This Policy lets you know how the DTCC Corporation and its affiliates and subsidiaries ("DTCC" or "we") collect and use your personal information in connection with DTCC's recruiting efforts, both online and offline. DTCC and its subsidiaries are listed in the “Businesses & Subsidiaries” page of this Site.
Collecting Personal Information. We may collect personal information directly from you. We ask for certain data, including educational and employment background, contact information and preferences, information regarding previous financial industry sanctions, job qualifications, and jobs for which you would like to submit an application. This information is necessary for us to process your application. If you do not provide it we may not be able to process your application and may not be able to offer you a position. You also may choose to provide DTCC additional information, such as your CV, resume, or transcripts, employment references and related information, and compensation requests.
In addition, DTCC may collect information from third parties, for example, in connection with initial and ongoing background, employment, social media checks and/or an employment reference. This information consists of: clearance of criminal history, confirmation of educational history, historical employment dates and salary confirmation, and information from social media sites (e.g. posts, likes). Information relevant to these background checks may be collected from publicly-available sources.
Sensitive Personal Information. DTCC does not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. If you have a disability and would like DTCC to consider any accommodation, you may provide that information during the recruiting process. In some countries we ask for information such as race or ethnicity for the purpose of monitoring equal opportunity; however, we do not require applicants to provide race or ethnicity information, and if you provide this information it will not be viewable in the hiring or selection process.
To the extent information you provide contains details of your racial or ethnic origin, political opinions or beliefs, religious beliefs, membership in a trade union or political party, physical or mental health or condition, sexual orientation, commission or alleged commission of a criminal offense or related proceedings, job evaluations or educational records, you expressly authorize DTCC to handle such details as specified in this Policy, and acknowledge that not all of this information is available to our recruiters or hiring managers.
Employee Trade Monitoring. As an officer or persons in select roles within DTCC, you will be required to adhere to DTCC’s efforts to prevent insider trading on material nonpublic information (MNPI). You must disclose the existence of any household investment accounts in which you can transact in individual securities and must adhere to any relevant trading restrictions based on your specific access to MNPI.
Voluntary Disclosure. Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide to DTCC. For applicants outside of the United States, if you decide not to provide information, it may affect our ability to consider you for employment.
Using Personal Information. The information may be used to communicate with you, to manage DTCC's recruiting and hiring processes, for compliance with corporate governance, and for legal and regulatory requirements. We process your personal information for all these purposes to meet our legitimate interests in processing your application and finding the best candidate for a position. If you are hired, the information may be used in connection with your employment and for managing our organization. We use your information for these purposes as it is necessary for us to comply with our obligations to you as set out in your employment contract, and as it is in our legitimate interests to manage our business efficiently and keep our records accurate and up to date. DTCC employees may be subject to ongoing background and social media checks, monitoring of their personal financial transactions, industry related sanctions, or other screenings as required by law or regulatory requirements, and we perform these checks only where necessary to meet our legal or regulatory obligations.
Data Recipients and Sharing with Third Parties. DTCC may share your personal information internally and with service providers and other third parties as necessary in connection with recruiting, background and social media checks, employment, corporate governance, acquisitions and legal or regulatory requirements, including our primary human resources service providers, Taleo, HCM-Cloud and HireRight. DTCC requires that its service providers and such other third parties keep your personal information confidential and that they only use the personal information in furtherance of the specific purpose for which it was disclosed. DTCC and its service providers may use your personal information in an anonymized format (in a form in which your identity cannot be determined) for other purposes not specified above, including in the development and testing of products and services.
Security and Confidentiality. Except as otherwise stated in this Policy or as required for legal or regulatory purposes, DTCC treats your personal information as confidential and will not disclose it to third parties without your consent. DTCC maintains, and requires its service providers to maintain, reasonable administrative, physical, and technical controls designed to protect the confidentiality and security of your personal information. DTCC employees who may have access to personal information are required to keep that information confidential.
Retention and Access. DTCC may retain your information throughout the course of your application. If your application is unsuccessful, DTCC may retain your personal information for a period after your application is closed, in which DTCC may consider you for other job opportunities. DTCC may also retain your personal information in compliance with our data retention policies, which set retention periods based on legal requirements and regulators' expectations, or other in order to comply with applicable regulatory requirements. To the extent permitted or required by law, DTCC may delete data at any time and you should retain a copy of any information you submit to us.
You may access, correct and delete personal information you have submitted online. You may submit requests for access, correction and deletion by sending an email to firstname.lastname@example.org or to the DTCC privacy office at email@example.com. You also have the right, in certain circumstances, to object to our uses of your personal information, to restrict our uses of your personal information, and to be given a copy of your personal information in a commonly-used format to be provided, at your discretion, to another company. If you have given your consent to any uses of your personal information, you can withdraw that consent at any time. If you wish to exercise any of these rights, please contact us using either of these email addresses. If you have any concerns about our uses of your personal information, please contact us using these email addresses and we hope to be able to resolve these concerns. For applicants in the EU, you also have the right to complain to the Information Commissioner's Office using their website www.ico.org.uk.
Your Responsibilities. You are responsible for the information you provide or make available to DTCC, and you must ensure it is honest, truthful, accurate and not misleading in any way. If you provide any information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for DTCC to collect and use that information for the purposes described in this Policy.
Cross Border Transfers. DTCC is a global corporation and has developed global data practices designed to assure your personal information is appropriately protected. Personal information may be transferred, accessed and stored in the United States and globally as may be necessary for the uses and disclosures described above, and such transfer or storage may be subject to different data protection laws than those in your home country.
The DTCC affiliates have entered into an Intra-Company Data Processing and Transfer Agreement within the DTCC Group which allows for the processing of your personal information and which also incorporates the European Union Model Clauses requirement for transfers of personal information. If you would like to see a copy of this agreement, please contact us at recruiters@DTCC.com.
General. DTCC may update this Policy from time to time, and the current version will be available on DTCC’s job search page. If you have any questions or concerns about this Policy or its application, or if you believe your personal information has been used in a way that is not consistent with this, please contact us at recruiters@DTCC.com .
PRE-EMPLOYMENT BACKGROUND CHECK PROCESS
In accordance with DTCC policies and regulatory requirements, background checks are required for individuals being considered for employment, and are also periodically conducted for our employees. If you are selected for a position and requested to complete a background check, please review the information below. A criminal record verification and a global sanction screening are also required for all applicants at any location.
DTCC's background check vendor is HireRight, a leading provider of on-demand background screening services. When DTCC initiates the process, HireRight will e-mail you a link to its online application, along with unique login and password information. You should promptly use that information to login and complete (in its entirety) the online form.
DTCC Human Resources or our Global Security team will assess the results of the information that HireRight provides and will check for inconsistencies between the information you provided during the screening process and the information listed on the resume you supplied to DTCC during the application process.
It is your responsibility to verify the accuracy of the information you submit to DTCC and HireRight. Providing inaccurate information about your education and/or employment history which cannot be substantiated, either on your resume, the DTCC online job application, or the HireRight application, may disqualify you from further consideration for employment with DTCC.
If you have any additional questions about this process, please send an e-mail to recruiters@DTCC.com. Applicants from India may send inquiries to the above address or to firstname.lastname@example.org.
Effective Date: May 2018