Privacy Notice – Pymetrics, Inc.

1. Introduction

This Privacy Notice is intended to describe the practices EY follows in relation to the Pymetrics, Inc (“Tool”) with respect to the privacy of all individuals whose personal data is processed and stored in the Tool. This Privacy Notice should be read together with the ey.com Privacy Statement, and in case of any conflict with the ey.com Privacy Statement, the terms of this Privacy Notice will prevail.  Please read this Privacy Notice carefully.

For purposes of clarity, this Privacy Notice is solely entered into between you and EY, and is not intended to replace and/or supersede the separate privacy policy, terms and/or conditions entered into between you and Pymetrics, Inc. in connection with your usage of and interaction with the Tool, including without limitation, the privacy policy located at https://www.pymetrics.ai/privacy-policy, which shall remain in full force and effect.

2. Who manages the Tool?

“EY” refers to one or more of the member firms of Ernst & Young Global Limited (“EYG”), each of which is a separate legal entity and can act as a data controller in its own right. The entity that is acting as data controller by providing this Tool on which your personal data will be processed and stored is:

• For the personal data of EY personnel: The data controller is the EY entity which employs you.
• For the personal data of third-party personnel (including EY clients): The data controller is the EY local member firm with which the third party has a relationship.

You can find a list of local EY member firms and affiliates on ey.com Privacy Statement.

The personal data you provide in the Tool is shared by the above data controller with one or more member firms of EYG (see “Who can access your information” section below).

The Tool is hosted on servers in an Amazon Web Services (“AWS”) data centre (Northeast Region, US).

3. How does the Tool process personal data?

The Tool assess competencies and aptitude of candidates using a digital psychometric assessment based on game technology.

Your personal data processed in the Tool is used as follows:

For EY Users, gameplay data is used to analyze what are the key characteristics and traits that are common between those employees that make them successful in the role. This data is then used to create a data model to assess candidates against.

Candidates who apply to the same role will take the same assessment and be assessed against the model. Fit for role is determined based on percentile match against model.

Optional Sensitive Personal Data relating to Candidates and EY Users are used to ensure that the models are unbiased against gender/ethnicity.

Candidate data: name, email, requisition ID, and assessment ID are used to associate gameplay with the correct candidate.

EY relies on the following basis to legitimize the processing of your personal data in the Tool: 

• The data subject has given consent to the processing of their personal data for one or more specific purposes.
• Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. The specific legitimate interest(s) pursued are as follows: Human Resource management, including performance reviews and recruitment.

The provision of your personal data to EY is optional. However, if you do not provide all or part of your personal data, we may be unable to carry out the purposes for processing.

4. What type of personal data is processed in the Tool?

The Tool processes these personal data categories: 

EY Personnel:

• EY Recruiters
  • Full name
  • Email address
  • Audit logs relating to user login and activity.
• EY Users (part of norm group)
  • Assessment data
  • Audit logs relating to user login and activity.

Other:

• Candidates
  • Full name
  • Email address
  • Assessment data
  • Requisition ID
  • Assessment ID
  • IP addresses
  • Location data
  • Audit logs relating to user login and activity

This data is sourced from a feed from other EY systems known as GRMS, Yello and SuccessFactors (SF) Recruitment; or directly from yourselves:

• EY Recruiters
  • Full name
  • Email address
  • Provided by candidates applying for EY vacancies.
    

5. Sensitive Personal Data

Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.

EY does not intentionally collect any sensitive personal data from you via the Tool. The Tool’s intention is not to process such information.

6. Who can access your information?

Your personal data is accessed in the Tool by the following persons/teams:

EY:

• EY Recruiters: EY Recruiters will have access to candidate match results in the form of Highly Recommend, Recommend, Do Not Recommend, for their respective countries. EY Recruiters can also gain access to a report for each candidate in their respective countries to obtain more details on their specific traits.

Other:

• Vendor Personnel: Pymetrics personnel in the Customer Success, Client Deployment, IO, and Data Science teams will have access to data to provide support services.

Location:

• EY access locations will be dependent on where EY roll outs of the Tool.
• Pymetrics access will primarily be accessed from HQ in NYC, USA. Customer Success and Client Deployment teams may be distributed between offices in Singapore, England, and Australia.

Purpose:

• Pymetrics IO and Data Science teams have Read-Only access incumbent and candidate data to create and validate the models created for customer.
• Pymetrics Customer Success and Client Deployment teams have read-only access to candidate data to validate data flow and support customers.

The access rights detailed above involves transferring personal data in various jurisdictions (including jurisdictions outside the European Union) in which EY operates (EY office locations are listed at https://www.ey.com/en_gl/locations). An overview of EY network entities providing services to external clients is accessible here (via ey.com UK site) (See Section 2 (About EY) - “View a list of EY member firms and affiliates”). EY will process your personal data in the Tool in accordance with applicable law and professional regulations in your jurisdiction. Transfers of personal data within the EY network are governed by  EY’s Binding Corporate Rules. 

We transfer or disclose the personal data we collect to third-party service providers (and their subsidiaries and affiliates) who are engaged by us to support our internal ancillary processes. For example, we engage service providers to provide, run and support our IT infrastructure (such as identity management, hosting, data analysis, back-up, security and cloud storage services) and for the storage and secure disposal of our hard copy files. It is our policy to only use third-party service providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and that comply with any applicable legal requirements for transferring personal data outside the jurisdiction in which it was originally collected.

To the extent that personal data has been rendered anonymous in such a way that you or your device are no longer reasonably identifiable, such information will be treated as non-personal data and the terms of this Privacy Notice will not apply.

For data collected in the European Economic Area (EEA) or which relates to individuals in the EEA, EY requires an appropriate transfer mechanism as necessary to comply with applicable law. The transfer of personal data from the Tool to IBM is governed by an agreement between EY and the IBM that includes standard data protection clauses adopted by the European Commission.

7. Data retention

Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “How does the Tool process personal data?” Retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.

In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights and for archiving and historical purposes, we need to retain information for significant periods of time.

The policies and/or procedures for the retention of personal data in the Tool are:

Data retention is in accordance with EY Records Retention Global Policy and the applicable Global, Area, Region or Country Retention Schedule.

Data retention can be adjusted as per the requirements of the local EY office. EY will define data retention according to local laws.

Your personal data will be retained in compliance with privacy laws and regulations. After the end of the data retention period, your personal data will be deleted.

8. Security

EY protects the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure. Additional information regarding our approach to data protection and information security is available in our protecting your data 2018 (pdf) brochure.

9. Controlling your personal data

EY will not transfer your personal data to third parties (other than any external parties referred to in section 6 above) unless we have your permission or are required by law to do so.

10. Your rights in relation to your personal data

Depending on the applicable jurisdiction, you may have certain rights in relation to your personal data, including:

• To request details of the personal data EY processes about you and to access the personal data that EY processes about you
• To have your personal data corrected, for example, if it is incomplete or incorrect
• To restrict or object to the processing of personal data or request the erasure of your personal data
• To receive a copy of the personal data which you have provided to EY in a structured, commonly used and machine-readable format which you can re-use for your own purposes (known as “data portability”)
• Where you have provided consent to the processing of your personal data, the right to withdraw your consent.
• The right to complain to a data protection authority (see section “Complaints”)

If you have any questions about how EY processes your personal data or your rights related to your personal data, please send an e-mail to  data protection team.

11. Complaints

If you are concerned about an alleged breach of privacy law or any other regulation, contact EY’s Global Privacy Leader, Office of the General Counsel, 6 More London Place, London, SE1 2DA,United Kingdom or via email at data protection team or via your usual EY representative. An EY Privacy Leader will investigate your complaint and provide information about how it will be handled and resolved.

If you are not satisfied with how EY resolved your complaint, you may have the right to complain to your country’s data protection authority. You may also have the right to refer the matter to a court of competent jurisdiction. 

Certain EY member firms in countries outside the European Union (EU) and the UK have appointed representatives in the EU and the UK respectively to act on their behalf if, and when, they undertake data processing activities to which the EU General Data Protection Regulation (GDPR) and/or the UK General Data Protection Regulation (UK GDPR) applies. Further information and the contact details of these representatives are available below:   

EU data protection representative

UK Data protection representative

12. Contact us

If you have additional questions or concerns, contact your usual EY representative or email to data protection team.