CAREERS SITE PRIVACY NOTICE

Last Updated: January 2024

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. 

The provision of personal information as described in this Notice is partly a legal requirement and partly a requirement necessary to initiate a possible employment relationship with you. In general, you are required to provide the personal information, except in limited cases where we indicate that the provision of certain information is voluntary. Failure to provide personal information may prevent PFI from carrying out the possible employment relationship with you. 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. We use your personal information listed above for the following business purposes associated with recruitment and pre-employment activities:

  • To process your application and assess your capabilities and qualifications for a job; 
  • To provide you with information about job and internship opportunities and the application process; 
  • To conduct reference checks; 
  • To provide any services available to you on the Careers Site and to monitor the operation and performance of the site and services; 
  • To respond to your inquiries and communicate with you about your application; 
  • To comply with or monitor compliance with any applicable law or regulation; 
  • To conduct background checks if we offer you a position; 
  • To notify you about changes to the Careers Site or the services; 
  • To improve the quality of the Careers Site, the services, and our training; 
  • To manage complaints, feedback, and queries; 
  • To provide an opportunity to self-identify for diversity purposes in accordance with applicable federal, state, and international reporting requirements; 
  • To protect against fraud or other illegal activity or for risk management purposes; 
  • To respond to inquiries or requests from government or public authorities; 
  • To comply with any legal or regulatory obligations (including in connection with a court order); 
  • To enforce or apply the agreements concerning you (including agreements between you and us) or our policies; 
  • To protect the legal rights, privacy, or safety of PFI or its employees, agents and contractors; 
  • To protect the safety and security of visitors to the Careers Site; to conduct and manage our business and protect those that visit our websites and other properties. 
  • To improve and ensure the security of the site and services; and
  • To conduct and manage our business and protect those that visit our websites and other properties.

We only use your sensitive personal information to administer your possible employment (e.g., for workplace accommodations), to maintain sickness/medical leave information and records, for health and wellness purposes to comply with applicable health regulations, for equal opportunities monitoring, and for any other purposes that are necessary to allow us to comply with our statutory obligations.

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.

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.

LEGAL BASIS FOR PROCESING PERSONAL INFORMATION

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, which may be based on where you are located. PFI relies on the legal justifications below to collect, use, transfer and disclose (“Process”) personal information you submit through the Careers Site:

  • When Pursuing Legitimate Interests.  We process personal information for our legitimate interests in conducting and managing our business as a global organization; for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within Company and across the organization; and (3) to prevent fraud;
  • With Your Consent (or express/explicit consent for sensitive personal information). As permitted by applicable law and where appropriate provided that such consent is voluntary, you have the right to withdraw your consent at any time, and your consent meets applicable legal requirements of such consent;
  • When We Have Legal Obligations. We will process your personal information when we have a legal obligation to do so (e.g., responding to a legal process or enforceable government request) or for our own compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws;
  • To Perform a Contract With You. We will process your personal information when processing is necessary for the execution or performance of a contract with you.  For the purposes of this Notice, such contract is a contract of employment; and
  • Protection of the Vital Interests of you or another individual.

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.

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).

Personal Information may be transferred 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). In such circumstances, we will take appropriate steps to provide an adequate level of data protection within the meaning of applicable data protection law, including by implementing the EU Standard Contractual Clauses, the UK Addendum to the EU Standard Contractual Clauses, or any other appropriate safeguard based on jurisdiction where required. You can request a copy of the appropriate safeguards referenced in this section by contacting us.  

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).

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.

YOUR RIGHTS

You may have specific rights under applicable data protection laws with respect to your personal information in certain circumstances and depending on your jurisdiction, which are described below. 

  • Right of Access - You may have the right to request a copy of the personal information held about you. 
  • Right to Correct/Rectify - You may be entitled to have any inaccurate or incomplete personal information held about you corrected or amended.
  • Right to Erasure/Deletion -  You may have the right to have your personal information erased (also referred to as the right to be forgotten) where, for example, retaining your personal information is no longer necessary in relation to the recruitment and pre-employment purpose for which it was originally collected/processed, or where you have withdrawn consent, subject to there being no overriding legal basis or requirement related to retention for continuing to hold your personal information.
  • Right to be Informed - You may have the right to know what personal information relating to you is held and processed by us. On receipt of a written request from you, we will provide information relating to the type of personal information held, the purposes for which the personal information is held or processed and to whom the information is disclosed. 
  • Right to restrict processing - You are entitled at any time to request in writing to discontinue or ‘block’ the processing of your personal information where, for example, you believe your personal information is not accurate. Your request should clearly state the reason and we will respond to your request within a reasonable timeframe detailing whether we are able to comply with the request or the extent to which we are able to comply. 
  • Right to Object – We are committed to the legitimate privacy interests of all employees and do not use personal information collected and processed in the context of your employment relationship for profiling purposes. If at any point in time you do not believe this to be the case you are entitled to object in writing, clearly stating the reasons for your objection. We will seek to make reasonable accommodations in response to your objection where appropriate and as required. 
  • Rights in Relation to Automated Decision Making - With respect to the collection, processing, and evaluation of personal information, subject to any supplementary notice or later amendment to this notice, we do not apply automated decision-making processes, i.e., significant decisions about you are not made based solely on automated processing of your personal information.
  • Right to Data Portability – We can provide you with your personal information in a structured, commonly used, machine readable form which provides the ability to move, copy or transfer your personal information. 
  • Right of Non-discrimination/Retaliation – We do not discriminate against individuals who exercise any of their rights described in this Notice, nor do we retaliate against individuals who exercise their rights.
  • Right to Anonymization - You may have the right to have unnecessary, excessive, or non-compliant personal information anonymized, blocked, or erased.
  • Right to Withdraw Consent – You may have the right to withdraw consent for the processing of personal information, where applicable.

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 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.

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, color, 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.

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.

Additional Information Regarding the UK and EEA

  • The contact information for our data protection officer (DPO) in Germany is as follows: Jochen Geck VIVACIS Consulting GmbH Horexstraße 1 | ALTER GÜTERBAHNHOF D – 61352 Bad Homburg, Telephone: +49 160 938 492 30, Email: jochen.geck@vivacis.de
  • You may lodge a complaint with an EU/EEA or the UK data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities in the EU/EEA is available at: (http://ec.europa.eu/newsroom/article29/itemdetail.cfm?item_id=612080) and information regarding lodging a complaint with the UK ICO can be found here: (https://ico.org.uk/make-a-complaint).

California Applicants

In addition to this Notice and the contents herein, if you are a California applicant, please refer to the California Resident Statement, available on the Prudential (https://www.prudential.com/links/privacy-center) and PGIM (https://www.pgim.com/terms-use/privacy-center) privacy centers, for more information on our privacy practices, including the categories of personal information we collect, the purposes for that collection, and our retention practices.

Acknowledgment

I acknowledge and agree that I have received a copy of this Notice, and completely read and understand this Notice, its contents, and its requirements.