Privacy Policy

PRIVACY POLICY FOR HIRE CULTURE

Welcome to the Hire Culture website. This website (“site”) has been developed by the Massachusetts Cultural Council (“MCC,” “We,” “Us,” “Our”). This policy covers how We use and treat personal information collected and received through use of this site by individuals who are searching for employment opportunities (“Job Seeker” or “User”) and companies, individuals, and other entities that provide employment listings (“Company,” “Job Poster,” or “User”). Upon reading this privacy policy, Job Seekers and Companies will know this site’s privacy practices, including:

  1. What personally identifiable information, if any, is collected from Users through their use of this site and how this is done;
  2. How Users’ information will be used;
  3. With whom the Users’ information may be shared or disseminated, and under what circumstances this can occur;
  4. How certain Users could, in some instances and through their own actions, disclose their own personally identifiable information to others when using this site;
  5. The type of security procedures, if any, that are in place to protect against the loss, misuse, or alteration of Users’ information;
  6. How Users can access and correct any inaccuracies in the information collected about them, when appropriate; and
  7. Who to contact if Users have any questions regarding this Privacy Policy and use of their information.

General Privacy Considerations
We take Our Users’ privacy concerns seriously. As a general matter, the MCC takes reasonable precautions and makes reasonable efforts to protect privacy, when appropriate, depending upon the nature of the information to be protected. We cannot, however, guarantee absolute privacy and that no third party will ever receive a User’s information. As the MCC is a publicly-funded state agency, information provided by Users to the MCC through use of this site may be made available and disclosed to members of the public pursuant to laws such as the Massachusetts Public Records Law, M.G.L. Chapter 66, section 10 as described herein, regardless if the User’s state, country, or territory laws may be different. For the reasons described below, this particular site does not take any security measures regarding Job Seekers’ and Companies’ use of the site and the information collected by Us.

Based upon this Policy, Users can, in some cases, make an informed choice as to the information they wish to share with Us. This Policy does not apply to the privacy practices of other state agencies, their employees, or any company or third party that may be working with Us. Websites operated by other agencies may have different practices in effect and any inquiries regarding these other practices must be directed to the appropriate agency. We will not answer any inquiries about another agency’s privacy policy or practices and, to the extent that a User does receive any information from Us regarding a particular inquiry, it in no way modifies this or any other privacy policy or binds Us or any other agency or employee.

Also, this Policy only applies to this site. Other sites operated by or associated with the MCC may have different privacy policies in effect. Please consult the appropriate policy when using other affiliated sites. A User may also have the ability to connect with Our site using a variety of mobile devices. This Privacy Policy applies to all such mobile access by a User and his/her mobile devices.

What Information We Collect and How We Do It
Information can generally be collected in two ways: (1) Information that is knowingly and voluntarily input into the system directly by the User in response to particular prompts or fields that require an affirmative response; and (2) information that is collected automatically when the User interacts with Our site. This site does not require Job Seekers to input any information in response to particular prompts or fields before using it. Companies, however, are required to provide some information voluntarily in order for the site to be an effective resource for them. Also, this site automatically collects some information when Users use it. This is explained in more detail below.

Some information can be “personally identifiable.” This means any type of information which could be used to identify or be readily associated with a particular individual using this site. Examples of personally identifiable information include, but are not limited to, a User’s name, address, telephone number, and e-mail address, or any combination thereof. Pursuant to the Fair Information Practices Act, Chapter 66A, Section 2(l), We do not collect or maintain more personally identifiable information than is reasonably necessary for the performance of the MCC’s statutory functions or for the operation of this site. Additional protection may also be found in Executive Order Number 504 and other sources. With respect to the operation of this site, We do NOT at this time collect any personally identifiable information from Job Seekers. We will attempt to notify Job Seekers prior to implementation if this practice were to change.

If, however, the User is a Company that will be posting job information on Our site, We do require the Company to register with Us and provide basic information. For example, in order for a Company to provide job listings, it will be required to provide information to Us upon registration such as the job to be posted, its organizational name, phone number, address, and geographical information. In addition, the Company must provide the name of an administrative contact person to Us if We have any questions or issues, including his/her phone number and e-mail address. This information would not generally be released to the public and would be for Our own internal use.

A Company is not required to provide the name of a public contact person in order to receive inquiries about the job listing from interested Job Seekers, but may do so at its own initiative. In this instance, the Company is required to obtain the consent of its contact person, who must be over the age of eighteen years (18), prior to listing any job information. This individual would then be readily associated with a particular Company. This would be the extent of the personally identifiable information known about that person through use of Our site.

We do not consider personally identifiable information to include information that has been made anonymous by Us or a third party, or that which may be aggregated so it can no longer be used, whether in combination with additional information or otherwise, to readily identify a particular User.

The transmission of an e-mail voluntarily initiated by a User to Us can transmit personally identifiable information about the User. For example, a User’s e-mail address can be considered personally identifiable information in some instances. If a User includes his/her name, telephone number, and other information in the body of the e-mail, this information is also personally identifiable. A User should not send personally identifiable information through this site via unencrypted e-mail, particularly information that the User deems to be sensitive or confidential. Also, as described herein, this information could be disclosed in certain circumstances.

Furthermore, a Job Seeker who responds to any listing on Our site, whether through e-mail or through any other affirmative action on that User’s part, may be disclosing personally identifiable information to that Job Poster. Such responses take place without Our knowledge. The Job Seeker may want to consult that Job Poster’s privacy policy, if any, regarding its use of such information once transmitted as the Job Seeker may be subject to it. We do not review, assess, or have any control over any Job Poster’s privacy policy or practices to which a User may submit his/her personally identifiable information. We encourage a User to investigate those privacy issues before disclosing his/her personally identifiable information to others.

The automatic collection of information refers to information collected from a User that does not require the User to knowingly and intentionally provide information in response to particular fields or prompts. For example, this site uses “cookies.” A cookie is a small text file placed on a User’s web browser that is used to recognize Users who have visited the site previously. In general, these cookies are either persistent and may reside on a User’s computer for several months after a User last accessed the site (or until the User deletes or otherwise disposes of them), or on a temporary basis. For example, a site may use temporary cookies called “session cookies,” which are stored for a single user session with the site and are deleted as soon as the user's browser is shut down. Presently, this site uses session cookies for both Job Seekers and Companies. We do not use persistent cookies at this time.

We also automatically collect a User’s “internet protocol” (“IP”) address. An IP address is a unique series of numbers that identifies each computer or mobile device which connects to the internet. An IP address can be used to provide information such as the date and time of a User’s visit, the availability of certain requested files, the popularity of various website functions, and the amount of information transmitted to each User from the site. Presently, We use a User’s IP address to address the frequency of visits to this site and to determine the frequency with which certain pages and functions of the site are accessed. This will allow Us to improve the site’s functionality and ease of use. As a particular computer is identified, rather than identifying a particular User, no personally identifiable information is disclosed.

We will not routinely attempt to match a User’s particular IP address to any personally identifiable information that a User may provide to Us on its own, except in certain situations. For example, in instances where We, in Our sole discretion, suspect or determine that the site is being used for any unacceptable, inappropriate, or illegal purposes, information relating to a User’s use of this site may be disclosed to other parties as We deem appropriate. Such information may also be disclosed pursuant to any authorized law enforcement investigation or other legal process, regardless of whether it was initiated by Us or another party.

How We Use Your Information
Pursuant to the Fair Information Practices Act, M.G.L. Chapter 66A, Section 2(l) We do not collect or maintain more personally identifiable information than is reasonably necessary for the performance of the MCC’s statutory functions or for the operation of this site. Additional protection may also be found in Executive Order Number 504 and other sources. The information that We collect is used to assist Us in the administration and operation of Our site. All of information collected at this site may be stored in Our database for an indefinite period of time.

Dissemination of Your Personally Identifiable Information
As noted above, We do not collect any personally identifiable information from Users on this site except what a User may provide to Us via e-mail or the contact information provided by a Company. We do not sell or license any personally identifiable or other information We collect from a User when using this site to any party or for any purpose. However, once personally identifiable information is collected through a User’s use of the site, its dissemination becomes subject to certain laws and policies, including, but not limited to, the Massachusetts Public Records Law, M.G.L. Chapter 66; the Fair Information Practices Act, M.G.L. Chapter 66A; and Executive Order Number 504 and other sources. Consequently, any User’s personally identifiable information sent to Us could be disseminated to the public in response to an official public records request. In addition, any of the information that is submitted by, or collected from a User can be disclosed to employees or officials of, or those under contract to, the Commonwealth of Massachusetts who have a “need to know” such information for purposes of fulfilling their job responsibilities, legal or administrative obligations, or for rendering assistance to a User. In some instances, We may provide all of the information submitted by a User via e-mail to the person or company that is the subject of the User’s inquiry, or to a government agency responsible for the matters referred to in that communication.

Web Site Security
This is NOT a secure site. As We do not collect any personally identifiable information about a User, We have not employed any security measures to protect data. We have not implemented any security protocols regarding the access, use, encryption, disclosure, or authentication of any information that is available on this site or that a User may make available to Us.

Accessing and Correcting Your Information
As We do not collect any personally identifiable information from Job Seekers, We do not provide access to a Job Seeker to correct any information that he/she deems to be inaccurate, incomplete, or out-of-date. If the User is a Company, however, We do provide access to the Company to correct any inaccurate, incomplete, or out-of-date information which the Company may have provided to Us previously. If, however, a Job Seeker or Company sends e-mail to Us, We may provide access to this e-mail under certain circumstances. In general, the Massachusetts Public Records Law, M.G.L. Chapter 66 and the Fair Information Practices Act, M.G.L. Chapter 66A provides certain rights to a User who wants to obtain his/her information in Our records.

Children’s Information
We do not actively market, target, or direct Our efforts to, or knowingly collect personally identifiable information from, children under the age of thirteen (13) years. This site is intended for use by adults only.

Third Party Service Providers
MCC contracts with a third party service provider, Newtek, to assist Us in hosting this site and managing certain functions in its operation. We only provide third party service providers with Our information so that it may perform its services in operating this site. We do not purposely or knowingly disclose a User’s personally identifiable information to third party service providers. If a User has any questions about Newtek’s privacy or other business practices, please review its privacy policy at: http://www.thesba.com/privacy-policy/. Please note that by visiting the Newtek site, a persistent or temporary cookie may be placed on a User’s web browser which could be used to analyze the usage of that particular site.

Policy Revisions
Any revisions made to this Policy will be posted by Us at least thirty (30) days before they take effect.

Links to Other Web Sites
This site may contain hypertext links to other websites. We are not responsible or liable for the content, transmissions, or privacy practices of these other sites. Any questions that a User may have regarding another site’s content, transmissions, or privacy practices must be directed to the appropriate party at that site.

Contact Information
For any questions about this privacy policy or Our information collection and dissemination practices, please contact dawn.heinen@art.state.ma.us.