Cummins Talent Acquisition Privacy Statement and Consent

""

CUMMINS TALENT ACQUISITION PRIVACY NOTICE

Effective as of: September 2025

Cummins takes data privacy seriously and is committed to respecting our obligations under data privacy and data protection legislation and to meeting the expectations of individuals who entrust their information to us.

This Privacy Notice supplements the Cummins Privacy Policy and explains how Cummins Inc., 500 Jackson Street, Columbus, Indiana, 47201 United States, (“Cummins”, “we”, or “us”) handles the personal data of individuals who inquire about employment with us, who join our Talent Community or who apply for full or part-time roles, internships, work placements, or other types of positions (“Candidates” or “you”) with us, or another legal entity within the Cummins group.

For the purposes of this Privacy Notice, Cummins is the controller of your Personal Data. Applicable data protection laws, including but not limited to the GDPR, may apply depending on your country of residence. Some Cummins legal entities may present their own privacy notice, as required by local law. In the event of any inconsistency between this Privacy Notice and the local privacy notice, the local privacy notice will apply.

CATEGORIES OF PERSONAL DATA WE COLLECT AND HOW WE USE IT:

As part of the talent acquisition process, Cummins will need to process certain personal information about you as outlined below (“Personal Data”) in order to respond to your request, to accept or assess your application, or to consider you for the position you are applying for. Some of the Personal Data we request is necessary to assess your application and consider you for a position. Where the provision of data is optional, this will be clearly indicated, and your decision not to provide such data will not affect your application.

Where permitted by applicable law, we may de-identify, aggregate, or anonymize Personal Data so that it is not reasonably capable of identifying or being linked to you and use or share it in such de-identified formats as necessary for our business purposes.

In some countries, we must have a valid legal justification (legal basis) to collect and handle your Personal Data. Where applicable, we provide those legal bases below. Depending on the specific purpose, and subject to applicable law, we rely on one or more of the following legal bases:

  • Legal obligations: where we need to comply with a legal obligation. For example, under local employment legislation.
  • Legitimate interests: where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
  • Consent: In limited circumstances, with your consent. For example, where you provide your consent to a criminal background check or our use of automated decision-making technologies. We will explain how we use and share that information when we ask for your consent.
  • Pre-Contract Steps – where it is necessary to take steps at your request prior to entering into a contract of employment with you

Please refer to the following tables which outline what types of Personal Data we collect, how we use your Personal Data, and the applicable legal bases we rely upon.

Categories of Personal Data Purpose of collection Legal Basis

Contact information including name, title, address, email address, phone number, social media handles, and your preferred language

Education and training information including your language and computer skills, academic awards, degrees, certificates, or licenses, training or apprentice records, and professional memberships and the results of related verification checks

Employment information including business title and contact information, employment history, professional experience, certifications, referees’ names and contact details, salary and compensation information and the results of our validation of the same.

Selection information contained in appraisals and assessments, and information obtained or generated during screenings, interviews, reference checks or other feedback channels

Photos & videos including photos you provide to us and any recordings or transcripts of video or in-person interviews you participate in

Your Talent Community website registration credentials, including account login information and communication preferences

Other information voluntarily provided during Candidate interactions

Identify, engage, and recruit suitable Candidates

Conduct educational and employment background checks, reference checks, sanctions and directorship checks, and other relevant pre-hire screenings to ensure Candidates meet the necessary criteria

Determining whether we wish to establish a relationship with you (whether as an employee or in another capacity)

Maintain accurate and detailed records of all talent acquisition activities, Candidate interactions, selection decisions, and other administrative aspects of the process

To manage your registration and profile in our Talent Community website

Measure, assess and further develop our talent acquisition programs

To detect, investigate and take measures to prevent fraudulent activities throughout the talent acquisition process

To manage and resolve any legal disputes

Legitimate interests

To prepare, offer, negotiate and conclude employment terms

Pre-contract steps

To conduct surveys and research activities to improve our talent acquisition process.

Inform Candidates about relevant events, job openings, and career opportunities across other Cummins entities

To maintain a candidate talent database to enable us to identify and contact Candidates for potential future roles that match the desired skills and experience

Legitimate Interests and, where required by law, your Consent

To fulfill our obligations and legal requirements under applicable local, national or international laws, including meeting our statutory storage or retention obligations

Legal obligation

SENSITIVE PERSONAL DATA:

In limited situations, such as when a Candidate is shortlisted, or when we have a legal obligation to do so, we may also collect certain categories of Personal Data, as outlined below, that may be considered sensitive under applicable law (Sensitive Personal Data). Given the nature of Sensitive Personal Data, we take additional measures to protect these types of Personal Data and comply with the requirements for the collection, use, disclosure and security of such Sensitive Personal Data as set out in applicable law.

Sensitive Personal Data Categories (where legally permissible to collect) Purpose of collection Legal Basis

Your date and place of birth

Government-issued identification numbers such as social security, national insurance number, or tax id number

Passport or driver’s license information

Residence permit number, and other citizenship information

Employment visas, and other right to work information

Financial information, such as your bank account details, wage garnishment records, and authorized deductions, as and if applicable.

General background screening information including the results of credit checks, motor vehicle records checks, and the results of other required pre-employment screening assessments

Information about any current or historical criminal convictions or offences relevant to the role being applied for.

To fulfill our obligations and legal requirements under applicable local, national or international laws, including identity verification

To confirm a Candidate’s eligibility to work

To comply with our health and safety obligations

To meet statutory storage or retention obligations

Legal obligation

As necessary for the preparation, offer, negotiation and conclusion of employment terms

To detect, investigate and take measures to prevent fraudulent activities throughout the talent acquisition process

To protect our rights or property, or to protect the safety and security of you or others

To manage and resolve any legal disputes

Pre-contract steps and/or, where required by law, your Consent

Legitimate Interests and/or, where required by law, your Consent

WHO WE SHARE YOUR PERSONAL DATA WITH

Personal Data may be accessed by or shared with Cummins’ talent acquisition team, recruiters, hiring managers and members of relevant Human Resources teams. Depending on where you, or the position is based, Personal Data may also be shared with similar functions within applicable Cummins legal entities, for example, where the hiring manager sits within a different Cummins legal entity than that to which you, or the job is located. The sharing of this information between Cummins and its other legal entities is on a strict need to know basis and only as necessary for the purposes outlined above.

We may also make your Personal Data available to third parties for limited and specific purposes in accordance with our specific instructions and under our direction. These organizations are bound by appropriate contractual arrangements or obligations of confidentiality to protect your Personal Data.

  • Our third-party service providers such as recruitment firms, consultants, advisors, and other trusted parties who provide candidate recruitment, interview and assessment support services to us, or undertake background screening or pre-employment checks on our behalf
  • Our technology vendors and suppliers such as those that provide our IT systems, including our human resource management systems, platforms, websites, and applications utilized by Cummins.

We may also disclose Personal Data to other third parties in the following circumstances:

  • With your consent and on your direction.
  • Where required by governmental, regulatory, law enforcement or other public authorities to comply with a legal obligation.
  • It is necessary to address fraud or security issues, to respond to an emergency, to investigate and prepare legal claims, to protect our rights or property, or to protect the safety and security of you or others.
  • As required due to a change in our ownership in connection with, or during negotiation of, any merger, sale of assets, financing, or acquisition of all or a portion of our business by another.

We will not disclose your Personal Data to third parties for their independent use without your prior notice or, where required by law, with your consent, unless we are legally obligated to do so.

HOW LONG WE KEEP PERSONAL DATA

We retain Personal Data for as long as required to engage in the uses described in this Privacy Notice, unless a longer retention period is required by applicable law. Our standard data retention periods for Candidates are as follows:

Unsuccessful Candidates: we retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including documentation of the recruitment process, compliance with applicable legal obligations (such as equal treatment and anti-discrimination laws), and to manage potential legal claims. The specific retention period may vary depending on the jurisdiction and applicable local laws. Once retention is no longer necessary, your Personal Data will be securely deleted or anonymized in accordance with our internal policies.

If you have consented to receive job alerts and/or to receive other Talent Community emails, we will keep your Personal Data until such time as you have unsubscribed from those communications and/or you delete your Talent Community profile.

Successful Candidates: Personal Data gathered during the talent acquisition process will be transferred to an employee file and retained throughout the term of employment and for a period afterwards, as permitted or required by law.

For specific information about our retention practices in your country, please contact us at dataprivacy@cummins.com.

HOW WE SECURE PERSONAL DATA

Cummins implements appropriate technical, organizational, and physical security measures to protect your Personal Data against unauthorized access, loss, misuse, alteration, or destruction. These measures are designed to ensure a level of security appropriate to the risks presented by the processing and the nature of the data and are reviewed and updated regularly in line with industry standards and legal requirements.

While we take data protection seriously and continuously work to strengthen our security posture, no method of electronic transmission or storage is entirely secure. Nevertheless, we remain committed to maintaining the confidentiality, integrity, and availability of your Personal Data and to responding appropriately in the event of any security incident

OUR USE OF AUTOMATED DECISION-MAKING TECHNOLOGIES (ADMT)

We do not use technology to purely automate or profile individuals for recruitment decisions. We may use technologies, such as decision support or automated tools to help recruiters more effectively identify qualified Candidates where there may be a large number of applicants by assessing the information you provide aligns to the requirements and qualifications defined in the position. To mitigate the risk of bias or discrimination, we ensure direct involvement of our recruiters, hiring managers and other individuals required as part of any decision-making processes.

Cummins gives you a choice as to whether these tools are used, and you will receive equal consideration whether you provide consent or decline the use of these technologies.

COOKIES AND SIMILAR TECHNOLOGIES

When you visit our websites, use our online services, or view our content on certain third-party websites we direct you to, we may use various online tracking technologies, such as cookies. Some of these cookies are technically necessary for the operation of the website or service, while others are used to improve performance, understand usage patterns, or personalize content. For more information, see our Cookies Website Notice and Disclosure Statement.

INTERNATIONAL TRANSFERS

Cummins is a global organization, which means your Personal Data obtained through the talent acquisition process may be stored, transferred to, or accessed from various locations where we or our third party service providers operate, including systems located in the country from which you are located, the United States, and within Europe (e.g., the United Kingdom and Germany). Some of these countries may have different privacy and security standards than your own, potentially offering varying levels of protection.

Cummins adheres to its obligations to protect your Personal Data during such storage, transfer or access, by utilizing appropriate legal mechanisms (e.g., standard contractual clauses) and by implementing technical and organizational measures designed to adequately safeguard your Personal Data, wherever it may be and with each entity it is disclosed to.

If you would like further information about what measures we take to protect your Personal Data when transferring it outside the country where you reside, please Contact Us.

UPDATING YOUR PERSONAL DATA

If you have joined the online Cummins Talent Community, you can access and update the Personal Data in your profile and manage your application directly by logging in to the Talent Community website.

You have the option to receive various types of communications from us, including information relating to jobs which may be of direct interest to you. You can change these preferences at any time by accessing your Talent Community profile, or by selecting ‘Unsubscribe’ at the bottom of any email communications.

YOUR RIGHTS

Where we process personal data on the basis of your consent, you can withdraw that consent at any time. This choice does not affect the lawfulness of our use of your Personal Data before the consent is withdrawn. Depending on where you reside, you may have certain rights with respect to your Personal Data, which may include:

  • The right to be informed: you have the right to obtain clear, transparent and easily understandable information about how we use your personal data, and your rights;
  • The right of access: you have the right to access the personal data that Cummins holds about you;
  • The right of rectification: you have the right to have your personal data rectified if it is incorrect or outdated and / or completed if it is incomplete;
  • The right to erasure / right to be forgotten: you have the right to have your personal data erased or deleted;
  • The right to restriction of processing: you have the right to object to, or request that we restrict, certain processing;
  • The right to object to direct marketing: you can unsubscribe or opt out of our direct marketing communication at any time;
  • The right to withdraw consent: at any time for data processing based on your consent;
  • The right to data portability: you have the right to move, copy or transfer data from our database to another.
  • The right to no discrimination: you have the right not to be discriminated against for exercising any of your privacy rights; and
  • The right to lodge a complaint with the data privacy/data protection authority where you reside

If you are entitled to exercise any of the rights above, we will honor your request within the time permitted by applicable laws. Please note that these rights may not be absolute, and there may be situations in which we are permitted by law to limit or decline your request.

You, or your authorized agent, may exercise your privacy rights by emailing dataprivacy@cummins.com. In some instances, we will need to verify your identity. If you have appointed an authorized agent, we will also request written evidence of their authority to exercise these rights on your behalf.

HOW TO CONTACT US

If you have any questions about this or other Cummins Privacy Notices or our privacy practices, to submit a complaint, or to obtain the contact information of our local data protection officers (DPOs) you can contact us by:

  • emailing dataprivacy@cummins.com
  • writing to us at Cummins Inc., Global Headquarters, 500 Jackson Street, Columbus, Indiana, USA 47201 Attn: Global Data Privacy Office.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time as required by law or when we consider it necessary. We encourage you to review this Privacy Notice regularly to stay informed about our information practices and the choices available to you.

Last updated: September 2025