Welcome to the JPMorgan Chase Contingent Worker Privacy Notice
You have entrusted JPMorgan Chase (JPMC) with your personal information. This Notice helps you
understand the data we collect, why we collect it and what we do with it. This Notice is important;
we hope you will take time to read it carefully.
As an employee of a JPMC vendor or contingent worker (“engaged individual”), when you share your
information with us we use this information for a variety of purposes, including, but not limited to:
•
Engagement-related
purposes such as, but not limited to, the administration and delivery of the
vendor contract, reviewing and assessing your onboarding application and supporting vendor
engagements.
•
Fraud Prevention / Investigation / Security
purposes such as, but not limited to, providing for the
safety and security of technology systems assets, physical premises, and personnel, and the health
and safety of premises, personnel, and others we interact with in any capacity.
•
Audit, compliance, risk management and reporting, and legal
purposes such as, but not limited to
internal audit and compliance with legal obligations. Examples include our legal and regulatory
reporting obligations.
This Notice explains:
• The principles which support our data strategy
• How we collect your details
• What information we collect and why we collect it
• The choices we offer, including how to access and update information
This Notice is issued by JPMorgan Chase Bank N.A. on behalf of itself, its branches, its subsidiaries
and its affiliates, identified as Controllers in the table in the “Controllers” section below (together,
“J.P.Morgan”, “we”, “us” or “our”) and is addressed to individuals who are prospective, former
engaged individuals and currently engaged individuals. Defined terms used in this Notice are
explained in the “Defined Terms” section.
Processing your Personal Data
We collect
Personal Data about you from a variety of sources (subject to local legal requirements) as
follows:
• We obtain your Personal Data when you provide it to us (e.g., as a vendor employee applicant you
provide personal information like your name, email address and telephone number so that we can
contact you about possible engagement opportunities).
• We collect your Personal Data in the ordinary course of our relationship with you (e.g., in
connection with processing access to our premises).
• We collect Personal Data that you manifestly choose to make public, including via social media
(e.g., we may collect information from your social media profile(s), to the extent that you choose to
make your profile publicly visible).
• We receive your Personal Data from third parties who provide it to us (e.g., credit reference
agencies and law enforcement authorities).
• We collect or obtain Personal Data through our monitoring practices, subject to applicable law,
such as, but not limited to monitoring computer, telephone and other internal JPMC electronic
communications.
We create
Personal Data about you, such as records of your interactions with us, and details of your
engagement, subject to applicable law.
Categories of Personal Data
The categories of Personal Data about you that we Process, subject to applicable law, are as follows:
•
Personal details:
given name(s); preferred name(s); nickname(s), gender; date of birth/age;
marital status; Social Security number; passport number(s); other government issued
number(s) (tax identification number(s), Green Card number(s); driving licence number(s));
nationality; lifestyle and social circumstances; images of passports, driving licences, and
signatures; authentication data (passwords, mother’s maiden name, challenge/response
questions and answers, PINs, facial and voice recognition data); photographs; visual images;
and personal appearance and behaviour.
•
Contact details:
address; telephone number; email address; and social media profile details.
•
Employment details:
industry; role; business activities; names of current and former
employers; work address; work telephone number; work email address; and work-related
social media profile details.
•
Employment history:
details of your education and qualifications
•
Financial details:
billing address; bank account numbers
•
Views and opinions:
any views and opinions that you choose to send to us or publish about
us (including on social media platforms).
•
Electronic Identifying Data:
IP addresses; cookies; activity logs; online identifiers; unique
device identifiers and geolocation data
When we collect your Personal Data, we will inform you if it is required or voluntary. If the
requested Personal Data is required, you will be informed of the potential consequences for failing
to provide the data.
Processing your Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data, except where (subject
to local legal requirements):
•
the Processing is necessary for compliance with a legal obligation (e.g., to comply with our
diversity reporting obligations);
•
the Processing is necessary for the detection or prevention of crime (including the
prevention of fraud) to the extent permitted by applicable law;
•
you have manifestly made those Sensitive Personal Data public;
•
the Processing is necessary for the establishment, exercise or defence of legal rights;
•
we have, in accordance with applicable law, obtained your explicit consent prior to
Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to
Processing that is entirely voluntary – it is not used for Processing that is necessary or
obligatory in any way); or
•
processing is necessary for the reasons of substantial public interest such as the promotion
of equal opportunity and diversity, and is proportionate to the aim pursued and provides for
suitable and specific measures to safeguard your fundamental rights and interests.
Purposes for which we may Process your Personal Data, and legal bases for Processing
The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases
on which we may perform such Processing, are
Processing Purpose
Legal Basis for Processing
AML/KYE:
fulfilling our regulatory compliance
obligations, including ‘Know Your Employee’ for
engaged individual checks; and confirming and
verifying your identity (including by using credit
reference agencies); and screening against
government, supranational bodies (including
but not limited to the European Union and the
United Nations Security Council) and/or law
enforcement agency sanctions lists as well as
internal sanctions lists and other legal
restrictions.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
The Processing is necessary in
connection
with any contract
that you may enter into
with us, or to take steps prior to entering
into a contract with us; or
•
We have
a legitimate interest
in carrying
out the Processing for the purposes of
preventing money laundering, sanctions
violations and protecting against fraud (to
the extent that such legitimate interest is
not overridden by your interests or
fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary – it is not used for Processing that
is necessary or obligatory in any way).
Engaged individual on-boarding:
on-boarding
new engaged individuals; and compliance with
our internal compliance requirements, policies
and procedures.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
The Processing is necessary
in connection
with any contract
that you may enter into
with us, or to take steps prior to entering
into a contract with us; or
•
We have a
legitimate interest
in carrying
out the Processing for the purpose of on-
boarding new engaged individuals (to the
extent that such legitimate interest is not
overridden by your interests or
fundamental rights and freedoms); or
•
We may carry out the Processing when
necessary to
prevent fraud and ensure
your safety
in the identification and
authentication process of registration in
electronic systems; or
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary – it is not used for Processing that
is necessary or obligatory in any way).
Credit worthiness:
conducting credit reference
checks and other financial due diligence.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
The Processing is necessary
in connection
with any contract
that you may enter into
with us, or to take steps prior to entering
into a contract with us; or
•
We have a
legitimate interest
in carrying
out the Processing for the purpose of
conducting financial due diligence (to the
extent that such legitimate interest is not
overridden by your interests or
fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary – it is not used for Processing that
is necessary or obligatory in any way).
IT operations:
management of our
communications systems; operation of IT
security; and IT security audits.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
The Processing is
necessary in connection
with any contract
that you may enter into
with us, or to take steps prior to entering
into a contract with us; or
•
We may carry out the Processing when
necessary
to prevent fraud
and ensure your
safety in the identification and
authentication process of registration in
electronic systems; or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
managing and operating our IT systems and
ensuring the security of those systems (to
the extent that such legitimate interest is
not overridden by your interests or
fundamental rights and freedoms).
Health and safety:
health and safety
assessments and record keeping; and
compliance with related legal obligations.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
providing a safe and secure environment at
our premises (to the extent that such
legitimate interest is not overridden by your
interests or fundamental rights and
freedoms); or
•
The Processing is necessary to protect the
vital interests
of any individual; or
•
The Processing is necessary to protect the
life or the physical safety
of any individual.
Financial management:
sales; finance;
corporate audit; and expense and travel
management.
•
The Processing is
necessary in connection
with any contract
that you may enter into
with us, or to take steps prior to entering
into a contract with us; or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
managing and operating the financial affairs
of our business (to the extent that such
legitimate interest is not overridden by your
interests or fundamental rights and
freedoms); or
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary – it is not used for Processing that
is necessary or obligatory in any way).
Research:
conducting research; and engaging
with you for the purposes of obtaining your
views on your experience.
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
conducting research and producing analysis
(to the extent that such legitimate interest
is not overridden by your interests or
fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary – it is not used for Processing that
is necessary or obligatory in any way).
Security:
physical security of our premises
and
Personnel
(including records of visits to our
premises and CCTV recordings); and electronic
security (including login records, access details,
and monitoring and surveillance practices
(subject to applicable law), where you access
our electronic systems).
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
The Processing is necessary to
protect the
life or the physical safety
of any individual;
or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
ensuring the physical and electronic
security of our business, premises, and
assets
and Personnel
(to the extent that
such legitimate interest is not overridden by
your interests or fundamental rights and
freedoms).
Investigations:
detecting, investigating and
preventing potential breaches of
policy/acceptable standards of conduct, and
criminal/other
offences, in accordance with
applicable law.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
detecting, and protecting against, potential
breaches of our policies, acceptable
standards of conduct, and applicable laws
(to the extent that such legitimate interest
is not overridden by your interests or
fundamental rights and freedoms).
Legal compliance:
compliance with our legal
and regulatory obligations under applicable law
and legal and regulatory and reporting.
•
The Processing is necessary for
compliance
with a legal obligation
.
Legal proceedings:
establishing, exercising and
defending legal rights, complying with
associated obligations and dispute resolution.
•
The Processing is necessary for
compliance
with a legal obligation
; or The Processing is
necessary for the regular exercise of rights
in court or in administrative or arbitration
proceedings; or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
establishing, exercising or defending our
legal rights, complying with associated
obligations and dispute resolution (to the
extent that such legitimate interest is not
overridden by your interests or
fundamental rights and freedoms).
Risk Management:
Audit, compliance, controls,
insurance and other risk management and
reporting.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
We have
a legitimate interest
in carrying
out the Processing for the purpose of
managing risks to which our business is
exposed (to the extent that such legitimate
interest is not overridden by your interests
or fundamental rights and freedoms).
Fraud prevention:
Detecting, preventing and
investigating suspected fraud.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
The Processing is necessary in
connection
with any contract
that you may enter into
with us, or to take steps prior to entering
into a contract with us; or
•
We may carry out the Processing when
necessary to
prevent fraud and ensure
your safety
in the identification and
authentication process of registration in
electronic systems; or
•
We have a
legitimate interest
in carrying
out the Processing for the purpose of
detecting, and protecting against, suspected
fraud (to the extent that such legitimate
interest is not overridden by your interests
or fundamental rights and freedoms).
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary – it is not used for Processing that
is necessary or obligatory in any way.)
Workplace Environment:
such as, but not
limited to health and safety factors.
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
We have a
legitimate interest
in carrying
out the Processing for the purpose of
promoting a diverse and inclusive workplace
that is free from harassment or other
inappropriate workplace conduct, and to
better support our engagement with
engaged individuals (to the extent that such
legitimate interest is not overridden by your
interests
or
fundamental
rights
and
freedoms).
•
We have obtained
your prior consent
to the
Processing (this legal basis is only used in
relation to Processing that is entirely
voluntary - it is not used for Processing that
is necessary or obligatory in any way).
Business Process Execution:
maintaining and
running a financially viable organization in
accordance with law and regulations
•
The Processing is necessary for
compliance
with a legal obligation
; or
•
We have a
legitimate interest
in carrying out
the
Processing
for
the
purpose
of
maintaining and running a financially viable
organization in accordance with law and
regulation (to the extent that such
legitimate interest is not overridden by your
interests
or
fundamental
rights
and
freedoms).
The Disclosure of Personal Data to third parties
We disclose your Personal Data to other entities within the J.P. Morgan group, in accordance with
applicable law and legal bases. In addition, we may disclose your Personal Data to:
•
you and, where appropriate, your family, your associates and your representatives;
•
clients, customers and counterparties of, or to, our businesses;
•
credit reference agencies;
•
anti-fraud services;
•
Governmental, legal, regulatory, or similar authorities, ombudsmen, and central and/or local
government agencies, upon request or where required, including for the purposes of
reporting any actual or suspected breach of applicable law or regulation;
•
accountants, auditors, financial advisors, lawyers and other outside professional advisors to
J.P. Morgan, subject to binding contractual obligations of confidentiality;
•
debt-collection agencies and tracing agencies;
•
data aggregation services;
•
accreditation bodies;
•
third party Processors (such as screening vendors), located anywhere in the world, subject to
the requirements noted below in this Section;
•
any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to
the extent necessary for the establishment, exercise or defence of legal rights in accordance
with applicable law;
•
any relevant party for the purposes of prevention, investigation, detection or prosecution of
criminal offences or the execution of criminal penalties, including safeguarding against and
the prevention of threats to public security in accordance with applicable law;
•
any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant
portion of our business or assets (including in the event of a reorganization, dissolution or
liquidation);
•
the press and the media; and
•
voluntary and charitable organisations.
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to
binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior
written instructions; and (ii) use measures to protect the confidentiality and security of the Personal
Data; together with any additional requirements under applicable law.
International transfer of Personal Data
Because of the international nature of our business, we may need to transfer your Personal Data
within the J.P. Morgan group, and to third parties as noted in this Section above, in connection with
the purposes set out in this Notice. For this reason, we may transfer your Personal Data to other
countries that may have different laws and data protection compliance requirements, including data
protection laws of a lower standard to those that apply in the country in which you are located.
Where we transfer your Personal Data to other countries, we do so on the basis of:
• adequacy decisions;
• our Binding Corporate Rules;
• suitable Standard Contractual Clauses; or
• other valid transfer mechanisms.
If you want to receive more information about the safeguards applied to international transfers of
Personal Data, please use the contact details below.
Securing of Personal Data
We have implemented appropriate physical, technical and organizational security measures
designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration,
unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of
Processing, in accordance with applicable law.
You are responsible for ensuring that any Personal Data that you send to us are sent securely.
Data Accuracy
We take reasonable steps designed to ensure that:
• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes
for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
Data Minimisation
We take reasonable steps designed to ensure that your Personal Data that we Process are limited to
the Personal Data reasonably required in connection with the purposes set out in this Notice.
Data Retention
We take reasonable steps designed to ensure that your Personal Data are only Processed for the
minimum period necessary for the purposes set out in this Notice. The criteria for determining the
duration for which we will retain your Personal Data are as follows:
1.
We will retain copies of your Personal Data in a form that permits identification only for as
long as
•
We maintain an ongoing relationship with you (e.g., while you remain an engaged individual,
or where you are still receiving services from us); or
•
Your Personal Data are necessary in connection with the lawful purposes set out in this
Notice, for which we have a valid legal basis
Plus
2.
The duration of:
•
any applicable limitation period under applicable law; and where required
and
3.
In addition, if any relevant legal claims are anticipated/brought, we may continue to Process
your Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted above we will restrict our Processing of your Personal Data to storage of,
and maintaining the security of, that data except to the extent that those data need to be reviewed
in connection with any legal claim, or any obligation under applicable law.
Once the periods above, each to the extent applicable or permitted by applicable law, have
concluded, we will 1) permanently delete or destroy the relevant Personal Data, or 2) archive your
Personal Data so that it is beyond use; or 3) anonymize the relevant Personal Data.
Your legal rights
Subject to and to the extent provided under applicable law, you may have a number of rights
regarding the Processing of your Personal Data, including:
•
the right to request access to, or copies of, your Personal Data that we Process or control,
together with information regarding the nature, processing and disclosure of that Personal
Data;
•
the right to request rectification of any inaccuracies in your Personal Data that we Process or
control;
•
the right to request, on legitimate grounds:
o
erasure of your Personal Data that we Process or control; or
o
restriction of Processing of your Personal Data that we Process or control;
•
the right to request anonymization, blocking or elimination of Personal data that is
unnecessary, excessive, or processed non-compliant with the provisions of applicable law;
•
the right to have your Personal Data that we Process or control transferred to another
Controller, to the extent applicable;
•
where we Process your Personal Data on the basis of your consent, the right to withdraw
that consent or to request elimination of Personal Data, except if we have legitimate
grounds to keep such Personal Data, but you should note that withdrawing consent does not
affect the lawfulness of Processing based on consent before its withdrawal;
•
the right to object to the processing performed on the basis of one of the consent waiver
scenarios, in case of violation of the provisions of the applicable law, on grounds relating to
your particular situation; and
•
the right to lodge complaints with a Data Protection Authority regarding the Processing of
your Personal Data by us or on our behalf.
This does not affect your statutory rights. To exercise one or more of these rights, to ask a question
about these rights or any other provision of this Notice, to obtain details of the Data Protection Officer
or about our Processing of your Personal Data, please use the contact details provided in the “Contact
Us” section.
Objecting to our use of your Personal Data
If you object to the Processing of your personal data, we will respect that choice in accordance with
our legal obligations or rights. Your objection could mean that we are unable to perform the actions
necessary to achieve the purposes set out above or that you may not be able to make use of the
services and products offered by us.
Cookies
A cookie is a small file that is placed on your device when you visit a website (including our Sites). It
records information about your device, your browser and, in some cases, your preferences and
browsing habits. We may Process your Personal Data through cookie technology, in accordance with
our
Cookie Policy
.
Data Controller
The Data Controller for the data addressed in this Notice is JPMC’s Global Security & Investigations
function.
For any queries please send an email to the Office of the GS&I Data Privacy Champion
(
GSI.DATA.PRIVACY@JPMORGAN.COM
) who will respond to your email.
Additional controllers include, but are not limited to
Controller Entity
Contact Details
J.P. Morgan Administration Services
(Guernsey) Limited.
1st Floor, Les Echelons Court, Les Echelons,
South Esplanade, St Peter Port, Guernsey, GY1
1AR.
J.P. Morgan Administration Services (Ireland)
Limited
JPMorgan House, International Financial
Services Centre, Dublin 1, Ireland D01W213
J.P. Morgan Administration Services (Jersey)
Limited
Forum 4, Grenville Street, St. Helier, Jersey,
Channel Islands JE4 8QH
J.P. Morgan AG
Taunustor 1 (TaunusTurm), 60310 Frankfurt
am Main, Germany
J.P. Morgan Bank (Ireland) plc
JPMorgan House, International Financial
Services Centre, Dublin 1, Ireland D01W213
J.P. Morgan Bank Luxembourg S.A.
European Bank and Business Centre, 6 route
de Treves, L-2633, Senningerberg, Luxembourg
J.P. Morgan Custody Services (Guernsey)
Limited
1st Floor, Les Echelons Court, Les Echelons,
South Esplanade, St Peter Port, Guernsey, GY1
1AR
J.P. Morgan Europe Limited
25 Bank Street, Canary Wharf, London, E14
5JP, UK
J.P. Morgan Limited
25 Bank Street, Canary Wharf, London, E14
5JP, UK
J.P. Morgan Markets Limited
25 Bank Street, Canary Wharf, London, E14
5JP, UK
J.P. Morgan Securities plc
25 Bank Street, Canary Wharf, London, E14
5JP, UK
JPMorgan Chase Bank, N.A., Amsterdam
Branch
Strawinskylaan 1135, 1077X Amsterdam, The
Netherlands
JPMorgan Chase Bank, N.A., Brussels Branch
1 Boulevard du Roi Albert II, 1210 Brussels
Belgium
JPMorgan Chase Bank, N.A., Jersey Branch
Forum 4, Grenville Street, St Helier, JE4 8QH
JPMorgan Chase Bank, N.A., London Branch
25 Bank Street, Canary Wharf, London, E14
5JP, UK
JPMorgan Chase Bank, N.A., Madrid Branch
(Sucursal en España)
Paseo de la Castellana nº 31 - 28046 Madrid
JPMorgan Chase Bank, N.A., Milan Branch
via Catena 4, 20121 Milano
JPMorgan Chase Bank, N.A., Paris Branch
Succursale de Paris- 14, place Vendôme 75001
Paris
JPMorgan Hedge Fund Services (Ireland)
Limited
JPMorgan House, International Financial
Services Centre, Dublin 1, Ireland D01W213
Contact Us
We encourage you to raise any questions you might have regarding our principles or practices via
email to
GSI.DATA.PRIVACY@JPMORGAN.COM
.
Ask A Question
The Office of the Global Security & Investigations Data Privacy Champion will review and respond to
your question.
Data Subject Access Requests
Data Subject Access Requests (DSAR) should be sent to the Office of the GS&I Data Privacy
Champion (
GSI.DATA.PRIVACY@JPMORGAN.COM
) who will respond to your email. When you make
a request we keep a record of your communication so we can action it appropriately. It will be
retained in compliance to the JPMC Record Management policy.
General Information
Other Notices
Throughout your engagement you will encounter privacy Notices regarding the collection and use of
your information. Further details can be found here: www.jpmorgan.com/privacy.
Defined Terms
Term
Definition
Controller
The entity that decides how and why Personal
Data is Processed. In many jurisdictions, the
Controller has primary responsibility for
complying with applicable data protection
laws.
Data Protection Authority
An independent public authority that is legally
tasked with overseeing compliance with
applicable data protection laws.
Personal Data
Personal data means any information relating
to an identified or identifiable natural person
("data subject"); an identifiable natural person
is one who can be identified, directly or
indirectly, in particular by reference to an
identifier such as a name, an identification
number, location data, an online identifier or
to one or more factors specific to the physical,
physiological, genetic, mental, economic,
cultural or social identity of that natural
person.
Process or Processed or Processing
Anything that is done with any Personal Data,
whether or not by automated means, such as
collection, recording, organisation,
structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise
making available, alignment or combination,
restriction, erasure or destruction.
Personnel
Any current, former and prospective directors,
officers, consultants, employees, temporary
staff, individual contractors, interns,
secondees and other personnel including
engaged individuals.
Processor
Any person or entity that Processes Personal
Data on behalf of the Controller (other than
employees of the Controller).
Sensitive Personal Data
Personal Data about race or ethnicity, political
opinions, religious or philosophical beliefs,
trade union membership, physical or mental
health, sexual life, or any other information
that may be deemed to be sensitive under
applicable law.