Global Privacy Notice for Job Applicants

1. Information about Broadridge

All of the companies in the Broadridge Group are committed to protecting the privacy of our current and former employees, job applicants, and other people with whom we work. 

2. Personal Information Processed by Broadridge

2.1 We collect, use, store and, when necessary, transfer, your personal information through automated and/or paper-based data processing systems. 

2.2 We may process the following categories of your personal data:

1. Information you have provided to us in a resume/curriculum vitae and covering letter.
2. Information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications.
3. Information you provide to us during an interview.
4. Information you provide us as part of any communications, such as e-email.
5. Aptitude test results (where applicable).
6. Background screening data from screening checks, subject to applicable law, if you are selected for a position. These checks are typically provided to us by third parties who provide employment background screening services.

2.3 We may also collect, store and use:

1. The following "special categories" of more sensitive personal information:
   1. Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
   2. Information about your health, including any medical condition, health and sickness records.
2. Criminal convictions, subject to applicable law.

2.4 Please note that you are not required to provide any personal information to Broadridge. However, if you do not provide certain personal information to us, we are unable to consider you for employment.

3. Legal Basis for Processing and How We Will Use Your Personal Information

3.1 Processing of personal information:

1. We will process your personal data in order to pursue Broadridge’s legitimate interests in recruiting appropriate personnel into our organization and, where recruitment activity leads to you becoming employed or engaged by us, in order to carry out appropriate functions as an employer or consultant. We will only do so provided your interests and fundamental rights do not override those interests.
2. We will use the personal information we collect about you to:
   1. Assess your skills, qualifications, and suitability for the work or role as applicable.
   2. Carry out background and reference checks, where applicable.
   3. Communicate with you about the recruitment process.
   4. Keep records related to our hiring processes.
   5. Comply with legal or regulatory requirements.

3.2 Processing of sensitive and/or special category personal information:

1. We will process your criminal convictions related personal information and/or special category of sensitive personal information based on your explicit consent. You have the right to withdraw this consent at any time by notifying us in writing.
2. We may use your sensitive personal information in the following ways:
   1. We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
   2. We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

4. Automated Decision-Making and Profiling

We will not use profiling techniques or make automated-decisions about you that may significantly affect you, unless:

1. The decision is necessary as part of a contract that we have with you;
2. We have your explicit consent; or
3. We are required by law to use the technology.

5. Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

6. Transfer of Your Personal Information

6.1 Your personal information may be transferred to:

1. Other Broadridge affiliates located in other geographic locations, which will only process your personal information for the purposes set forth in this Privacy Notice; or
2. Our third party service providers, which use your personal information only as permitted by our contracts with them (such as for recruitment services, verification or vetting, as appropriate).

6.2 We will also always transfer personal information when required to do so by law.

7. International Transfers

7.1 Your personal information may be processed in a location outside the country of your employment or engagement which may not have equivalent privacy or data protection laws. However, regardless of where your personal information is transferred, we will protect it in accordance with this Privacy Notice and applicable law.

7.2 We generally use approved European Union Standard Contractual Clauses to assure that personal information is adequately protected when it is transferred out of the European Economic Area, but we may also make transfers to recipients with approved Binding Corporate Rules or to recipients in the United States who have certified to the Privacy Shield Framework.

8. Data Retention

If you become a Broadridge employee or consultant, we will retain your application data as part of your employee or consultancy file. If you are not offered the job that you have applied for, we will retain your job application data in compliance with applicable law so that we may contact you about future opportunities. Please understand that these rights are subject to some limitations, such as when we are processing or retaining data to comply with our own legal obligations.

9. Your Rights

Broadridge respects your rights to access, correct and request erasure or restriction of your personal information as required by law. This means:

1. You generally have a right to know whether or not Broadridge maintains your personal information. If we do have your personal information, we will provide you with a copy (subject to the rights of others) upon request. If your information is incorrect or incomplete, you have the right to ask us to update it.
2. You have the right to object to our processing of your personal information. If we are processing your personal information on the basis of your consent, you may withdraw your consent at any time.
3. You may also ask us to delete or restrict your personal information.

10. Important Information for California Residents

11. Who to Contact?

11.1 To exercise any of your rights or if you have any queries about this Privacy Notice, please call 1-888-237-7769 or + 1 201-714-3864 and your query will be routed as appropriate.

11.2 If you believe that we have processed your personal information in violation of applicable law, you may file a complaint with privacy@broadridge.com.

Important Information for Prospective State of California Job Candidates

Broadridge Financial Solutions, Inc. and its affiliates (“Broadridge”) are providing this privacy notice to give individuals whose personal information is collected for human resources purposes information about our privacy practices. 

Broadridge is committed to protecting the privacy of prospective job candidates. Broadridge has a Global Privacy Policy that protects your personal information no matter how or where it is collected, used or stored. It also protects the personal information of others that we collect from you, such as information about your family members or beneficiaries. Broadridge also complies with applicable privacy and security laws, including the California Consumer Privacy Act (“CCPA”).

The CCPA provides California residents with specific privacy rights. California consumers have rights to receive privacy notices, access and request deletion of their personal information. 

Please contact the Broadridge Privacy Office for assistance with privacy matters. The Privacy Office can be reached at: privacy@broadridge.com.

1. General Purposes for Collecting, Using and Disclosing Personal Information

Broadridge collects personal information about its prospective, current, and former associates, contingent workers, and other individuals in the context of an employment or contractual work relationship (such as dependents). The categories of personal information, along with representative data elements, are listed in the chart below. We generally use, disclose and retain personal information for the following purposes:

a. Personal Information pertaining to prospective associates or contingent workers may be collected, use and shared for:

• Recruitment and staffing, including evaluation of skills and job placement;
• Hiring decisions, including negotiation of compensation, benefits, relocation packages, etc.;
• Determining an individual’s eligibility to work and assisting with work permits or visas;
• Risk management, including background checks, vetting and verification; and
• Our Everyday Business Purposes (defined below).

b. Personal Information pertaining to current associates and contractors may be collected, used and shared for:

• Staffing and job placement, including scheduling and absence management;
• Administration of compensation, insurance and benefits programs;
• Time and expense management and other workplace administration tasks (such as managing our computers and other assets, providing communication and social media tools, facilitating relationships within Broadridge and with our customers and others, and offering community programs);
• Diversity programs;
• Health and wellness programs, including offering onsite medical care and accommodating disabilities;
• Occupational health and safety programs (including required reporting, disaster and pandemic planning, and incident management);
• Talent and performance development, skills management and training, performance reviews (including customer surveys), engagement surveys, and recognition and reward programs
• Succession planning and tasks related to retention or reductions in force;
• HR support services, such as responding to inquiries, providing information and assistance, and resolving disputes;
• Risk management, including employee and premises monitoring;
• As requested by individuals, such as providing employment and income verification; and
• Everyday Business Purposes.

c. Personal Information pertaining to former associates may be collected, use and shared for: 

• Re-employment;
• Administration of compensation, insurance and benefits programs, including retiree and alumni programs;
• As requested by individuals, such as providing employment and income verification; and
• Everyday Business Purposes.

d. Personal Information pertaining to individuals whose information is provided to Broadridge in the course of HR management (such as information pertaining to employees’ family members, beneficiaries, dependents, emergency contacts, etc.) may be collected, use and shared for:  

• Legal compliance (such as in connection with required screening programs);
• Administration of compensation and benefit programs;
• Workplace administration, such as maintenance of directories and to comply with child support orders or garnishments;
• To maintain emergency contact lists and similar records; and
• Everyday Business Purposes.

Everyday Business Purposes means the following purposes for which personal information may be collected, used and shared:

• Identity and credential management, including identity verification and authentication, issuing ID card and badges, system administration and management of access credentials;
• Security, loss prevention, information security and cybersecurity;
• Legal and regulatory compliance: all uses and disclosures of Personal Information that are required by law or for compliance with legally mandated policies and procedures, such as: anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines;
• Corporate audit, analysis and consolidated reporting;
• To enforce our contracts and to protect Broadridge, our workers, our clients and their employees and the public against injury, theft, legal liability, fraud or abuse, to people or property;
• As needed to de-identify the data or create aggregated datasets, such as for consolidating reporting, research or analytic;
• Making back-up copies for business continuity and disaster recovery purposes; and
• As needed to facilitate corporate governance, including mergers, acquisitions and divestitures.

2. Categories of Personal Information

This chart describes the categories of Personal Information that Broadridge collects in connection with its employment and contractual work relationships:

Effective January 1, 2020