Privacy Notice

Last updated: 22 January 2025

 

Privacy Notice – EY Alumni Portal Re-platform PeoplePath
 

1. Introduction

This Privacy Notice is intended to describe the practices EY follows in relation to the EY Alumni Portal Re-platform PeoplePath (“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. 

 

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 determine the purposes and means for data processing in its own right (i.e., act as a data controller or in a similar capacity).

The entity that is acting as data controller (or similar capacity) 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 the ey.com Privacy Statement.  

The personal data in the Tool is shared by the above data controller with one or more member firms of EYG (see “Who can access your personal data” section 6 below).

The Tool is hosted Externally by the vendor or its third-party hosting provider. The Primary server is AWS and is hosted in Frankfurt, Germany.

 

3. How does the Tool process personal data?

The Tool is to serve as a platform for alumni management and engagement. The tool aims to improve alumni engagement by providing enhanced functionality, seamless data integration, and streamlined communications. The platform supports collaborative efforts among stakeholders from BMC, Technology, HR, and local alumni teams to ensure effective planning, implementation, and a smooth transition to better support alumni interactions.

 

Your data processed in the Tool is used as follows:

Data is processed for internal reporting, and to facilitate communication with registered members only.

Data is processed for registration purposes and granting access to the users via Azure Active Directory.

Data is also processed for validating the users as EY current or former employees.

 

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

Processing of your personal data 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) are: learning and events registration and management and providing a platform for EY Alumni interaction and engagement.

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you based on the above legitimate interest(s).

We process your personal data based on your consent. 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. You have the right to withdraw your consent at any time.

 

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

The Tool processes these personal data categories:

  • GUI
  • GPN
  • First Name
  • Middle (Initial)
  • Last Name
  • Hire Date
  • Mobile
  • Primary Email
  • Preferred First Name
  • Last Name at EY
  • EY Employment Status
  • Start Year
  • End Year
  • Intern to Permanent Date
  • End Date
  • Rehire Date
  • Partner Departure Status
  • EY Retiree
  • Management Region
  • Last EY Office
  • Prior EY Office
  • Rank at Departure
  • Rant at Departure Code
  • EY Grade
  • Service Line
  • Sub-Service Line
  • Specialty
  • Specialty Description
  • Start Office
  • Start Rank
  • Prior Employer
  • Prior Employer Ending Title
  • Preferred Language
  • Global Industry
  • Partner Admission Date
  • Client Serving
  • Counselor (First Name; Last Name)
  • Country
  • Role
  • Population
  • Reason for Leaving
  • Delete Flag
  • Alumni Program Eligibility
  • Gender
  • Current Rank
  • Location Code
  • Country Code
  • Management Area
  • Legal Entity Code
  • Legal Entity Description
  • Department ID
  • Date of Death
  • Profile Picture
  • Photos of the EY Alumni Network Events
  • Videos/Sound Bites

 

This data is sourced from:

  • Provided directly by EY Partners, Employees or Contractors
  • A feed from other EY systems (FITServ; Active Directory)

 

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 personal data?

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

USER GROUP

 

LOCATION

 

PURPOSE

 

ACCESS

 

AMOUNT

 

Global system administrator

All geographies

can access all functionalities in all geographies

Everything described below across all geographies.

3-5

 Alumni country leader

US, some countries in EMEA and APAC (but only in their respective locations)

 Has access to all the functionality within a local geography

- Add, edit, delete, search and view alumni data- Search and view administrators- Search, view and delete company data- Create e-mails, build contact lists, view reports, manage templates and set notifications- Manage events, FAQs and articles- Manage job postings- Manage reports- Manage tags

20-30

Alumni manager

US, some countries in EMEA and APAC (but only in their respective locations)

Has limited access to the functionality within a local geography:

-Add, edit, search and view alumni data- Search company data- Create e-mails, build contact lists, view reports- Manage events, view FAQs and create, view and edit articles, but not delete them- Manage reports

20-30

Alumni support

US, some countries in EMEA and APAC (but only in their respective locations)

Can only view information, not add, edit or delete any data from the system

Can only view information, not add, edit or delete any data from the system

Very limited user numbers

 

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 (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 PeoplePath is governed by a contract containing EY Data Transfer Agreement between EY and PeoplePath.

 

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:

The total retention period is defined and will be implemented in accordance with the EY Records Retention Global Policy and the relevant Country Retention Schedule (CRS).

These are required records and have defined retention requirements.

Log Data will be retained for 180 days

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 ey-gl-protecting-your-data-09-2024.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 global.data.protection@ey.com.

 

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, 1 More London Place, London, SE1 2AF, United Kingdom or via email at global.data.protection@ey.com 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 | EY

EU data protection representative | EY - Global

 

12. Contact us

If you have additional questions or concerns, contact your usual EY representative or email global.data.protection@ey.com.