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EU/UK Data Privacy Notice for Job Applicants

Introduction

Collecting your information

Using your information

Automated decisions

Sharing your information

Retaining your information

Transfers outside the UK / European Economic Area (EEA)

Your rights and responsibilities

 

Introduction

Nuveen, LLC, including its subsidiaries and affiliated investment advisers (“Nuveen” or “we”) respect the privacy of every person who applies or expresses an interest in working with us. You are being sent a copy of this privacy notice because you are applying for work with us in the European Union (“EU”) and / or the United Kingdom (“UK”) (whether as an employee, worker or contractor) or registering your interests to work at Nuveen in the future.

This privacy notice outlines the information that we may collect about you during the recruitment lifecycle and how we may use that personal data (as defined by the EU’s General Data Protection Regulation (“GDPR”) and other UK and European data privacy laws (together the “Privacy Laws”).

This privacy notice also describes the practices of the Nuveen entity to which you are applying for a job opening (as identified in the relevant advertisement) or registering your interest to work at Nuveen in the future.

1.       Collecting Your Information

1.1       Information we collect directly from you

·     In the course of your application being submitted, Nuveen will receive and hold your personal information, such as: contact information such as your name, home address, email address or phone number;

·     Information contained in your resume or CV, and other documents related to the application or recruitment process such as a cover letter, transcripts or certifications, and date of birth;

·     Information about your visa status and authorisation to work in the relevant jurisdiction;

·     Contact information of your referees (although you should be aware that it is your responsibility to obtain your referees permission before providing their personal information to Nuveen);

·     Your job history; and

·     Any other information you choose to provide to Nuveen in connection with your application or registered interest to work at Nuveen in the future.

1.2       Information we may collect from other sources

·     Background check information from employment screening agencies, recruitment agencies, educational institutions, law enforcement agencies, credit agencies, former employers, publicly available registers or other organisations as allowed by local law, for example address history, work experience or employment history, social security number or other national identifier, date of birth and gender;

·     Criminal and credit history, education, employment verification, FCA references, directorship search, public safety verification, professional qualifications;

·     Publicly available professional profiles on websites or social media (e.g. LinkedIn); and

·     Training records from education and professional bodies.

We will not collect sensitive information or “special categories of sensitive personal data” (as defined by the Privacy Laws) about you (such as information about your health or medical history; ethnic origin; political or religious beliefs; trade union, guild or other professional associations memberships; sexual orientation; or criminal record) except where set out below or where you have voluntarily provided it to us or where it is required by law.

Nuveen may be required by law to collect certain personal information about you, or as a consequence of (or to enter into) any contractual relationship Nuveen has with you.  Failure to provide this information may prevent or delay the fulfilment of these obligations.   If you fail to provide information when requested, which is necessary for Nuveen to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

1.3       Information about Criminal Convictions

We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.

2.        Using Your Information

Nuveen will use the information you have provided for the following purposes:

·     Considering your suitability for the role, skill set and qualifications;

·     Verifying the information that you have provided, including by conducting screening (including background screening, where applicable) and onboarding;

·     Communicate with you about the recruitment process and arranging interviews;

·     Where applicable, providing an offer of employment;

·     Keep records related to our hiring processes;

·     Contacting you with details of future roles which may be of interest to you;

·     Complying with employment law obligations and other legal or regulatory requirements; and

·     Undertaking general statistical analysis and reporting, including candidate activity and demographic reports. 

Should you become an employee of Nuveen; any personal information you submit through the application process will be used in connection with your employment as set out in your contract of employment, Nuveen’s Employee Privacy Notice and other applicable internal policies and procedures and as permitted by applicable laws.

In most cases our basis for processing your personal information will be one of the following:

·     To comply with Nuveen's legal obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations or obtaining proof of your right to work status to enable us to meet relevant obligations;

·     To comply with Nuveen's legal obligations to you (e.g. health and safety or anti-discrimination obligations that Nuveen must comply with) or to a third party (e.g. the taxation authorities, health insurance providers, social security authorities or other governmental or quasi-governmental authorities); or

·     To meet Nuveen's legitimate interests or those of a third party, for example to manage Nuveen's potential employees effectively and protect Nuveen against theft or other crime or for internal, external or regulatory investigations.  When Nuveen processes personal information to meet Nuveen’s legitimate interests, Nuveen put in place robust safeguards to ensure that your privacy is protected.

Nuveenmay obtain your consent to collect and use certain types of personal information when Nuveen is required to do so by law (for example, in certain jurisdictions where consent is always required to collect personal information, in relation to our direct marketing activities, Cookies and Tracking Technologies or when we process sensitive personal information). If Nuveen asks for your consent to process your personal information, you may withdraw your consent at any time by contacting privacyoffice@nuveen.com.

3.       Automated Decisions

Nuveen may automatically process your personal information to make decisions or conduct 'profiling' about you for Nuveen's recruitment purposes.  This means Nuveen may process your personal information using software that is able to evaluate your personal aspects and predict risks or outcomes. This may involve decisions about you that relate to, for example, your suitability for a role.  The significance of Nuveen’s actions in this connection is that is that it may impact whether you are offered employment with Nuveen.  If we conduct these types of automated decisions, the logic involved will consist of using an algorithm in order to automatically assess your suitability for the particular role you are applying for on the basis of your information.

Nuveen will only make these kinds of automated decisions about you where:

·     Such decisions are necessary for entering into a contract. For example, Nuveen may decide not to offer you a role based on information about your educational history, professional qualifications and aptitude testing scores Nuveen has collected about you.

·     Such decisions are required or authorized by law, for example for fraud prevention purposes; or

·     You give your consent to Nuveen carrying out automated decision-making.

Subject to local legal requirements and limitations, you can contact Nuveen to request further information about automated decision-making, object to Nuveen's use of automated decision-making, or request an automated decision to be reviewed by a human being.

4.        Sharing Your Information

The Nuveen entity to which you are applying for a job opening (as identified in the relevant advertisement) is the controller responsible for the personal information Nuveen collects and processes and the managers responsible for data privacy issues can be contacted at privacyoffice@nuveen.com.

Nuveen works and may share your personal information with carefully selected third parties who provide various services to Nuveen, these include:

·     Providing background checks including credit or criminal check verification services (to the extent that such checks are permitted under applicable law);

·     Recruitment and selection;

·     Professional and mandatory training;

·     IT services such as website management, data analysis and data backup; and

·     Security and storage services.

Where this occurs Nuveen takes appropriate technical, administrative and physical steps to keep your personal information secure. Where required, your personal information may also be disclosed to law enforcement, regulatory or other government agencies or third parties to comply with legal or regulatory obligations or requests.  

Nuveen is part of a global group of companies and, for recruitment and employment purposes, may use resources and servers located in various countries around the world to use, store or process your personal information, including outside the European Economic Area (EEA) or the jurisdiction in which you reside.  See the section on "Transfers outside the UK / European Economic Area (EEA)" below for more information.

5.        Retaining Your Information

Nuveen will retain your personal information in accordance with its statutory obligations and internal policies and procedures.

If your application is successful, Nuveen will retain your personal information for as long is necessary in respect of your employment application.

If your application is unsuccessful, Nuveen may retain your personal information for a reasonable period of time in respect of Nuveen’s legal or other legitimate business purposes and to contact you about other relevant employment opportunities. Please let us know during the application process or by using the contact details address below if you do not want your personal information to be retained in order to be notified about employment opportunities.

6.        Transfers Outside the UK / European Economic Area (EEA)

Where you are based in the European Union you should be aware that your personal information may be transferred to, stored and processed in a country, such as the United States, that is not regarded by the European Commission as ensuring an adequate level of protection for personal information under European Union law.

Where you are based outside of the European Union, you should be aware that your personal information may be transferred to, stored, and processed in a jurisdiction that is not your home jurisdiction. You consent to the transfer, disclosure, storage and/or processing of your personal information outside the jurisdiction in which the information was originally collected.

Where appropriate, we have endeavoured to put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

7.        Your Rights and Responsibilities

You are responsible for ensuring that the personal information and information you submit is accurate and up to date, as any incorrect information may invalidate your application and, where applicable, any offer of employment. In addition, you may have certain rights (subject to local law) regarding your personal information, these include rights to:

·     Access your personal information;

·     Request proof of the authorization or previous consent given to us to perform the collection and processing of the personal information;

·     Rectify the information Nuveen holds about you;

·     Erase your personal information;

·     Restrict Nuveen's use of your personal information;

·     Object to Nuveen's use of your personal information;

·     Request information about the use and processing of your information;

·     Revoke the consent given by you for the processing of your personal information;

·     Lodge a complaint with your local data protection authority; and

·     Receive your personal information in a usable electronic format and transmit it to a third party (right to data portability).

If you require more information about how your personal information is used or would like to review, update, delete or request access to your personal information, please contact us at privacyoffice@nuveen.com.  

Nuveen is committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that Nuveen has not been able to assist with your complaint or concern, you may have the right to make a complaint to your local data protection authority.

Contact Us

If you have questions or concerns regarding the way in which your personal information has been collected, used or disclosed, please contact us at privacyoffice@nuveen.com or please contact the person you have been in touch with regarding your employment.

Changes to this Privacy Notice

This Privacy Statement may be updated periodically to reflect changes in Nuveen’s personal information practices or applicable laws. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, Nuveen will give you sufficient notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).