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RGA Workforce and Recruitment Privacy Notice: European Union

 
We are committed to protecting personal information that we receive about our employees, agency staff, consultants and applicants applying to us for a job. We are committed to maintaining transparent practices and explaining how we collect, process, and share that information. Protecting your privacy is very important to us.

This privacy notice explains how and why RGA International Reinsurance Company dac and its subsidiaries and affiliates (“RGA”, "we" or "us") collect personal information in relation to our employees, agency staff, consultants and job applicants ("you"), and how we use it.  A full list of all RGA entities is available at http://www.rgare.com/global-directory.

RGA is a global reinsurance company focusing primarily on life- and health-related reinsurance solutions.  Our core products and services include life reinsurance, living benefits reinsurance, group reinsurance, health reinsurance, financial solutions, facultative underwriting and product development.

  • What personal information we may collect and hold;
  • The purposes for which your personal information may be collected, held, used and disclosed;
  • How we collect and hold your personal information;
  • What other information we use about you;
  • How we protect your personal information;
  • Who we may share your personal information to (including overseas recipients);
  • How you may access and correct your personal information; and
  • How you can contact us.

This privacy notice is designed to provide compliance with all relevant applicable laws in the European Economic Area (EEA) and in particular those transposing the General Data Protection Regulation (“GDPR”).  RGA recognizes that certain laws might be modified to require stricter standards than those described in this privacy notice, in which case we will ensure compliance with those stricter standards. 

RGA will handle personal information in accordance with local law at the place where the personal information is collected.  If applicable law provides for a lower level of protection of personal information than that established by this privacy notice, then this privacy notice shall prevail. Links to additional country specific privacy policies can be located in the Privacy Center at rgare.com.

Personal information means information, or a combination of pieces of information, that could reasonably allow an individual to be identified. 

If you are applying for a position with RGA, we collect your personal information in the following ways (to the extent permissible under local law):

  • from your application and CV, which you provide directly to us;
  • from your application and CV, which a recruiter provides to us on your behalf;
  • by interviewing you and conducting assessments to test your suitability for a role;
  • by performing background checks with employment screening agencies or publicly available registers (as permitted by law). For example, RGA may check your name against lists developed by various governments for the prevention of money laundering and terrorism;
  • from publicly available professional profiles on websites or social media (e.g. LinkedIn); and
  • from former employers or other referees.

If you are an employee, we may collect your personal information (to the extent permissible under local law):

  • directly from you, when you first joined the company and from time to time throughout your employment;
  • from our communications with you throughout your employment;
  • from managers, other employees, clients or service providers that provide feedback about you throughout your employment;
  • by performing ad hoc background checks with employment screening agencies or publicly available registers, such as lists developed by various governments for the prevention of money laundering and terrorism;
  • from professional or regulatory bodies;
  • through the use of CCTV on our premises; and
  • by monitoring use of our IT systems.

To the extent permissible under local law, we may collect the following categories of personal information about you:

  • personal details (e.g. name, date of birth);
  • contact details (e.g. phone number, email address, postal address or mobile number);
  • photographs;
  • identification documents to verify your identity;
  • educational and professional background information (e.g. educational history, qualifications, certifications, skills, licenses, professional memberships, compensation history);
  • information about your marital status, family and dependents;
  • employment information (e.g. bank account details, payroll information, tax information, benefits, retirement and/or pension information);
  • information about any health issues or disabilities to administer sick pay, to monitor and manage sickness absence, to comply with health and safety legislation and to adapt the workplace or facilities where necessary;
  • citizenship or immigration information; and
  • criminal records.

Some of the information we ask you to provide is mandatory, which means that you must provide this to us in order for us to continue employing you and/or to fulfill our legal obligations. Where it is mandatory for you to provide certain information, we will make this clear to you when we ask for the information.

If you are applying for a job with us or are one of our employees, some of the categories of information we collect are special categories of personal information (sometimes referred to as "sensitive personal information”). These include (to the extent permissible under local law):

  • health or disability information to administer sick pay, to monitor and manage sickness absence, to comply with health and safety legislation and to adapt the workplace or facilities where necessary.

If you voluntarily supply other types of sensitive personal information to us, we will process this information in accordance with the law, and only for the purposes for which you have disclosed it (for example, to make special arrangements to accommodate religious beliefs or to promote diversity in the workplace).

If you are applying for a job with us, we use your personal information to:

a) facilitate the recruitment process and to match your details to job opportunities;
b) match your experience to role criteria;
c) communicate with you in relation to your application;
d) keep you informed of job opportunities which we think may be of interest; and
e) check whether you have previously applied for a job with us.

If you are an employee with us, we use your personal information to:

a) carry out and support human resources administration including recruitment and selection, compensation, performance evaluation and development, promotions, training, payroll administration, immigration and mobility, pension and insurance or other benefit administration, succession planning, employment status, reporting and management;
b) enable you to fulfil your role in providing services to our clients;
c) conduct investigations and resolve employee disciplinary or grievance issues;
d) carry out performance appraisals, promotion assessments and salary reviews
e) comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
f) deal with your enquiries and requests; and
g) maintain the security of our premises, facilities and data.

We may use technology (including technology provided by third party service providers) to process your personal information in a manner that constitutes "profiling" (to the extent permissible under local laws).  This involves the use of software that is able to evaluate your personal aspects and predict risks or outcomes. The main examples of when we conduct profiling are: 

  • when we use personality or psychometric tests, particularly in the recruitment process. These tests analyse your responses to highlight potential strengths and weaknesses and your possible match for certain types of roles, but we do not use these tests to automatically select or eliminate candidates; and
  • for workforce management. We may use software to ensure our workforce is managed and utilised efficiently, to predict risks in staff retention, and to ensure that employees are being compensated fairly. 

Although we may use profiling to assist our decision-making, we do not make solely automated decisions about individuals. So we do not make decisions about hiring, compensation, dismissal, promotion or other matters which may significantly impact an individual, without assessing all the circumstances.

Where necessary we will share your personal information with third parties under the following circumstances:

  • RGA group companies. We operate as a global business, so we may share your contact details as well as other aspects of your employment profile with group companies for human resource management and internal reporting.
  • Service providers. We may share your personal information with service providers that perform services and other business operations for us, for example, we may partner with other companies for payroll administration, offering and administering employee benefits, employee vetting, immigration advice, psychometric testing, hosting the HR platform, and analysing information to improve our processes and policies.
  • Hotels, transport providers and relocation companies, in order to provide relocation support or to arrange transport and accommodation for you, when needed.
  • Any law enforcement agency, court, regulator, government authority or professional body. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party. We may also check your name against lists developed by various governments for the prevention of money laundering and terrorism.
  • Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

You have certain rights regarding your personal information, subject to local law. These include the right to:

  • ask us to confirm whether your personal data is being processed, to access your personal data and for information concerning its processing (right of access);
  • rectifyany inaccurate information we hold about you (right to rectification);
  • erase your personal information (right to erasure);
  • In certain circumstances (for example, when the data subject contests the accuracy of their personal data, while their accuracy is being checked),the right to ask for the processing of your personal data to be restricted (right to restriction of processing);
  • ·object to our processing of your personal information (right to object);
  • withdraw your consent in relation to processing your personal information (where we rely on your consent as our lawful basis for processing) (right to withdraw your consent);
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
  • lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact the HR department or the Global Privacy & Security Office (GSPO) at dsr@rgare.com, or by using the contact details provided below.

We encourage you to contact the HR department to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing. 

If you are an employee, we will keep your personal information for as long as you remain employed with us. Once our relationship with you has come to an end, we will retain your personal information in accordance with our retention policy for a period of time that enables us to:

  • Provide you with any continuing benefits such as pension or insurance
  • Comply with record retention requirements under the law
  • Defend or bring any existing or potential legal claims
  • Deal with any queries or complaints you may have
  • Conduct checks against departing employees that move to certain controlled functions, in accordance with regulations

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

If you are applying for a job with us, we will retain your personal information until the position you are applying for has been filled, after which we will retain your personal information in accordance with our retention policy for a period of time that enables us to:

  • Check our records should you apply for another role with us
  • Comply with record retention requirements under the law
  • Defend or bring any existing or potential legal claims
  • Deal with any queries or complaints you may have

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

Because we operate as a global business, your personal information may be transferred to, stored, and processed in other countries, which may include countries that are not regarded as ensuring an adequate level of protection for personal information under European Union law. A list of the jurisdictions in which RGA operates and hosts personal information is available here.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details contained in the "Contact us" section below.

RGA International Reinsurance Company dac is the controller responsible for the personal information we collect and process. Other RGA entities may also be controllers in respect of your personal information, depending on the nature of the services they provide. A full list of all RGA entities is available at http://www.rgare.com/global-directory.

If you have questions or concerns regarding the way in which your personal information has been used, please e-mail us at privacy@rgare.com, or call or write to us.

Our Ireland postal address is:

RGA International Reinsurance Company dac
3rd Floor, Block C
Central Park
Leopardstown, Dublin 18, D18 X5T1

Our United States postal address is:

Reinsurance Group of America, Inc.
Attn.: Global Privacy Office
16600 Swingley Ridge Road
Chesterfield, Missouri 63017-1706

Our telephone number is:

+353 1.290.2900 (Ireland)
+1 (636) 736-7000 (United States)

Our data protection officer: RGA has appointed the law firm of Fieldfisher as its external Data Protection Officer (“DPO”) to satisfy its requirements under the GDPR.  Should you have any questions for our DPO or concerns regarding the way in which your personal information has been used, please contact them at dpo@rgare.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local supervisory authority (i.e. the supervisory in the jurisdiction where you live or work) or the supervisory authority of the jurisdiction where you believe an infringement of data protection laws has occurred.  Each supervisory authority may have a difference process for lodging complaints so we encourage you to contact the relevant supervisory authority first to check this.

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. If we make a significant change to this privacy notice, we will notify you and, where appropriate, give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing). 

You will be able to see when we last updated the privacy notice because we will include a revision date, shown below. 
 


Last updated: May 2018