Privacy Notice – EU | Vanguard Careers

Introduction and Notice Scope

The Vanguard Group (“Vanguard”) is one of the world’s largest and most respected investment management families of companies, with investment funds, offices, and affiliates in North America, Australia, Europe, and Asia. Vanguard’s global headquarters are located in the United States. For information about Vanguard-affiliated companies (“Vanguard Affiliates”) outside the US, please visit here.

Vanguard Careers, http://vanguardjobs.com (the “Site”), is a website owned by Vanguard. At the Site, persons interested in employment with Vanguard may browse and apply for open positions.

This Privacy Notice solely governs the collection, use, disclosure, and transfer of personal information that we collect at the Site and through the job application process; this Privacy Notice does not apply to any other website operated by Vanguard.

By visiting this Site, using the AI chatbot technology (“Virtual Assistant”) or other Site features, applying for an open posting, or otherwise providing information to Vanguard through this Site, you acknowledge the practices described in the Notice. Please also refer to the terms and conditions, which are incorporated herein by reference, for additional information related to your use of this Site.

Information Collection

Vanguard collects information directly from you when you apply for employment or register for our Talent Community. We also collect information about you systematically as you navigate our site and/or use its features.

What personal information do we collect?

Vanguard may collect the following personal information from you:

• Personal information we collect when you apply for employment:  To apply for an
  open position through this Site, you must first create an account on our application processing system. To create an account, you’ll need to provide your email address and create a password. You can complete the account creation process without applying for a position. You may also save and come back to an application after creating an account. The information that we require you to submit as part of your employment application through this Site varies depending on the position and the Vanguard affiliate company to which you are submitting your application. If you would like to apply for an open position through this Site, we may collect the following, where permitted or required by law:
  • your full name
  • postal mailing address
  • preferred telephone number
  • email address
  • work history
  • educational background
  • language skills
  • professional licenses (e.g., bar membership)
  • legal residency status
  • whether you’ve previously held or applied to any Vanguard positions
  • referral information
  • any information provided on your resume/CV
• Personal information we collect when you register for our Talent Community: To stay up to date regarding our latest career opportunities you may create a profile on our Talent Community, which is provided by Symphony Talent, a service provider. A profile on our Talent Community is separate from the account creation and employment application process discussed above. If you choose to create a profile on our Talent Community, you will be asked to create a user name and password. We will also collect the following information:
  • your full name
  • zip code
  • email address
  • cell/mobile phone number (optional)
  • current or last job title
  • level of education
  • area of interest
  • information you provide on your resume/CV
  • your preferred job title
  • your preferred job location
  • your relocation and travel preferences

You can choose to join the Vanguard Talent Community by logging into one of your social networks, including Facebook, Google, and LinkedIn. If you join using a social network, Vanguard will use information from your social network profile to complete your Talent Community profile.

Along with the above categories of information, we may also collect “special categories” of data if you provide it to us in your resume/CV. However, we are not requesting that you provide us with medical information or other sensitive personal information.

You can also opt-in to receive job alerts via email and be contacted directly by our recruiters should a job matching your profile become available. You may opt-out of this at any time via the unsubscribe link at the bottom of the job alert email or within your Talent Community profile.

We require you to provide the personal data requested in the application to process your application for employment with us. If you do not provide some or all of this personal data, it may affect our ability to process your application and therefore to enter into an employment agreement with you. We will tell you when we ask for personal data due to a contractual requirement or to comply with our legal obligations.

What personal information do we collect about Site usage?

The Site uses a variety of technologies, such as AI chatbot technology, cookies, web beacons, and similar mechanisms, as described further below, to collect information that enables us to provide Site functionality (e.g. the Virtual Assistant, if you choose to use it) and helps us understand how the Site is used (so-called website analytics; for further information see at the end of this section). Specifically, when you visit the Site, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; web pages you view; links you click; searches conducted on the Site; the internet protocol (IP) address used to access the Site; and your general geographic location (e.g., your city, town, or post code). We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. When you visit the Site, you can accept or decline these cookies and other tracking mechanisms, except those that are strictly necessary for you to enter and move around the Site and use essential Site features. You can change your preference at any time.

Cookies

A cookie is a small file of letters and numbers that is stored on your computer, tablet, mobile phone, or other device when you visit a website. Cookies contain information that is transferred to or read on your device and allow websites to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of the Site. This helps us to provide you with a useful experience when you browse the Site and allows us to improve the Site. We and our third-party service providers use session cookies, which link your actions during a particular browser session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.

How to refuse and delete cookies

If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive Notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly. The cookies used on our Site are categorized as follows:

• Strictly Necessary Cookies: We use strictly necessary cookies to ensure our website is functioning properly. For instance, to help you complete common online requests, like setting your privacy preferences, logging onto your account and completing forms online. These cookies are set by default and cannot be disabled.
• Performance Cookies: We use performance cookies to measure website traffic and the popularity of pages. This data is used to measure and improve the website experience for our clients and visitors to the website. If you turn off these cookies your personal information will not be included in our aggregated data and we will not be able to know when you have visited our site.
• Functional Cookies:  These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
• Targeting Cookies: These cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly identifiable personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

You can change your cookie preferences at any time using our cookie preference tool by changing the toggle button on each category of cookies. Once you have made your choice, then click the “Confirm My Choices”.

If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of our Site may not operate correctly.

If you change the settings on your web browser or delete your cookies, in either case so that Vanguard is not able to detect any prior cookie preferences you may have indicated, you may be presented with the consent option again the next time you visit our Site.

Web Beacons

The Site and the emails that you receive from Vanguard use an application known as a “web beacon” (also known as a “pixel tag” or “clear gif”). A web beacon is an electronic file that usually consists of a single-pixel image. We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click on any links in the email.

Website Analytics

The tools we use for website analytics either do not collect IP addresses or anonymize these upon collection and any profiles created by these tools only contain aggregate data. The service providers providing these tools are not permitted to use the information collected on our behalf except to help us conduct and improve our business and subject to our instructions. You will find information below on each tool’s provider and how you are able to object to the collection and processing of data by the respective tool.

Google Analytics

Google Analytics is provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). Google provides for adequate data protection standards due to its certification for the EU-US Data Privacy Framework. You may object to the collection or processing of your data by this tool via this link: https://tools.google.com/dlpage/gaoptout.

Use, Legal Basis, and Disclosure

How do we use personal information?
We use personal information that we collect for the purposes described in this Notice, for the purposes for which it was provided to us, as required by law, and for our business purposes, including:

• To establish a profile for you on Vanguard Careers and/or through the Talent Community;
• To process your employment application and assess your suitability for one or more
vacancies;
• To notify you of job opportunities matching your interest. For example, if you register for our Talent Community and opt-in to receiving email job alerts, you will receive email alerts regarding potential jobs;
• To provide the AI “Virtual Assistant” chatbot functionality. If you choose to use it, the chatbot will use non-generative AI/natural language processing (NLP) to assist you in tasks such as finding information about Vanguard and job vacancies, applying for a job, and scheduling interviews. The AI functionality is not used for any automated decision making within the meaning of Art 22 GDPR;
• To comply with our legal obligations and protect our legal rights, including to comply with record-keeping and reporting;
• To count and recognize visitors to the Site and various Site features and better understand how users access and use our Site and Vanguard products and services;
• To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and

Legal bases for using personal information

We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. To the extent we process personal information, we do so because:

• Our use of your information is necessary to perform a contract or take steps to enter into a contract with you (for example where we use your information to extend an offer of employment to you);
• Our use of the data is necessary for hiring decisions;
• Our use of your data is necessary to comply with a relevant legal or regulatory obligation that we have under EU or EU Member state law (for example, where we are required to undertake a background check to comply with applicable regulations or where we are required to disclose data to a court or tax authority);
• You have provided your consent to us using your data (for example in relation to our use of targeting cookies on the Site or your opting-in to email job alerts); and/or
• Our use of your Personal Data is in our legitimate interest as a commercial organization (for example in order to provide the Virtual Assistant or other Site functionality to you, to better understand how our Site is used and to improve our web design and functionality); in these cases we will process your personal information at all times in a way that is proportionate and respects your privacy rights, and you have a right to object to this processing as explained in the section below titled “Your legal rights”.

If you would like to find out more about the legal bases on which we process your information, please contact us using the details below.

To whom do we disclose personal information?

We will disclose personal information to third parties for the following purposes, as permitted by law. You have certain rights to object to the processing of your personal information as described below.

• Affiliates: We disclose Personal and Other Data to Vanguard Affiliates for the purposes described in this Notice. Should you choose to sign up for our Talent Community the information you provide will be available to all Vanguard Affiliates and they may contact you regarding open positions matching your interests.
• Third Party Service Providers: We disclose personal data about you to our IT service providers in order to process your application, provide the Virtual Assistant or other Site functionality, maintain your Talent Community profile, or send you job alerts. Our service providers are selected partly on the basis of their information security capabilities, and we put in place contract terms to protect the confidentiality of your personal information.
• Legal purposes:  We may use and disclose information about you as we believe reasonably necessary to courts, parties to litigation, government authorities, law enforcement agencies, and legal and professional advisers to protect the rights and property of Vanguard and Vanguard Affiliates, including to establish legal claims or defenses, to obtain legal advice, to defend our legal rights, to protect our rights or property and those of Vanguard Affiliates, to protect other users of our services and our Sites, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a court order or direction.

Cross-Border Transfer of Information

Vanguard generally maintains centralized servers and systems in the United States and may maintain servers and systems elsewhere. These servers and systems are managed by or on behalf of The Vanguard Group, Inc., or Vanguard Affiliates located in or outside the United States. Vanguard also may subcontract the processing of your information to, or otherwise share your information with, other third parties in the United States or countries other than your country of residence. As a result, where the personal information about you that we collect is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) or UK for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA or UK, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or relying on certification schemes such as the EU-US Data Privacy Framework. You may have a right to receive details of the mechanisms under which your data is transferred outside the EEA or UK, and to obtain access to data transfer agreements (which may be redacted for reasons of commercial confidentiality).

Personal Data Quality

Vanguard relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that personal data collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by Vanguard, you should contact us at the address provided in the Contact us section below.

Your Legal Rights

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal Data.

Right to Access Personal Data

You have a right to request that we provide you with a copy of your personal information, and you have the right to be informed of:

• the source of your personal information;
• the categories of personal information that we hold;
• the recipients or categories of recipient to whom personal data have been or will be disclosed;
• the period for which personal information will be stored or, if not possible, the criteria used to determine that period; where personal information was not collected directly from you, available information about its source; or
• the existence of automated decision-making.

Right to Rectify or Erase Personal Information

You have a right to request that we rectify inaccurate information about you. We may seek to verify the accuracy of the data about you before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

• it is no longer needed for the purposes for which it was collected;
• you have withdrawn your consent (where the data processing was based on consent);
• following a successful right to object (see Right to object below);
• it has been processed unlawfully; or
• to comply with a legal obligation to which we are subject.

We are not required to comply with your request to erase your personal information if the processing is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise, or defense of legal claims.

Right to Restrict the Processing of Your Personal Information

You can ask us to restrict the processing of your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy;
• the processing is unlawful, but you do not want it erased;
• it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise, or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction:

• where we have your consent;
• to establish, exercise, or defend legal claims; or
• to protect the rights of another natural or legal person.

Right to Transfer Your Personal Information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

Right to Withdraw Consent

If you have given consent to the processing of your personal data, then you can withdraw such consent at any time. Please note that the withdrawal applies prospectively only. Processing that occurred before the withdrawal of consent is unaffected.

Right to Object to the Processing of Your Personal Information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to Object to How We Use Your Personal Information for Direct Marketing Purposes

Vanguard does not use the personal information collected from you or about you on this Site to market any Vanguard or its affiliates products or services.

If you would like Vanguard to stop sending job alerts to your email address, you may opt out of receiving them by following the “unsubscribe” instructions at the bottom of each communication.

Right to Obtain a Copy of Personal Information Safeguards Used for Transfers Outside Your Jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.

Right to Lodge a Complaint with a Supervisory Authority

You have a right to lodge a complaint with a supervisory authority, including your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

If you would like to exercise any of the rights described above, please send us a request at the address or email provided in the “Contact us” section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, transfer, or delete.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information for you that was requested. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information to fulfill your request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Children’s Privacy

You must be over the age of 18 to apply for a job at Vanguard. The Site is not directed to children under the age of 18, and Vanguard does not knowingly collect information from individuals under the age of 18.

Information Security and Retention

We use commercially reasonable physical, electronic, and procedural safeguards to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable law. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. If you have established an employment application account, we recommend that you take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your user name and password private.

Unless you commence employment with us, in which case the data will be transferred to your employment file, data related to your application will be destroyed six months after it is no longer necessary for the purpose for which it was obtained. Personal data connected with use of the chatbot function may be retained for up to two years to support business and operational purposes. If you choose to provide information to become part of the Talent Community, your information will be retained unless or until you delete your information.

Contact Us

If you have any questions regarding the application process please contact us at careers@vanguard.com.

If you have any privacy related questions regarding the recruitment process, including requests to act upon your legal rights, please email us at privacy@vanguard.com. You may also contact us by sending a message to:
Vanguard Asset Management, Limited
Attn: Data Protection Officer
25 Walbrook
London, GB EC4N 8AF

If you raise concerns about how we have handled your personal information, we may request additional details from you regarding your concerns and may engage or consult with other parties to investigate and resolve your issue. We will keep records of your request and any resolution of your issue.

Changes to this Privacy Notice

We will post changes to this Notice on this Site along with the effective date of the changed Notice. We recommend that you review this Notice periodically.

Revised: March 2024