EY Privacy Notice - Pymetrics

1. Introduction

This EY 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 (including the associated third-party integrated systems referenced below).  For purposes of clarity, this EY 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 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 EY Global Services Limited. EY Global Services Limited licenses the Tool from Pymetrics, Inc. (1250 Broadway, 8th Floor, New York, NY 10001).

The personal data you provide in the Tool is shared by EY Global Services Limited 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 (North East Region, US).

3. Why do we need your information?

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:

Personal Data is:

Provided by a feed from other EY Systems (GRMS – Taleo):

  • 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.

Information such as ethnicity may be collected. The ethnicity questions are as part of a questionnaire asking about the candidate’s demographics. This is anonymized data and can be removed by EY should we wish to.

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.
Role Location Purpose for which access is required Level of access rights (e.g. read-only, edit, delete)

EY Recruiters

Global

Assess candidates and obtain information on the prioritisation/scoring of candidates and any potential follow ups.

Read, edit, delete

Access rights restricted by country.

Pymetrics users

USA, Singapore, UK and Australia

Maintenance and support

Read-only

IBM

Canada, China, Czech Republic, Hungary, India, Malaysia, Mexico, Oceania, Philippines, Poland, UK and US

To provide system support

Read/Write

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 www.ey.com/ourlocations). 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. The transfers of personal data from the Tool to IBM, is governed by an agreement between EY and the service provider that includes standard data protection clauses adopted by the European Commission.

7. Data retention

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 is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, EY has technical and organizational measures to safeguard and secure your personal data. All EY personnel and third parties EY engages to process your personal data are obliged to respect your data’s confidentiality.

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.  

You are legally entitled to request details of EY’s personal data about you.

To confirm whether your personal data is processed in the Tool or to access your personal data in the Tool, contact your usual EY representative or email your request to data protection team.

10. Rectification, erasure, restriction of processing or data portability

You can confirm your personal data is accurate and current. You can request rectification, erasure, restriction of processing or a readily portable copy of your personal data by contacting your usual EY representative or by sending 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 have the right to complain to your country’s data protection authority. You can also refer the matter to a court of competent jurisdiction.  

12. Contact us

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