Assurance IQ, LLC Employee and Non-Employee Personal Information Protection Notice

Introduction

As an Assurance IQ (“Assurance”) employee, contractor, consultant, or temporary worker, you are required and agree to protect the Personal Information that you may have access to in the course of your employment. This may include the Personal Information of your fellow employees, Assurance’s customers, and any other Personal Information that Assurance IQ processes. You further agree to follow Applicable Laws and Assurance’s policies, standards and procedures when handling any Personal Information and to access or use any Personal Information only to the extent that it is necessary for your work with Assurance. You understand that these obligations continue to exist after termination of your relationship with Assurance.

Scope

Assurance IQ, LLC (“Assurance IQ,” “we,”, “our,” or “us”) is a subsidiary of Prudential Financial, Inc. (“Prudential”). We are committed to protecting your Personal Information. The purpose of this Privacy Notice (the “Notice”) is to inform you about how Assurance IQ may collect, use, share and disclose Personal Information collected as a result of your employment or other relationship with us and why.

Collection of Employee Personal Information

In the course of your employment with Assurance, we may have collected or will collect information about you and your working relationship with us, or about your spouse, domestic/civil partner, or dependents (“Dependents”). We refer to such information as “Personal Information.”

For more specific information regarding what Personal Information about you we may collect, use, share, and disclose – as well as the purposes for which it may be collected, used, shared and disclosed – please see the end of this Notice. Your local office or team may provide additional information in local employee handbooks, work rules, office manuals and notices.

We receive Personal Information from you as well as from other sources. Other sources include, but are not limited to:

  • Colleagues / Other employees
  • Managers
  • References you provide in relation to your job application
  • Companies offering employment-related services (e.g., recruiting agencies, headhunters, etc.)
  • Educational institutions and membership or certification organizations
  • Clients
  • Occupational Health providers
  • Background check providers

Use of Employee Personal Information

We collect and process information about you for a variety of reasons. These include but are not limited to:

  • Managing Workforce
  • Workforce Analytics
  • Communications & Emergencies
  • Business Operations
  • Compliance & Managing Legal Risk
  • Monitoring Use of Technology
  • Marketing Products & Services

For more details regarding the purposes for which we process Personal Information, see the end of this Notice. Where none of these reasons apply, your decision to provide Personal Information to us is voluntary.

All personnel within Assurance IQ will generally have access to business contact information such as name, employee ID, position, business unit, telephone number, postal address, email address and supervisor or manager name.

Share or Disclosure of Employee Personal Information

Assurance IQ may disclose Personal Information to personnel, departments, and affiliated companies in other locations (including Prudential) to fulfill the purposes described at the end of this Notice.

We may transfer your Personal Information to countries located outside of your home jurisdiction, where the information protection standards may differ. For more information on transfers, please see the end of this Notice.

From time to time, Assurance IQ may need to make Personal Information available to third parties. See the end of this Notice for a list of the categories of third parties. Some of the third parties will be located outside of your home jurisdiction, including in the United States and elsewhere.

Security

We will take appropriate measures to protect Personal Information. These measures will be consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Information.

Access to Personal Information is limited to those who have a need to know the information for the purposes, as described at the end of this Notice, and may include your managers and their designees, personnel in Human Resources (HR), Information Technology (IT), Information Security, Compliance, Legal, Privacy, Facilities/Physical Security, Business Continuity, Finance and Accounting and Internal Audit.

Data Integrity and Retention

We will take reasonable steps to ensure that the Personal Information processed is reasonable for its intended use and is accurate and complete for carrying out the purposes described in this Notice.

We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by law.

Access and Correction Requests, and Complaints

For Employees

If you have questions or concerns about how Assurance IQ processes Personal Information, please contact your Human Resources Business Partner. You may request access to, correction, or deletion of your Personal Information by contacting AskHR@assurance.com or submitting a request through Employee Support Center. We will respond to your request consistent with applicable law. Please note, however, that certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations.

For Non-Employees

If you have questions or concerns about how Assurance IQ processes Personal Information, please contact AskHR@assurance.com or privacy@assurance.com. You may request access to, correction, or deletion of your Personal Information by contacting AskHR@assurance.com or submitting a request through Business Relationship Request Form. We will respond to your request consistent with applicable law. Please note, however, that certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations.

Employee’s Obligations

Please keep Personal Information up-to-date and inform us of any significant changes to Personal Information. You agree to inform your Dependents (whose Personal Information you provide to us) about the content of this Notice, and you agree to obtain their consent (provided they are legally competent to give consent) for the use (including transfer and disclosure) of that Personal Information by us as set out in this Notice. You further agree to follow applicable law and our policies, standards and procedures that are brought to your attention when handling any Personal Information to which you have access in the course of your relationship with us. In particular, you will not access or use any Personal Information for any purpose other than in connection with and to the extent necessary for your work with us. You understand that these obligations continue to exist after termination of your relationship with Assurance.

Changes to this Notice

We reserve the right to amend this Notice at any time in order to address future developments of Assurance IQ, or changes in industry and legal trends. We will post the revised Notice on Assurance IQ’s HR Portal.

You can determine when the Notice was revised by referring to the “Last Revised” legend on the top of this Notice. Any changes will become effective upon the date posted.

Questions

If you have any questions about this Notice, please contact privacy@assurance.com. If you have other employment related questions or concerns, please contact your Human Resources Business Partner.


Types Of Information We May Collect, Use, Share and Disclose:

  • Personal Details: Name, employee identification number, work and home contact details (email, phone numbers (including mobile), fax numbers, physical address) language(s) spoken, gender, age, date of birth, biometric data, national identification number, social security number, marital/civil partnership status, spouse or domestic partners, dependents, disability status, emergency contact information, next of kin, beneficiaries, compliance forms (broker exemption, government relationship disclosure, outside business activity disclosure, personal securities holding report, conflict of interest and double employment disclosures), nationality, passport information, identity verification documents (e.g. Utility bills, Driver’s license), company event videos, photographs and CCTV images, and personal financial records, including securities account numbers and trading activity.
  • Documentation Required under Immigration Laws: Citizenship, visa data, details of residency or work permit, passport number, gender, date of birth, name, home address, nationality, next of kin details.
  • Compensation and Payroll: Base salary, incentive compensation, bonus, employee benefits and allowances, long term compensation awards, total compensation, pay period, compensation rate, benefit plan enrollments and entitlements, benefit election statements, beneficiary support documents, compensation type, stock option awards and grants; restricted stock share awards and grants, performance unit awards and grants; shares purchased in the employee stock purchase plan, other company equity grants, currency, pay frequency, compensation history, effective date of current compensation, salary reviews, banking details, bank account number, tax identification number and related information, tax location code, tax planning information for expats, working time records (including vacation and other absence records, leave status, hours worked and department standard hours), payroll identification number and payroll, and overtime eligibility and overtime pay.
  • Position: Description of current position, job title, job status, management category, business unit, job code, salary plan, pay grade or level, job function(s) and subfunction(s), company name and code, legal employer entity, branch/unit/department name and code, location, employment status and type, full- time/part-time, terms of employment, employment contract, severance plan and eligibility data, internal job and work history, job responsibilities, hire/re-hire and termination date(s) and reason, service date, promotion dates, employee class length of service, retirement eligibility, promotions, performance improvement plans, disciplinary records, date of transfers, reporting manager(s) information, subordinate employee information.
  • Talent Management and Operational Planning Information: Details contained in letters of application and resume/CV (previous employment background, education history, professional qualifications, language and other relevant skills, certifications, certification expiration dates), internal and external employment history, information necessary to complete a background check, details on performance ratings (and ratings dates), probation form, training and development programs planned, attended and completed, web-based training programs, performance and development reviews, ratings and comments, including dates for the foregoing, willingness to relocate, space utilization sensor information, driver’s license information, opinions expressed about you, and information used to populate employee biographies, including likes, dislikes and interests.
  • Management Records: Details of any shares of common stock or directorships.
  • Business Related Travel and Expenses: Travel and transaction details for business related travel, including travel reservation numbers if issued; expense reimbursement information, credit card numbers and transactions; travel information (airline, flight number, hotel name dates of travel), and Passport details.
  • Investigation Records: Name, position, and contact information of associates making a complaint, the individuals who are the subject of the complaint or an investigation, and the persons investigating the complaint, the facts collected, the results of the investigation.
  • System and Application Access Data: Information required to access company systems and applications, email account, instant messaging account, mainframe ID, previous employee ID, system username and passwords, system multifactor authentication details, employee status reason, branch state, country code, previous company details, previous branch details, and previous department details, and electronic content produced by you using company systems.
  • Use of Systems: Employee incoming and outgoing emails; employee internet history and sites accessed; incoming and outgoing text messages and social media postings, call recording and screen capture (i.e., for call center support and business meetings).
  • Use of Assurance IQ and Prudential Websites: Your use of Assurance’s and Prudential’s publicly facing websites or Assurance IQ and Prudential social media may result in the collection of Personal Information. To the extent applicable, the collection and use of Personal Information from an Assurance IQ or Prudential publicly facing website or social media is described in the applicable website’s online privacy statement.
  • Sensitive Information: We may also collect certain types of sensitive information only when permitted by local law, such as health/medical information (including COVID-19 vaccination status and responses to health-related questions asked in connection with pandemic-related screening), sick notes, and occupational health reports), place of birth, trade union membership information, religion, veteran status, LGBTQ+, gender identity, and race or ethnicity. We collect this information for specific purposes, such as health/medical information in order to accommodate a disability or illness and to provide benefits; and diversity-related Personal Information in order to comply with legal obligations and internal policies relating to diversity equity, and inclusion, as well as and anti-discrimination.

The Purposes for Which We May Collect, Use, Transfer and Disclose Personal Information:

    We collect, use, transfer and disclose Personal Information for one or more of the following reasons:

  • Managing Workforce: Managing work activities and personnel generally, including recruitment, appraisals, performance management, promotions and succession planning, rehiring, administering salary, and compensation administration and reviews, wages, bonuses, and other awards, equity plan (e.g., stock options, stock grants, and employee stock purchase plan) participation and administration, processing accounts payable and receivable for employees healthcare benefits and accommodation requests, pensions and savings plans, training, leave, managing disability and sickness leave, promotions, transfers, secondments, pension plans, honoring other contractual benefits, providing employment references, loans, performing workforce analysis and planning, performing employee surveys, performing background checks, managing disciplinary matters, grievances and terminations, reviewing employment decisions, making business travel arrangements, managing business expenses and reimbursements, planning and monitoring of training requirements and career development activities and skills, employment grants, and creating and maintaining one or more internal employee directories. Space utilization desk monitoring is used for space management only. We will engage in these activities to manage our employment relationship with you, based on our legitimate interests and/or to comply with a legal obligation.
  • Workforce Analytics: We use workforce analytics for succession planning, workforce management, and data security. For instance, we use workforce analytics to assist in planning succession and to ensure business continuity, to design employee retention programs and diversity initiatives, to offer training opportunities and to identify patterns in the use of technology systems to safeguard information entrusted to us as well as to protect Assurance’s people and property. We will engage in these activities based on our legitimate interests.
  • Communications and Emergencies: Facilitating communication with you and your designated emergency contacts, communication across the business (AIQLive, All Hands, CTW, Corporate Social Responsibility, internal awards, employee programs, training), ensuring business continuity, property management (e.g. laptops and mobile phones), providing references, protecting the health and safety of associates and others, safeguarding IT infrastructure, office equipment and other property. We will engage in these activities to manage our employment relationship with you, based on our legitimate interests and/or to comply with a legal obligation.
  • Business Operations: Operating and managing the IT and communications systems (including collection, storage and review), managing product and service development, improving products and services, managing company assets, allocating company assets and human resources, strategic planning, project management, business continuity, compilation of audit trails and other reporting tools, maintaining records relating to business activities, budgeting, financial management and reporting, communications, managing mergers, acquisitions, sales, re-organizations or disposals and integration with purchaser. Passport information and identity verification documents (e.g., utility bills, driver’s license) are required for bank signatory authorizations. Call recording and screen captures for coaching/training/escalation in support of Assurance IQ business purposes. We will engage in these activities based on our legitimate interests and/or to comply with a legal obligation.
  • Compliance and Managing Legal Risk: Complying with legal and other requirements, such as income tax and national insurance deductions, record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, corporate compliance, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations, including employee reporting of allegations of wrongdoing, policy violations, fraud, or financial reporting concerns, and complying with internal policies and procedures. We will engage in these activities to manage our employment relationship with you, based on our legitimate interests and/or to comply with a legal obligation.
  • Monitoring Use of Technology: Reviewing employee internet access and monitoring of internet history and sites accessed; monitoring use of information resources, including applications, communications tools, and connected devices; monitoring incoming and ongoing messages and social media postings. We will engage in these activities based on our legitimate interests and/or to comply with a legal obligation. We monitor usage of technologies and contents of communications to protect the company and to detect, respond to, and prevent crime, fraud, other illegal activities, and violations of our policies and procedures.
  • Marketing Products and Services: From time to time, Assurance IQ may use your Personal Information to send you marketing communications on Assurance IQ products and services or products and services offered by third parties that Assurance IQ or its Affiliates are licensed to sell. To opt-out of such Marketing, please contact AskHR@assurance.com.

The Categories of Third Parties with Whom Assurance IQ May Share Personal Information

  • Public and Government Authorities: We may be obligated to disclose your Personal Information to a law enforcement agency; by a court order; under the discovery process in litigation, investigations, and prosecutions; or in response to requests from, or if required by, government agencies and/or regulators and/or tax advisers, legal advisers, investigators, accountants, financial advisers and/or any other person having appropriate legal authority or justification for receipt of the same. Assurance IQ may also disclose Personal Information voluntarily to cooperate with law enforcement agencies or any of the above bodies, including but not limited to matters of national security, criminal charges, civil claims or as may otherwise be permitted by applicable law.
  • Third Party Service Providers: Companies that provide products and services to Assurance IQ or its Employees such as consultants, vendors, outsourcing partners, payroll, pension scheme, benefits providers; human resources services, performance management, training, expense management, IT systems suppliers and support; third parties assisting with equity compensation programs, credit card companies, medical or health practitioners, trade bodies and associations, travel service companies, financial service companies, accountants, lawyers, insurers, bankers, and other service providers. In some cases, Assurance IQ provides your Personal Information; in other cases, the consultants, vendors, and service providers may collect your Personal Information directly from you and if permitted to do so, may share that Personal Information with Assurance IQ.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, joint venture, or transition of service to another provider, your Personal Information may be shared or disclosed as part of such a transaction.
  • Prudential Companies: We may share your Personal Information with our parent company, Prudential, and/or any of its Affiliates for processing described in this Notice.