UBS takes your privacy seriously. The candidate privacy notice contains information on what personal data UBS and its group companies (“UBS”, “we”, “our”, or “us”) collect(s), what they do with that information, and what rights you have.
This applies to Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Jersey, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Monaco, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the UK.
UBS CANDIDATES AND PROSPECTIVE CANDIDATES PRIVACY NOTICE
Data protection under the EU General Data Protection Regulation (EU GDPR)
UBS takes your privacy seriously. This privacy notice contains information on what personal data UBS and its group companies (“UBS”, “we”, “our”, or “us”) collect(s), what they do with that information, and what rights you have. If you have any questions or comments about this notice, please contact the Group DPO Office at email@example.com. To run our business, UBS collects and uses information about living individuals (also known as “personal data”), including information about our prospective, current and former candidates for employment with UBS.
As part of our commitment to protect your personal data in a transparent manner, we want to inform you:
- why and how UBS collects, uses and stores your personal data;
- the lawful basis on which your personal data is processed; and
- what your rights and our obligations are in relation to such processing.
1. What does this Privacy Notice cover?
This notice applies to any and all forms of use of personal data (“processing”) by us in Jersey, Monaco and the European Economic Area (“EEA”).
2. What type of personal data do we collect?
For prospective, current and former candidates, we collect basic identification information, such as your name, title, position, professional history, experience and contact details.
If you actively apply for a role with UBS, we will usually also collect:
- Detailed identification information (e.g. name, position, title, office location, business telephone number, date and place of birth, picture, ID card, passport numbers and other national ID numbers as required, private email and/or postal address, country, and car registration number);
- Personal and physical characteristics (e.g. gender, date of birth, immigration status, and physical characteristics);
- Education and employment information (e.g. remuneration at your current employer, employment dates with your current employer, interview performance evaluation and scores in any online testing, position information such as position title, and language skills);
- Information submitted as part of your application (e.g. recordings of any video interviews in which you participate, and anything you choose to submit by choice in support of your application); and
- Where relevant, behavioural information and information about personality traits such as data collected to assess a candidate’s fit with UBS behaviours.
Information you submit as part of your application must be true, accurate, complete and not misleading. You understand that any false or misleading statements or omissions made by you during the application process, including your application and any assessments and interviews, may be sufficient cause to justify the rejection of your application or, if you have already become an employee, the immediate termination of your employment, subject to due process.
If you provide information about your family or any other third party to us as part of your application (e.g. emergency contacts or referees) then, before providing us with such information, you must inform the relevant individuals that you will disclose their personal data to us and provide a copy of the information in this notice to them.
If you accept a role with UBS, then in order to conduct any necessary background checks and create your record in the UBS Group employee database, we will usually also collect:
- Family information (e.g. marital status, and details of any family or personal relationships within UBS); and
- Financial information (e.g. summary credit history, bank account details, tax-related information, and information required to undertake required checks for money laundering, criminal activities, corruption, terrorist financing and related matters).
In some cases, the personal data that we process will also include special categories of data, such as diversity-related information (including data about racial and ethnic origin, religious beliefs and other beliefs of a similar nature) and data about alleged or proven criminal offences, in each case where permitted by law.
In some cases, the personal data we collect from you is needed to meet our legal or regulatory obligations. If so, we will indicate to you that the provision of this information is mandatory, and the consequences if we cannot collect this information.
In some cases, UBS will also collect personal data indirectly from third parties, such as recruitment agencies that you used to apply to UBS, background check providers such as HireRight and other administration services providers (for instance who provide candidate shortlisting services), or from publicly available sources such as business- and employment-orientated social networking services and job boards.
3. On which legal basis and for which purposes do we process personal data?
3.1 Legal basis for the processing
We are not allowed to process personal data if we do not have a valid legal ground. Therefore, we will only process your personal data if:
- the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request, such as preparing a contract of employment for you following a decision to make you an offer of employment;
- the processing is necessary to comply with our legal or regulatory obligations, such as reference requirements;
- the processing is necessary to protect the vital interests of the relevant individual or of another natural person, such as providing disability access to UBS premises for interviews where applicable;
- the processing is necessary for the legitimate interests of UBS, and does not unduly affect your interests or fundamental rights and freedoms (see below);
- the processing is necessary for the performance of a task carried out in the public interest; or
- in some cases, and if requested from you from time to time, we have obtained prior consent.
Examples of the ‘legitimate interests’ referred to above are:
- to benefit from cost-effective services (e.g. we may opt to use certain IT platforms offered by suppliers);
- to determine whether a candidate or potential candidate’s skills, qualities and experience are suitable for a role within UBS, and determine whether or not to either (i) make an offer of employment with UBS; or (ii) approach a candidate with a view to making an offer of employment with UBS, on this basis;
- at the appropriate stage in the recruitment process (i.e. as part of making an offer of employment to you), to verify the accuracy of information you have provided to us as part of your application, including through background screening;
- to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks and security of UBS premises;
- to exercise our rights under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property (where applicable); and
- to meet our corporate and social responsibility objectives.
To the extent that we process any special categories of data relating to you, we will do so because:
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of a legal claim;
- the processing is necessary for reasons of substantial public interest; or
- you have given your explicit consent to us to process that information (where legally permissible).
3.2 Purposes of processing
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process candidates’ personal data to:
- undertake recruitment activities, such as determining the suitability of a candidate’s qualifications, carrying out background checks, including checking for any existing or potential conflicts of interest or any other restrictions which may otherwise restrict or prevent a candidate’s employment with UBS;
- assist us in managing external providers (e.g. recruitment agencies – see below for further information about when we work with third parties);
- manage our HR records and update the UBS Group employee database;
- where relevant, manage and make available personal data within the UBS Group;
- reply to an official request from a public or judicial authority with the necessary authorisation;
- comply with any legal obligations imposed on UBS in relation to its recruitment practices; and
- to enable a transfer to a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of UBS’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
4. How do we protect personal data?
All personnel accessing personal data must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure their confidentiality. They are also required to follow all technical and organisational security measures put in place to protect the personal data.
We have also implemented adequate technical and organisational measures to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal data, with particular care for sensitive data.
5. Who has access to personal data and with whom are they shared?
5.1 Within the UBS Group
We make available personal data to members of our personnel and of other companies of the group to which we belong (the “UBS Group”) to complete the purposes indicated in section 3.2 above. Such other companies of the UBS Group will either act as another controller under this notice or will only process personal data on behalf and upon request of the controller.
In Russia the information will be processed by OOO UBS Bank, located in Moscow, Paveletskaya pl 2-2, in accordance with the applicable laws and regulations.
5.2 Outside the UBS Group
To the extent permitted by law, we usually also transfer personal data to third parties outside the UBS Group to complete the purposes listed in section 3.2 above including:
- third party service providers, such as our IT systems providers, our hosting providers, cloud service providers, database providers, consultants (including the recruitment agency whom you used to apply to UBS, if applicable, and lawyers) and third parties who carry out pre-employment checks on prospective employees (such as HireRight) - each of these service providers has signed contracts to protect your personal information;
- a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of UBS’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
- any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request;
- the referees provided on your application form to UBS;
- any central or local government department and other statutory or public bodies; and
- any legitimate recipient of communications required by laws or regulations.
5.3 Transfers outside the European Economic Area
The personal data transferred within or outside the UBS Group as set out in sections 5.1 and 5.2, is in some cases also processed in a country outside the EEA, which covers the EU member states, Iceland, Liechtenstein and Norway. Non-EEA countries may not offer the same level of personal data protection as EEA countries.
If your personal data is transferred outside the EEA, we will put in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules. To ensure this level of protection for your personal information, UBS may use a data transfer agreement with the third party recipient based on standard contractual clauses approved by the European Commission or ensure that the transfer is to a jurisdiction that is the subject of an adequacy decision by the European Commission or to the US under the EU-US Privacy Shield framework. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below. Where UBS transfers personal data to other group companies, we rely on the standard contractual clauses.
A list of the countries in which UBS operates (inside and outside the EEA) can be found at https://www.ubs.com/locations.html.
6. How long do we store your data?
We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. In general, although there may be limited exceptions, data relating to unsuccessful candidates for roles within UBS is kept for 36 months after the date on which we notify you that your most recent application has been unsuccessful; data relating to potential candidates for roles within UBS is kept for 36 months from the date of our last communication with you; and data relating to successful candidates is dealt with by the employee privacy notice that will be provided to you upon joining UBS.
However, if individuals wish to have their personal data removed from our databases, they can make a request as described in section 7 below, which we will review as set out therein.
7. What are your rights and how can you exercise them?
7.1 Your rights
You may have a right to access and to obtain a copy of your personal data as processed by UBS. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction of your personal data.
You may also have the right to:
- object to the processing of your personal data;
- request the erasure of your personal data;
- request restriction on the processing of your personal data; and/or
- withdraw your consent where UBS obtained your consent to process personal data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).
UBS will honour such requests, withdrawal or objection as required under applicable data protection rules but these rights are not absolute: they do not always apply and exemptions may be engaged. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to better understand your request. If we do not comply with your request, we will explain why.
7.2 Exercising your rights
To exercise the above rights, please send an email to firstname.lastname@example.org.
If you are not satisfied with how UBS processes your personal data, please let us know and we will investigate your concern. Please raise any concerns by contacting the Office of the Group DPO at email@example.com.
If you are not satisfied with UBS’s response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen. The contact details of each Data Protection Authority can be found at the following website: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
In the interests of keeping personal data properly up to date and accurate, we ask you to inform us of any change in relation to your personal data (such as a change of address).
8. Updates to this notice
This notice was last updated in December 2018. It may be subject to amendments. Any future changes or additions to the processing of personal data as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
UBS CANDIDATES AND PROSPECTIVE CANDIDATES PRIVACY NOTICE
Data protection for all other countries
The information below is important - be sure to read it before you move forward. By continuing with the application you are consenting to the following privacy terms ("Privacy Notice"):
- For what purposes will your Information be used?
The information you submit / provide as a candidate / prospect ("Candidate") in your application or otherwise provide to UBS, whether verbally or in writing, and throughout or in connection with the recruitment process, including during initial exploratory conversations, assessments and interviews ("Information") will be hosted and stored on behalf of UBS by UBS branches, subsidiaries, or affiliated companies (collectively, "UBS"), and/or various third party suppliers based around the world.
Except with your express consent or otherwise permitted by applicable law, the Information will only be used or otherwise processed for the following purposes: (i) recruitment (including carrying out appropriate background checks); (ii) marketing purposes related to recruitment, (iii) legal; (iv) regulatory; (v) data retention; (vi) statistical (diversity reporting, trend analysis, metrics reporting); and (vii) personnel administration and management purposes; ("Purposes").
You understand that in some locations, the Information you submit may not be subject to the same legal protection as is mandated in your home country and that the laws regarding privacy, data protection, and confidentiality of personal information may not be accorded the same protection as in your home country. UBS will, however, treat your Information in accordance with this Privacy Notice anywhere in the world that it is received.
For the avoidance of doubt, UBS processes Information as permitted by applicable law and may rely on any lawful grounds other than consent where the law permits it. Such lawful grounds may include but are not limited to processing of personal information to comply with a legal obligation, contractual necessity and/or legitimate interests
- Who are the people who have access to or will process your Information?
UBS operates through branches, subsidiaries and business groups around the world and your Information may be accessed by / shared with and retained by any of these UBS branches, subsidiaries, or affiliated companies for the Purposes (see above). The controller of your Information (data controller) is the affiliate of UBS to which you have submitted / provided the Information.
In Russia, the information will be processed by OOO UBS Bank, located in Moscow, Paveletskaya pl 2-2, in accordance with the applicable laws and regulations.
UBS may also release the Information to a recruiting agency or other third party service provider which may be located outside of your home country to perform functions on UBS' behalf for or in support of UBS' processing of the Information within the Purposes (such as contacting you by phone or sending you e-mail, coordinating or organizing meetings with you or providing IT support). The third party service providers performing functions on behalf of UBS have to meet high security standards to protect your Information and will treat it confidentially and in accordance with this Privacy Notice. UBS may also release the Information to other third parties pursuant to a court order, directives or orders of states authorities or as required by law.
If you were referred to UBS by a UBS employee ("Referring Employee"), the Referring Employee will receive high-level information related to the status of your application (such as "Application under review", "Interviews/Assessment in progress", "No longer in process" or "Offer accepted"). The Referring Employee may be located outside of your home country in any of the UBS branches, subsidiaries, or affiliated companies. Other than high-level information about the status of your application, UBS will not share the Information that you submit in your application or otherwise provide to UBS with the Referring Employee.
- What information do we expect from you?
You confirm that all the Information you submit, including this application, will be true, accurate, complete and not misleading. You understand that any false or misleading statements or omissions made by you during the application process, including this application and any assessments and interviews, may be sufficient cause to justify the rejection of your application or, if you have already become an employee, the immediate termination of your employment, subject to due process.
- What can you do if you have difficulties in applying online?
UBS encourages you to apply online. Should you, however, have difficulties in applying online or there are circumstances that mean you are unable to apply online, please contact us by e-mail or letter at the address of the UBS office in the relevant country to discuss alternative ways you can apply.
- Why and how do we retain your Information?
The Information submitted to us may be retained for the Purposes described by UBS or by a third party on behalf of UBS in accordance with this Privacy Notice.
In the event that you are invited to attend a testing session or interview and assessment day, all assessment data will be retained by UBS or a third party service provider on behalf of UBS in accordance with this Privacy Notice.
We may at a later stage in the recruitment process carry out a verification of Information you have provided, including that provided in your application. You agree that such verification processes may be carried out by UBS or a third party service provider on behalf of UBS in accordance with this Privacy Notice. If your application is successful, you agree that we may also use your Information for personnel administration (including, but not limited to, requesting that you complete recruitment related surveys) and management purposes.
In the event that exploratory conversations do not continue or your application is unsuccessful, the Information you submit may be referred to in the event that you make a later application and we may attempt to contact you via the e-mail address or the telephone number you provide in the event that a subsequent vacancy becomes available for which you may be suitable.
If you have applied for a role, your application is only an application for that specific position. If you are interested in other positions at UBS, please apply separately for these openings as UBS will not necessarily automatically consider you for other openings.
- What data about you do we store and process?
UBS checks the data of a Candidate for risk and compliance reasons (e.g. to comply with anti-money laundering requirements). To this effect, UBS will perform a name check in a central database, where data from publicly available sources is provided primarily by third party service providers. Such public data supplied by external providers may also contain data on a person's racial and ethnic origin, political opinions, religious or philosophical convictions, and union membership. UBS uses only data which is related to the hiring and execution of the employment and/or which is necessary to do the required checks on money laundering, criminal activities, corruption, terrorist financing and similar compliance aspects. The checks are performed by specially authorized UBS staff or specialist third party background check providers selected by UBS. The data and results are only used for the aforementioned Purposes.
- How can I access, change or remove my Information?
Your Information may be retained and accessible in the system for the purposes mentioned for up to 36 months from the date your profile is created or was last modified, whichever is later. After this period it will be destroyed, except that a Candidate's data for positions in the USA may be retained for a longer period of time.
If you do not agree to UBS retaining your Information, please contact us using the information provided online.
If we deem it appropriate or necessary, we reserve the right to, without notifying you, delete or remove from our systems the Information you submitted to us, at any time.
In some circumstances you may have the right to object to our processing of your data (and any other rights granted) under applicable data protection / privacy laws. If you wish to exercise any of these rights, please contact us using the information provided online.
You can also change or remove the Information you have submitted directly in the system through your secured online account.
- What is to be considered when Information is transmitted over the Internet?
The application form, all Information contained in it and any information you provide to us during the application process will be transmitted over the Internet, which is openly accessible to all. As such, you acknowledge that such means of transmission is not secure and the data in question may be transmitted across national boundaries without restriction, irrespective of the location of the sender and recipient. Neither UBS nor any of our third party service providers accept any liability whatsoever (whether for injury, loss or damage or howsoever incurred) to Candidates as a result of transmission of their personal data (including any errors, delays or failure in transmission) via the Internet.
This Privacy Notice may be subject to amendments. Any changes or additions to the processing of personal data as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
By continuing with the application, you confirm your acceptance of the terms and conditions of this Privacy Notice and give your consent to the processing of your Information (including any sensitive personal data) as envisaged by and in accordance with these terms and agree that UBS assumes no liability and is under no legal obligation unless explicitly stated in this Privacy Notice or otherwise as agreed in writing between you and UBS. You can withdraw your consent to the processing of your Information at any time. However UBS reserves the right to continue to process your Information where it has a legal basis to do so.
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