Careers Privacy Notice

Last Updated: September 2025

Davis Polk & Wardwell LLP and its associated entities that are authorized to carry the name Davis Polk (together, “Davis Polk,” “we,” “our,” or “us”) (a list of all Davis Polk entities is available here) are committed to protecting your privacy and handling your personal information in an open and transparent manner.

This Careers Privacy Notice (this “Privacy Notice”) describes our practices in relation to the personal information that we handle in connection with our talent acquisition and recruitment activities, including information collected on any website where this Privacy Notice is posted or linked (the “Careers Website”). Specifically, this Privacy Notice explains how we use, disclose, and protect the personal information that we collect from and about you when you (i) provide us with your information to express your interest in professional opportunities with Davis Polk (as a “Prospect”); (ii) apply (or have been submitted by a third party) for a specific position at Davis Polk (as an “Applicant”); or (iii) are being considered for a specific position at Davis Polk (as a “Candidate”). This Privacy Notice also describes the legal rights that may be available to you with respect to your personal information and how you can exercise them.

This Privacy Notice may be supplemented by other notices that explain how and why your personal information is collected, used, and disclosed by us (or on our behalf) under certain circumstances.

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific individual. For clarity, personal information includes information that constitutes “personal information,” “personal data,” “personally identifiable information,” or any substantially similar term under applicable data protection and privacy legislation in any relevant jurisdiction.

California Residents. If you are a California resident, please review the “Additional information for California residents” section below, which includes additional details about our information handling practices and your rights under California law.

Please note that the Davis Polk entity responsible for the processing of your personal information will depend on which Davis Polk entity you engage with as a Prospect, an Applicant, or a Candidate.

Within this Privacy Notice, you can navigate to a particular topic by clicking the following links:

• Collection of personal information
• Use of personal information
• Legal basis for processing personal information
• Disclosure of personal information
• International transfers of personal information
• Protection of personal information
• Retention of personal information
• Your legal rights
• Changes to this Privacy Notice
• Contact us
• Additional information for California residents 

Collection of personal information

We collect a variety of information in connection with our talent acquisition and recruitment activities. Additional details regarding the types of personal information that we may collect from and about you as a Prospect, an Applicant, or a Candidate and the sources from which we may collect such information are included below.

Information collected directly from you

We will request and collect certain types of personal information directly from you when you express your interest in professional opportunities with Davis Polk or apply for a role at Davis Polk and throughout the recruitment process, as appropriate. The specific categories of personal information that we may receive from you are described below.

• Account information, such as your username and password, if you create an account on the Careers Website.
• Contact information, such as your name, residential/postal address, email address, and telephone number(s).
• Application information and documentation, such as your completed application, resume/CV, cover letter, writing sample, and other supporting documentation.
• Education and training information, such as the educational institution(s) you attended and dates of attendance; the degree(s), certificate(s), or other educational qualifications earned; academic transcript(s) or training records; and academic references.
• Professional history and qualifications, such as your current and previous employer(s), position(s), and work experience; language(s) and other relevant skills; professional license(s), certification(s), and/or other qualifications; and professional references.

We will collect additional types of personal information that you choose to provide to us, including (i) demographic information that you voluntarily disclose (e.g., your military or veteran status) (note that we will not seek nor use any demographic information in hiring decisions unless specifically permitted by law or regulation); (ii) signatures that you include on forms that you submit; and (iii) information that you share when you engage with us via email, phone, or in person (including during interviews). Where permitted by law or regulation, we may also collect certain visual information from you (e.g., photographs, CCTV images, etc.) if, for example, you attend a recruiting event that we host (on or off-premises) or visit any of our offices for an interview.

Additionally, if you are offered and accept a role at Davis Polk, we will collect certain demographic information from you (e.g., your age/age range, birthdate, and/or citizenship or immigration status) in connection with our pre-onboarding process.

Information collected through automated means

When you submit your information to express your interest in professional opportunities with Davis Polk or apply for a specific position at Davis Polk through the Careers Website, we (and our service providers and partners) may collect certain information about your browser, device, and/or activity.

The specific types of information we (and our service providers and partners) may collect include the information described below. 

• Browser and device information, including the Internet Protocol (IP) address and/or other unique identifier(s) assigned to your device; the location of your device; and other information about your browser, device, and operating system.
• Activity and usage information, including information about your interaction(s) with the Careers Website (e.g., the date and time of your visit(s); the area(s) or page(s) that you visit; the amount of time you spend on the page(s) or using the Careers Website; the domain name from which you accessed the Careers Website; and other clickstream or usage information).

We (and our service providers and partners) also use “cookies,” which are small text files that are stored on your computer or other device when you visit a website. The cookies that are used on the Careers Website are necessary for it to function properly (“essential cookies”). Because these essential cookies are necessary to allow the technical operation of the Careers Website and enable basic features, they cannot be switched off and remain in your browser during your current browsing session only (i.e., until you leave the Careers Website). Your browser may enable you to view and clear/delete cookies and set your cookie preferences, but doing so may impact your experience on the Careers Website.

Please note that we do not use any information collected through automated means, including information collected via cookies, in hiring decisions.

Information received from third parties and other sources

We may collect or receive some of your personal information from other sources. For example, we may receive information about you from (i) an employment agency or professional recruiting firm (if one is involved in your recruitment); (ii) your current and/or former educational institution(s) and employer(s); (iii) your professional and/or academic references; (iv) third-party websites; and (v) social media platforms (e.g., LinkedIn), depending on your privacy settings on such platforms.

We may also collect information about you from Davis Polk recruiting personnel and/or other Davis Polk personnel with whom you interact or interview during the recruitment process. This information may include details about your interview performance and inferences drawn by Davis Polk personnel about your professional experience and competence.

If you are offered and accept a role at Davis Polk, where permitted by local law or regulation, we (or a third party acting on our behalf) will (with prior notice) conduct a background check and/or identity verification and employment authorization screenings. As part of the check or screenings, we (or the third party acting on our behalf) may collect from you personal information that is considered “sensitive” (or “special category”) or otherwise subject to extra protection under applicable data protection and privacy legislation (e.g., your government-issued identification number) (collectively, “sensitive personal information”). If we conduct a background check, we may also receive information (including sensitive personal information) about you, such as details about your professional, credit, and/or criminal history, from certain third parties (e.g., the third party that we instruct to conduct the check on our behalf).

Where we require any of your sensitive personal information, we will inform you of the purpose(s) for collecting your information and seek your consent, in accordance with applicable law or regulation. We will also handle your sensitive personal information in accordance with this Privacy Notice and/or in the ways described to you at or before the point where we request or collect the information. Unless requested, you should not submit any sensitive personal information to us through the Careers Website or other means. If you decide to transmit any sensitive personal information to us, we reserve the right to delete the information from our systems.

Please note that we may combine personal information that we collect or receive from various sources and use, disclose, and protect the combined personal information as described in this Privacy Notice.

Additionally, if we extend an offer to you and you join Davis Polk, the personal information that we collected or received during the recruitment process will become part of your personnel records. Once the information becomes part of your personnel records, it will be handled and retained in accordance with the privacy notice applicable to Davis Polk personnel.

Use of personal information

We use the personal information that we collect from and about you to carry out our talent acquisition and recruitment activities and fulfill other legitimate purposes. The specific purposes for which we may use your personal information are described below.

• To facilitate our talent acquisition and recruitment activities. We will use your personal information in connection with our talent acquisition and recruitment activities, which may include (i) operating the Careers Website; (ii) reviewing your information and identifying you as a Prospect; (iii) reviewing your application information and documentation and identifying you as a potential Candidate; (iv) conducting interviews with you; (v) verifying the information that we have collected or received from and/or about you, including details about your educational credentials and employment history; and (vi) conducting a background check and/or identity verification and employment authorization screenings, where permitted by local law or regulation.
• To communicate with you. Where appropriate, we will use your personal information to communicate with you, including to (i) contact you about professional opportunities with Davis Polk that we think may be of interest of you; (ii) request additional information from you that is relevant to your application or candidacy; (iii) schedule and coordinate interviews with you; and (iv) provide you with updates and correspondence, including details about the status of your application or candidacy.
• To perform analytics. We will use your personal information as necessary or appropriate to perform analytics designed to evaluate and improve the effectiveness of our prospecting and recruitment processes and programs.
• To maintain security and prevent fraud. We will use your personal information as necessary or appropriate to monitor and maintain the security and integrity of our business and to detect, prevent, investigate, and protect you, our business, and others from fraud and other unlawful or unsafe activity.
• To satisfy our legal and regulatory obligations. We will use your personal information as necessary or appropriate to comply with our legal and regulatory obligations, including to respond to requests from competent legal or regulatory authorities and legal process (e.g., court orders, subpoenas, or warrants).
• As otherwise permitted, necessary, or appropriate. We will use your personal information for other purposes communicated to you at or before the point of collection and, where necessary or appropriate, with your consent. We will also use your personal information as we believe necessary or appropriate to protect your, our, or others’ rights, privacy, safety, and property and pursue available remedies or limit damages that we may sustain.

Legal basis for processing personal information

Data protection and privacy legislation in certain jurisdictions requires us to set out the “legal basis” that we rely on to collect and further process your personal information.

Where applicable, the legal bases that we rely on are described below.

• Compliance with a legal or regulatory obligation. We are subject to various legal and regulatory requirements in the jurisdictions in which we operate. Accordingly, we will process your personal information as necessary for us to comply with  obligations arising under any applicable law or regulation.
• Consent. Where necessary or appropriate, we will process your personal information based on the consent that you provide at or before the point of information collection or disclosure. We will generally process your sensitive personal information based on your explicit consent.
• Contractual necessity. Where applicable, we will process your personal information to take steps before entering into a contractual relationship with you, such as a contractual employer-employee relationship.
• Legitimate interests. We will process your personal information in furtherance of our legitimate interests, including our interests in (i) evaluating you as a Prospect, an Applicant, or a Candidate and managing our relationship with you; (ii) communicating with you regarding professional opportunities with Davis Polk or the status of your application or candidacy; (iii) operating the Careers Website and our business; and (iv) carrying out our other talent acquisition and recruitment activities, provided that such interests are not outweighed by your interests or fundamental rights and freedoms.

If you have any questions about our legal basis for processing your personal information, please contact us at privacy.team@davispolk.com.

Disclosure of personal information

In connection with our fulfillment of the purposes described in the “Use of personal information” section above, we may disclose your personal information to various categories of third parties, as described below.

• Our affiliates. We will disclose your personal information to our Davis Polk offices and entities around the world as necessary for administrative purposes and to otherwise fulfill the purposes described in this Privacy Notice.
• Our service providers. We will disclose your personal information to third parties that provide business, professional, and technical support services to us and/or administer activities on our behalf (subject to appropriate contractual and/or professional obligations and restrictions), including providers of recruitment, website hosting, event hosting, and background check or pre-employment screening services.
• Our professional advisers. We will disclose your personal information to our professional advisers (e.g., lawyers, consultants, etc.) as necessary in the course of the professional services that they provide to us (subject to appropriate contractual and/or professional obligations and restrictions).
• Our personnel. We will disclose your personal information to Davis Polk personnel who are involved in our talent acquisition and recruitment activities and/or require access to the information to perform tasks in furtherance of the fulfillment of the purposes described in this Privacy Notice.
• Governmental authorities and law enforcement. We will disclose your personal information as required or permitted by applicable laws and regulations in any jurisdiction to governmental authorities, including regulatory authorities, courts and tribunals, government agencies, and law enforcement agencies (such as the police).
• Relevant third parties in connection with a business transaction. We may disclose or otherwise transfer your personal information to relevant third parties in connection with any actual or potential merger, acquisition, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets, including in connection with any bankruptcy, reorganization, or similar proceedings.
• Other third parties. We will disclose your personal information to other parties as we believe necessary or appropriate either to (i) comply with applicable laws and regulations; (ii) protect our operations and/or those of our affiliates; (iii) investigate and prevent against fraud and other illegal activity; (iv) protect your, our, or others’ rights, privacy, safety, and property; or (v) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your personal information to other categories of third parties to fulfill the purposes described in this Privacy Notice, and we will seek to inform you of such disclosures at or before the point of information collection or prior to disclosing your information.

Where required by applicable data protection and privacy legislation, we will provide you with additional details regarding the potential third-party recipients of your personal information and obtain your consent prior to disclosing your information to such parties.

We will not sell, rent, distribute, or otherwise make your personal information commercially available to any third party except with your prior permission.

Please note that we may de-identify, anonymize, or aggregate information such that it no longer constitutes personal information and use and disclose to third parties such information for various purposes, as permitted by applicable law or regulation.

International transfers of personal information

As an international law firm headquartered in the United States, we may transfer your personal information outside of the country or region in which you are located to fulfill the purposes described in the “Use of personal information” section above. This includes countries where our offices, data centers, and service providers are located.

As a result, your personal information may be transferred to and stored in the United States and other jurisdictions with data protection and privacy legislation that differs from the legislation in your country of residence. Additionally, your personal information may be subject to lawful requests by the courts or law enforcement authorities in those jurisdictions.

Where we transfer your personal information internationally (including to other Davis Polk entities), we do so in accordance with applicable law or regulation, which may entail us providing you with additional details regarding the transfer and obtaining your consent.

If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), please note that whenever we transfer your personal information to countries or regions that have not been recognized by the European Commission, Switzerland’s Federal Council, and/or the UK Government as providing an adequate level of protection for personal information, we ensure that appropriate or suitable safeguards are in place to protect your information. In particular, we may use government-approved contracts (e.g., EU Standard Contractual Clauses) that provide appropriate safeguards for personal information that is transferred to jurisdictions that have not been recognized as providing an adequate level of protection. You can obtain a copy of the EU Standard Contractual Clauses here.

In accordance with applicable law or regulation, we carry out a risk assessment to understand and assess the risks associated with a transfer of personal information internationally. Moreover, where appropriate, we identify and adopt supplementary measures to increase the level of protection of the personal information transferred to the standard needed to protect the information being transferred. If we find that we cannot provide the required level of protection even with the use of supplementary measures, we will not proceed with the transfer.

Protection of personal information

We use reasonable technical, administrative, and organizational measures to help protect personal information under our control from unauthorized access, use, disclosure, alteration, or destruction.

Because no information system can be 100% secure, we cannot guarantee the absolute security of any information that you transmit to us electronically. Thus, we recommend exercising caution when transmitting any personal information to us, including through the Careers Website.

Retention of personal information

To determine the appropriate retention period for personal information, we consider, as appropriate (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of the personal information; (iii) the purpose(s) for which we process the personal information and whether we can achieve such purpose(s) through other means; and (iv) the applicable legal and regulatory requirements (including minimum information retention requirements as prescribed by laws, regulations, or regulatory bodies).

We take reasonable steps to ensure that access to personal information is appropriately limited for the duration of its retention. Once personal information has reached the end of its retention period, we may de-identify it such that it no longer constitutes personal information. If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law or regulation.

Your legal rights

Pursuant to applicable data protection and privacy legislation, you may be entitled to exercise certain rights with respect to your personal information, including the right to:

• request confirmation as to whether we are processing your personal information and, if so, to request access to your personal information and details regarding our processing of such information (including the disclosure of such information to third parties);
• request correction or rectification of any inaccurate, incomplete, or out-of-date personal information that we hold about you;
• request deletion (or anonymization) of your personal information under certain circumstances (subject to applicable exceptions);
• object to the processing of your personal information under certain circumstances;
• request that we restrict our processing of your personal information in certain circumstances;
• request that we provide your personal information in an appropriate format and transmit your personal information to a third party (where technically feasible);
• refuse to provide your consent, in which case we will inform you of the consequences of your refusal; and
• withdraw the consent that you have provided us to process your personal information (without affecting the lawfulness of any processing carried out before you withdrew your consent).

Applicable law or regulation may also grant you the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects concerning you. We do not, however, engage in such automated processing. 

If you are interested in exercising any of the above-listed rights, you (or a third party acting on your behalf) can do so by emailing us at privacy.team@davispolk.com with the subject line “Privacy Rights Request – Prospect/Applicant/Candidate.” Please note that these rights are not absolute and that we may refuse to honor your request if a statutory or regulatory exemption applies.

To confirm that you are entitled to exercise the above-listed rights and protect your privacy, we may need to request specific information to help us confirm your identity (and/or confirm that a third party is authorized to act on your behalf). Where applicable, we will use the requested information for verification purposes only. Please note that we may deny your request if we are unable to verify your identity and/or a third party’s authority to act on your behalf.

In addition to the rights outlined above, you may have the right to lodge a complaint with the relevant authority if, for example, you are dissatisfied with our response to any query or request that you have raised to us or our handling of your personal information. The contact details for the data protection authorities in the EEA member states are available here, and instructions on how to submit a complaint to the UK’s data protection authority are available here.  

If you are a California resident, the “Additional information for California residents” section below sets out your rights under California law.

Changes to this Privacy Notice

We will change or modify this Privacy Notice from time to time to reflect changes in our information handling and privacy practices and/or changes in applicable laws and regulations.

The “Last Updated” date at the top of this Privacy Notice indicates when it was last revised. If we make changes, we will revise the date at the top of this Privacy Notice.

Unless otherwise stated, the current version of this Privacy Notice applies to all personal information under our control.

Contact us

If you have any questions, comments, or concerns regarding this Privacy Notice or our handling of your personal information, please contact us at privacy.team@davispolk.com.

Additional information for California residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and implementing regulations (collectively, the “CCPA”), provides California residents with certain rights with respect to their “personal information” (as defined in the CCPA). Pursuant to the CCPA, this section provides Prospects, Applicants, and Candidates residing in California with details regarding the categories of personal information we collect, use, and disclose. This section also describes the legal rights available to Prospects, Applicants, and Candidates residing in California in relation to their personal information and how they can exercise their rights.

Personal information collection and disclosure for a business purpose

The following table details which categories of personal information we have collected from and about Prospects, Applicants, and Candidates residing in California in the past twelve (12) months, the categories of sources from which we have collected each category of personal information, and the categories of third parties to whom we have disclosed each category of information for a “business purpose” (as defined in the CCPA). Please note that the first column in the table lists by category the types of information described in the “Collection of personal information” section of this Privacy Notice, as required by the CCPA.

Purposes for collecting personal information

As described in more detail in the “Use of personal information” section above, we collect the above-listed categories of personal information to carry out our talent acquisition and recruitment activities and fulfill other legitimate purposes.

Disclosure of personal information

As described in more detail in the “Disclosure of personal information” section above, we disclose the above-listed categories of personal information to carry out our talent acquisition and recruitment activities and fulfill other legitimate purposes. We also disclose certain categories of personal information to governmental authorities, law enforcement, and other third parties as necessary or appropriate, including when we have a legal or regulatory obligation to do so.

Sale and sharing of personal information

We do not “sell” or “share” (as these terms are defined in the CCPA) personal information (including personal information of individuals that we know to be under the age of 16), and we have not “sold” or “shared” personal information in the past twelve (12) months.

Use and disclosure of sensitive personal information

As detailed in the table above, we collect certain “sensitive personal information” (as defined in the CCPA) from Candidates after extending an offer to them. However, we do not collect or process sensitive personal information for the purpose of inferring characteristics about Candidates. We only use and disclose sensitive personal information provided by Candidates as necessary to conduct background checks and/or identity verification and employment authorization screenings, without inferring characteristics about the Candidates.

Retention of personal information

As explained in the “Retention of personal information” section above, we consider several factors when determining the appropriate retention period for personal information, including (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of the personal information; (iii) the purpose(s) for which we process the personal information and whether we can achieve such purpose(s) through other means; and (iv) the applicable legal and regulatory requirements (including minimum information retention requirements as prescribed by laws, regulations, or regulatory bodies).

Your legal rights

As a California resident, you have the right to request that we:

• Disclose to you the following information covering the twelve (12) months preceding your request:
  • the categories of personal information that we have collected about you;
  • the categories of sources from which we have collected such personal information;
  • the business or commercial purpose for collecting, selling, or sharing your personal information (as applicable);
  • the categories of third parties to whom we have disclosed your personal information;
  • if we have sold, shared, or disclosed your personal information for a business purpose, two separate lists detailing the following (i) sales and shares, identifying the personal information categories that each category of recipient received; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and
  • the specific pieces of personal information we have collected about you (“request to know”).
• Correct inaccurate personal information that we maintain about you, taking into account the nature of the information and the purpose(s) of the processing (“request to correct”).
• Delete the personal information that we have collected from you, subject to certain exceptions (“request to delete”).

You also have the right not to receive discriminatory treatment for the exercise of any of the above-listed rights. This means that we will not retaliate against you as a Prospect, Applicant, or Candidate for exercising your rights under California law.

If you are a California resident and are interested in exercising any of the above-listed rights, you can do so by:

• emailing us at privacy.team@davispolk.com with the subject line “California Privacy Rights Request – Prospect/Applicant/Candidate;”
• completing and submitting the form available here; or
• calling us at 1-800-274-3125 (toll free) and asking to exercise your California privacy rights.

Please note that these rights are not absolute and that we may refuse to honor your request if a statutory or regulatory exemption applies.

Exercising your rights does not require you to create an account with us. However, to protect your privacy, we will require the matching of up to three (3) pieces of personal information provided with your request with information that we maintain to verify that it is you making the request. Where applicable, we will use the requested information for verification purposes only. Please note that we may decline a request where we are unable to verify your identity and confirm that the personal information that we maintain relates to you.

You may authorize another natural person or a business entity to submit a request to know, request to correct, or request to delete on your behalf (an “authorized agent”). An authorized agent will need to demonstrate that you have given them signed permission to submit the request on your behalf unless you have provided the agent with power of attorney pursuant to applicable probate law. Depending on the evidence provided, we may also contact you to verify your identity with us or request confirmation from you that the agent is authorized to submit the request on your behalf.