement officials if required for the purposes above, if mandated by law or if (in our reasonable belief) necessary to protect the rights or security of you, Scribd, Inc., or others, in compliance with applicable laws; and
  • internally with a limited number of individuals within Scribd, Inc. when necessary to perform their job responsibilities.

How We Use Automated Processing Tools In Hiring

We may use certain automated tools to process your information, including those that may constitute automated employment decision tools or automated decisionmaking technology under applicable laws (together, “Automated Tools”), to help manage the high volume of job applications we receive. These tools help us review resumes, summarize screening interviews, support fraud prevention, and assist with other legitimate business operations related to recruiting and hiring.

We use these Automated Tools to process information as identified in the “Information Collection” section of this Policy to determine how candidates’ applications align with the role. The Automated Tools may consider Professional and Education History and Employment Information in determining whether your application is a good fit for a specific role and may summarize interview content. The Automated Tools generate outputs to identify which candidates’ applications are most closely aligned with the desired experience and skills for a specific position. Based on these outputs, we review application materials and independently determine which candidates to move forward in the hiring process, for example who should participate in a screening interview. 

We retain information, including personal information, for as long as reasonably necessary to use the Automated Tools. If you are hired for the position to which you apply, your information may become part of your employee records.

Right to Access. To exercise your right to access, contact us using the methods set forth in the “Contact Us” section of this Policy. We are prohibited from retaliating against you for exercising these rights. Note that in certain jurisdictions, individuals may have the right to opt out of certain uses of Automated Tools, but our uses are subject to certain exemptions.

How Long We Keep Your Personal Information

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to support our business operations and comply with legal, accounting, and reporting obligations.

In determining retention periods, we consider the nature and sensitivity of the information, the purposes for which it is processed, and applicable legal requirements.

Your Privacy Rights (Limited Jurisdictions)

In some instances, applicable law (such as in California, the EU, and the UK) may permit you to request additional details about your personal information, such as access to such information, the opportunity to correct any inaccuracies in it, to delete such information, to object to certain processing of such information, to restrict certain processing activities (such as when you dispute the accuracy of personal information), and in some jurisdictions, where technically feasible, transfer your personal information to a third party or have the information provided to you in a structured, commonly used and machine-readable form.

Where we rely on your consent to process your personal information, you have the right to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. You have the right not to be discriminated against (as provided for in applicable law, such as in California) for exercising your rights. You also have the right to lodge a complaint with your local data protection authority if you believe we have processed your personal information in violation of applicable data protection law.

Exceptions to Your Rights. 

Please note that in certain circumstances prescribed by applicable law, we may deny your request, including but not limited to when we or our service providers need to administer our employment relationship with you, provide you with a service you requested, comply with law, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (or prosecute those responsible for that activity), or preserve data for legal purposes.

Exercising Your Rights. 

You may contact us as described in the Contact Information section below to submit any of these requests. We may ask for certain information to verify your identity before we process such requests. Subject to applicable law, you may authorize an agent to make a request to us on your behalf by providing them with a written authorization or power of attorney, and we will verify the identity of your agent and their authority to submit the request on your behalf. We may also follow up with you to verify your agent’s identity or process your request. If we are unable to verify you, we have the right, but not the obligation, to request additional information.

How We Protect Your Information 

We implement and maintain a variety of administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

International Data Transfers

Subject to applicable law, we may transfer, process, and store your information outside your jurisdiction of residence, including in the United States and other locations where we or our vendors operate. 

Where your information is transferred to jurisdictions not recognized as providing an adequate level of data protection (such as those not deemed equivalent to the EEA, UK, or Switzerland), we ensure such transfers comply with applicable law by using legally recognized transfer mechanisms, including the European Commission’s Standard Contractual Clauses and equivalent mechanisms in the UK and Switzerland.

Changes To This Privacy Policy

This Policy does not form part of your employment contract. We may update this Policy from time to time. If we make material changes, we will provide notice as required by applicable law.

Contact Us

If you have questions about this Policy or our privacy practices, please contact us:

By email: hrprivacy@scribd.com

By mail:

460 Bryant St #300 
San Francisco, CA 94107
USA

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