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CAREERS SITE PRIVACY NOTICE

Last Updated: October 2022

Prudential Financial, Inc. and its affiliated entities (collectively “PFI”) value your trust and are committed to the responsible management, use and protection of personal information. PFI operates in many different countries. Some of these countries have laws related to the collection, use and transfer of the personal information of individuals. This Careers Site Privacy Notice (“Notice”) is applicable to information collected by PFI from you during your use of our Careers site (the “Careers Site”). If you merely browse the Careers Site, then only the section of this Notice entitled “Information Collected Automatically” will be applicable to you. All sections of this Notice are applicable if you submit an application or your résumé to us.

Personal information submitted elsewhere on PFI’s and its affiliates’ web sites will be used in accordance with the Online Privacy Statements applicable to those websites.

This Careers Site is operated by PFI and its affiliates located at 751 Broad Street, Newark, NJ 07102, U.S.A. in order to support the recruitment functions of PFI.

About This Notice

This Notice describes our practices regarding all the information that we collect in connection with your application for a job or internship with PFI.

Some of the countries in which PFI operates have laws related to the collection, use, transfer and disclosure of the personal information of individuals and PFI is committed to protecting the privacy of our current and potential associates. The purpose of this Notice is to give you information about what personal information we collect, use, transfer and disclose, and why.

This Notice does not constitute an offer or promise of employment with respect to any employment position posted or described on the Careers Site. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become an employee, any Personal Information that you submit may become part of your employee file and may be used for other employment/work-related purposes. You will be provided with a further Privacy Notice which sets out how we use your personal information in the course of your employment or engagement with us.

Submitting your personal information is entirely voluntary and you are free to decide what types of personal information, if any, to submit to us. However, if you choose not to submit your personal information, this may limit our ability to consider your candidacy.

INFORMATION WE COLLECT

Information You Provide

The types of information requested from you and the manner in which that information is collected and assessed are determined by the requirements of the country in which the position is located or the information is collected and stored, and not the country in which you reside. This Notice covers any personal information you submit through the Careers Site as part of the job application or job search process.

We may collect the following information from you regarding your application:

  • First name, middle name last name, address, telephone number, e-mail address, and other contact information;
  • Registration login and password;
  • Work authorization status;
  • CV, résumé, cover letter, previous work experience, skills, education information, title of qualifications and awards or any other information you elect to provide;
  • Professional qualifications and other work-related licenses, certifications held, certification expiration dates, professional memberships and awards;
  • Languages and other relevant skills;
  • Reason for considering leaving current role;
  • Employment preferences, willingness and eligibility to relocate, desired salary, available start date; and
  • How you heard about the position and information relating to references.

NOTE: We ask that you avoid submitting the following information which may qualify as sensitive information under applicable law, except where such information is legally required or specifically requested: information on race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, and veteran status.
Any information you submit must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

Information Collected Automatically

Please read our Cookies & Similar Technologies Statement to learn how we collect information from you automatically when you use the Careers Site and how we use such information.

Information from Other Sources

PFI may obtain information about you from your references or from a background check report in connection with your application, as required or permitted by applicable law.

USE OF INFORMATION

The information that you submit to PFI will be used for PFI’s global personnel recruitment, management and planning purposes. Data protection law seeks to ensure that the way your personal information is used is fair and lawful. Some countries require that we have a legal justification for using your personal information. To comply with the law, we need to tell you the legal justifications we rely on for using your personal information. PFI relies on the legal justifications below to collect, use, transfer and disclose (“Process”) personal information you submit through the Careers Site:

  • To process your application and assess your capabilities and qualifications for a job: This is in our legitimate interests to enable us to develop our business operations and recruit the workforce we need to support our business. Depending on the circumstances, this use of Personal Information may also be necessary to take steps prior to entering into a contract between you and us or to perform a contract.
  • To provide you with information about job and internship opportunities and the application process: This is in our legitimate interests to enable us to provide the services to you and recruit the workforce we need to support our business.
  • Conduct reference checks: This is in our legitimate interests to enable us to develop our business operations and recruit the workforce we need to support our business. Depending on the circumstances, this use of Personal Information may also be necessary to take steps prior to entering into a contract between you and us or to perform a contract
  • Provide any services available to you on the Careers Site and to monitor the operation and performance of the site and services: This is in our legitimate interests to provide the services to you, to recruit the workforce we need to support our business, as well as to improve and ensure the security of the site and services. Depending on the circumstances, this use of Personal Information may also be necessary to take steps prior to entering into a contract between you and us or to perform a contract between you and us.
  • Respond to your inquiries and communicate with you about your application: This is in our legitimate interests to enable us to provide the Careers Site, recruit the workforce we need to support our business, and communicate and manage our relationship with you
  • Comply with or monitor compliance with any applicable law or regulation: We do this for compliance with legal obligations to which we are subject or, depending on the circumstances, for our legitimate interests to comply with laws and regulations.
  • Conduct background checks if we offer you a position: This is in our legitimate interests to enable us to recruit the workforce we need to support our business.
  • To notify you about changes to the Careers Site or the services: This is in our legitimate interests to enable us to operate our business, and to ensure you are able to use our site and services.
  • To improve the quality of the Careers Site, the services and our training: This is in our legitimate interests to enable us to: (i) enhance, modify, and improve the Careers Site and the services for your benefit; and (ii) ensure our employees are adequately trained.
  • To manage complaints, feedback and queries: This is in our legitimate interests to enable us to operate our business, and to deal with complaints and queries appropriately
  • For diversity and equality monitoring purposes: We may process this for our legitimate interests (i.e. to ensure the diversity of our workforce) and for compliance with legal obligations to which we are subject
  • Protect against fraud or other illegal activity or for risk management purposes: This is in our legitimate interests in order to conduct and manage our business.
  • Respond to inquiries or requests from government or public authorities: This may be to comply with legal obligations to which we are subject; or in our legitimate interests (i.e. to co-operate with official bodies).
  • To comply with any legal or regulatory obligations (including in connection with a court order): We do this for compliance with legal obligations to which we are subject or, depending on the circumstances, for our legitimate interests to comply with laws and regulations.
  • To enforce or apply the agreements concerning you (including agreements between you and us) or our policies: This is in our legitimate interests in order to conduct and manage our business.
  • Protect the legal rights, privacy or safety of PFI or its employees, agents and contractors: This is in our legitimate interests in order to conduct and manage our business and also for the legitimate interests of our employees, agents and contractors (i.e. to ensure their rights are protected).
  • Protect the safety and security of visitors to the Careers Site: This is in our legitimate interests in order to conduct and manage our business and protect those that visit our websites and other properties. Depending on the circumstances, we may also do this for compliance with legal obligations to which we are subject.

We may also request your consent to collect, use, transfer and disclose (“processed”) personal information you submit through the Careers Site in circumstances where it is required and/or permitted by local law. Where we have relied upon your consent to process your Personal Information, you have the right to withdraw that consent. This right only applies where we process Personal Information based upon your consent.

For more sensitive special categories of personal information (such as racial or ethnic origin, religious or philosophical beliefs, health data or details concerning sex life or sexual orientation) we will, to the extent permitted by applicable local law, rely on one or more of the other legal justifications set forth above and typically one of the following additional justifications (however other legal justifications may be available), to the extent permitted by applicable local law: the use is necessary for the carrying out of obligations and exercising our or your specific rights under employment laws; or the use is necessary for the establishment, exercise or defense of legal claims, or whenever courts are acting in their judicial capacity (for example, when a court issues a court order requiring the processing of Personal Information); or your consent (but only in exceptional circumstances). Additional legal justifications may also be available in the country in which you are based, and we may also rely on these justifications from time to time.

Personal information about you will be added to PFI’s international candidate database and will be used for the purposes of considering whether your qualifications are suitable for other employment positions available at PFI. This Notice does not constitute an offer or promise of employment with respect to any employment position posted or described on the Careers Site. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become an employee, any personal information that you submit may become part of your employee file and may be used for other employment/work-related purposes.

However, if you do not provide sufficient information, PFI may be unable to consider your employment application.

PFI may anonymize and/or aggregate your personal information and, to the extent permitted by applicable law, use and disclose such anonymized and/or aggregated information for any purpose.

SHARING OF PERSONAL INFORMATION

PFI may share personal information with affiliates that are involved in evaluating candidates for a given position. Prudential Financial, Inc. will remain responsible for personal information that is jointly used with affiliates. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.

PFI may share personal information about you as we believe to be necessary or appropriate under applicable law, including laws outside your country of residence in order to: (1) protect the legal rights, privacy or safety of PFI or its employees, agents and contractors; (2) protect the safety and security of visitors to our web sites or other properties; (3) protect against fraud or other illegal activity or for risk management purposes; (4) respond to inquiries or requests from government or public authorities; (5) permit us to pursue available remedies or limit the damages that we may sustain; (6) enforce our enforce our policies; or (7) comply with the law or legal process.

PFI may share personal information with our third-party service providers who provide services such as recruiting assistance, background check processing, and similar services. Those third parties will be required to protect personal information.

PFI may need to make certain personal information available to other parties such as legal and regulatory authorities; accountants, auditors, lawyers and other outside professional advisors in all of the countries in which PFI operates; and to companies that provide products and services to PFI (such as payroll, pension scheme, benefits providers; human resources services, performance management, IT systems suppliers and support; third parties assisting with equity compensation programs, or other service providers). PFI will remain responsible for the personal information collected.

PFI may transfer information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Sharing your personal information may include transferring personal information to other countries (including countries other than where you are based that have a different data protection regime than is found in the country where you are based). If you are located in the European Economic Area (the “EEA”) this may include countries outside of the EEA. A list of the affiliate companies that may jointly process your personal information is available at our securities disclosures including 10-K available here, and/or upon request (please refer to the ‘Contact Us’ section at the end of this Notice).

Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available at: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. As for transfers to other countries, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your information.

DATA RETENTION

We will retain personal information for the period necessary to fulfil the purposes outlined in this Notice unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; and (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). We may also retain your information for the purpose of considering whether your skills are suitable for other opportunities. If you do not wish us to do this, please contact GlobalHRDataMgt@prudential.com. We may remove personal information for inactive accounts from our records, subject to any applicable legal or regulatory obligations. Furthermore, PFI may delete personal information about you (including your CV/résumé) from our records at any time for any reason. Therefore, please retain your own copy of the personal information provided to us.

ACCESS AND CORRECTION

You may, where permitted by applicable law, request: (i) access to personal information we collect; (ii) its modification or suppression;, (iii) that we restrict its processing; (iv) that we cease using it (objection right); (v) that we transfer personal information to you or another organization in a structured, commonly used and machine-readable format (right to data portability); and/or (vi) in the case of cross-border transfer of personal information, further information regarding how we ensure that the recipient has put in place adequate measures to protect your information. Please email us at GlobalHRDataMgt@prudential.com with any such requests. In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that certain personal information may be exempt from such access, correction, or suppression rights pursuant to local data protection laws.

We encourage you to promptly update your profile to ensure that all personal information is complete and accurate. If you would like to deactivate or remove your personal information from the Careers Site please contact us at GlobalHRDataMgt@prudential.com.

You may have the right under local data protection laws to lodge a complaint with a Data Protection Authority for your country or region or in the place of the alleged misconduct.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

Please do not send sensitive information to us via email. It is your sole responsibility to use the appropriate level of care whenever you communicate with us.

PFI hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Careers Site.

DIVERSITY

PFI is an equal opportunity employer, which means we offer equal treatment to all applicants. PFI does not discriminate, either directly or indirectly, on the grounds of race, colour, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment. In some countries we ask for information on the ethnic origin, gender and disability of our applicants for the purpose of monitoring equal opportunity. If you have a disability and would like to indicate as part of your application any relevant effects of your disability and any adjustment which you consider should reasonably be made to the process to assist your application, you are encouraged to disclose this during the application process.

CURRENT PERSONNEL OF PFI

If you currently work for one of PFI’s business units, you must be eligible to apply for a different position within PFI. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

CHANGES TO THE NOTICE

We reserve the right to amend this Notice at any time in order to address future developments of PFI, changes in industry or legal trends. We will provide the revised Notice upon future communication. You can determine when the Notice was revised by referring to the “Last Updated” legend on the top of this Notice. By continuing to use The Careers Site, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose to discontinue use of the Careers Site.

CONTACT US

The primary company responsible for your Personal Information (i.e. the main data controller) will be the PFI company with whom the vacancy is advertised. A list of the key PFI companies that are data controllers is available by contacting us at Global.Privacy@prudential.com.

Any privacy related matters should be directed to Global.Privacy@prudential.com or using the contact details set out in our public-facing local Privacy Policy for your country.