APAC Job Applicant Privacy Notice

1. ABOUT THIS PRIVACY NOTICE

1.1 As part of any recruitment process, Allspring Global Investments collects and processes personal data relating to job applicants. Allspring Global Investments is made up of several different legal entities¹ so when we mention Allspring, we, us or our in this Privacy Notice, we are referring to the relevant entity in the Allspring Global Investments group responsible for processing your personal data (being the data controller) as set out below:

If you apply for a role in Japan, Allspring Global Investments (Japan) Ltd., located at Level 20 - suite #2007, Marunouchi Trust Tower - Main, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo, Japan 100-000
If you apply for a role in Hong Kong, Allspring Global Investments (Hong Kong) Ltd., located at Unit 29 Level 15, AIA Central, 1 Connaught Road Central, Central, Hong Kong, China;
If you apply for a role in Singapore, Allspring Global Investments (Singapore) Pte Ltd., located at CapitaSpring, 88 Market Street, Level 21 Office #21-29A, Singapore 048948

1.2 This privacy notice sets out the categories of personal data we collect about you, how we collect it, what we use it for and with whom we share it, in accordance with the Data Protection Legislation applicable in your jurisdiction.

1.3 By personal data we mean any information relating to you such as your name or contact details as well as any other information that you provide to us about yourself or, as the case may be, other individuals. Personal data does not include data which has been anonymized, such as data from equal opportunities monitoring carried out on an anonymized basis.

1.4 By data controller we mean that we are responsible for deciding how we hold and use personal data about you. Should you have any questions about this Privacy Notice you can contact us at AllspringPrivacy@allspring-global.com.

1.5 This Privacy Notice also explains how we process personal data that you provide to us about other individuals and you should transmit this Privacy Notice to such individuals or otherwise advise them of its content.

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHAT DO WE USE IT FOR?

2.1 The types of personal data about you which we may collect, store and use are set out in the table below and in each case we have specified the purpose and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ for which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:

where it is necessary for compliance with a legal obligation to which we are subject; and/or
where it is necessary for the performance of the contract; and/or
where it is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of your personal data.

2.2 Where Allspring relies on legitimate interests as a reason for processing personal data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants and has concluded that they are not.

Category of personal data: Contact details.

Examples: Name (first, last), personal address, personal email address, details of whether you are 18 years of age or older and personal telephone number.
Purpose: To contact and communicate with the job applicant during the recruitment process and, more generally, for administration purposes during the recruitment process.
Lawful basis for processing: Legitimate interests. To take steps prior to entering and to enter into a contract with job applicants.
Legitimate interest (where applicable): To make contact and communicate with job applicants during recruitment process.

Category of personal data: Application related documents provided by candidates / permissible recruitment/ background check information.

Examples: Application form, resume, registrations, certifications, academic records, pre-employment checks and licenses.
Purpose: To assess job applicant’s suitability for the role and to keep records relating to our recruitment process.
Lawful basis for processing: Legitimate interests. To make recruitment decisions and maintain standards of integrity and excellence in Allspring’s workforce.

Category of personal data: Application documents generated by Allspring.

Examples: Feedback and notes from interviews or other selection processes.
Purpose: To verify information provided by the job applicant, to assess the job applicant’s application and make recruitment decisions, and to keep records relating to our recruitment process.
Lawful basis for processing: Legitimate interests. To make and justify recruitment decisions and maintain standards of integrity and excellence in our workforce.

Category of personal data: Details about current remuneration.

Examples: Current level of comprehensive salary to include but not limited to, bonus, commissions, stock, long term incentives, benefit entitlements.
Purpose: To make decisions about the financial package on offer.
Lawful basis for processing: Legitimate interests. To ensure appropriate and attractive financial
packages are offered to job applicants.

3. SPECIAL CATEGORIES OF PERSONAL DATA

3.1 Some personal data is more sensitive and requires a higher level of protection. This is personal data which reveals or contains:

(a) racial or ethnic origin;
(b) political opinions;
(c) religious and philosophical beliefs;
(d) trade union membership;
(e) genetic data;
(f) biometric data;
(g) health data; and
(h) sex life or sexual orientation.

3.2 We may process special category personal data because we have a lawful basis for doing so, provided that the collection and processing of such personal data is permitted under the laws applicable in the relevant jurisdiction, and primarily because it is necessary:

(a) for the purposes of carrying out our obligations and exercising specific rights in the field
of employment law (employment law obligations); and/or
(b) for the assessment of your working capacity as a potential future employee.

3.3 However, in limited circumstances we may also process special category data from job applicants to respond to and defend legal claims, or if you have given explicit consent.

3.4 The special categories of data about you which we may collect, store and process (provided that the collection, storage and processing of such personal data is permitted under the laws applicable in the relevant jurisdiction) are set out in the table below and in each case we have specified the purpose and
our ‘lawful basis’ for processing it.

Category of special categories of personal data: Medical/health information provided as part of application process.

Examples: Details relating to any disability.
Purpose: To make reasonable adjustments to the recruitment process.
Lawful basis for processing: Compliance with legal obligations and employment law obligations.

Category of special categories of personal data: Immigration information.

Examples: Passport, driving license visa, work permit.
Purpose: To check your right to work in the country in which you are being employed.
Lawful basis for processing: Compliance with legal obligations and employment law obligations.

Category of special categories of personal data: Information for equal opportunities monitoring

Examples: Race/ethnicity, sexual orientation, religion/philosophical belief, veterans and disability
Purpose: To allow us to monitor equal opportunities, including in some jurisdictions to fulfil our
legal obligations.
Lawful basis for processing: Compliance with legal obligations and employment law obligations.

3.5 We do not require you to provide any special categories of personal data other than those outlined in the table above. We recommend that you do not include any additional special categories of personal data in your application as it is unlikely to be relevant to the application process.

4. WHAT IF YOU DO NOT PROVIDE THE PERSONAL DATA WE REQUEST?

You are not under any statutory or contractual obligation to provide any personal data which Allspring may request during the recruitment process. However, if you do not provide the personal data when requested, we may be prevented from complying with our legal obligations (such as complying with our obligations under the applicable labour laws) and we may therefore not be able to take your application further. We will notify you if this is the case.

5. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it (as identified
under Purpose above), unless we reasonably consider that we need to use it for another
reason which is compatible with the original purpose. If we need to use your personal data
for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6. ADDITIONAL SOURCES OF INFORMATION

In addition to the data we collect from you during the recruitment process, we may receive personal information about you from third parties, such as:

(a) recruitment consultants;
(b) background check agencies (including, in the UK, the Disclosure and Barring Service and in other jurisdictions the local equivalent);
(c) former employers and any other named referees;
(d) any governmental or regulatory body with supervisory authority over Allspring; and
(e) where appropriate and in compliance with local law, third party job boards and social media platforms.

7. WITH WHOM WILL WE SHARE YOUR INFORMATION?

7.1 Your information will be shared internally including with other entities in our group for the purposes of the recruitment process. This includes members of the HR and recruitment team, interviewers and managers in the business area to which the vacancy relates.

7.2 We will not share your personal data with external third parties, unless your application for employment is successful and it makes you an offer of employment. We may then share your personal data with former employers to obtain references for you, and employment background check providers to obtain necessary background checks to the extent admissible under applicable law. We may share your personal data with third parties, for example with a regulator or otherwise to comply with applicable law.

7.3 We may transfer the personal data we collect about you, where necessary, to other entities in our group in the United States, United Kingdom, European Economic Area (the EEA, including Germany, France, Italy and Luxembourg), Bahamas, Japan, Hong Kong and Singapore, in order to assess your eligibility and suitability for employment with Allspring. In relation to the United Kingdom and Japan an adequacy decision by the European Commission exists, meaning that these countries are deemed to provide an adequate level of protection for your personal data. The other non-EEA countries listed are not deemed to provide an adequate level of protection for your personal data.

7.4 Accordingly, we have put in place standard contractual clauses between entities within our group as necessary to ensure that your personal data is treated in a manner that is consistent with the standards of protection that is equivalent to that under the Data Protection Legislation of your jurisdiction. If you require further information about this you can request it from AllspringPrivacy@allspring-global.com.

8. HOW DOES ALLSPRING PROTECT DATA?

Allspring shall use a reasonable standard of care to store and protect your personal data. Allspring safely stores personal data in its databases located in the US and UK and has implemented appropriate physical, technical, organizational and security measures to prevent your personal data from being accidentally lost, misused or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Personal data is protected with safeguards according to the sensitivity of the information contained therein.

Additionally, we have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. FOR HOW LONG DOES ALLSPRING KEEP PERSONAL DATA?

9.1 We will retain your personal data for as long as necessary for the purpose outlined in this Privacy Notice, unless we are obliged to hold it for a longer period under applicable law. Notwithstanding the duration of the purpose, we may retain your information for a longer period if necessary to comply with our legal or professional obligations, enforce our agreements, or resolve disputes. In such circumstances, we will ensure your personal data and privacy is protected.

9.2 If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held are explained in our Employee Privacy Notice and are set out in our Records Management Policy. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

9.3 Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.

10. YOUR RIGHTS IN RELATION TO YOUR INFORMATION

10.1 To the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal data Allspring holds about you. Please refer to jurisdiction specific privacy regulations below:

For Residents or Data Subjects in Australia

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal information. Subject to certain exceptions, you can contact us by email and request access to the personal information we hold about you. There may be some legal or administrative reason to deny you access (for example, where providing access would result in a serious threat to a person’s safety or where the access would be unlawful), in which case we will tell you our reason for the refusal.
Request correction of your personal information. You may request amendments or corrections if your personal information is inaccurate, irrelevant, outdated, or incomplete.
Withdraw consent. You may withdraw consent at any time by giving reasonable notice, unless it would frustrate the performance of a legal obligation.

For Residents or Data Subjects in Hong Kong

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal information. You can contact us by email and request access to your personal information. In normal circumstances, we will give you full access to your personal information. However, there may be some legal or administrative reason to deny you access (for example, where providing access would result in a serious threat to a person’s safety or where the access would be unlawful), in which case we will tell you our reason for the refusal. You may request a copy of your personal data records.
Request correction of your personal information. You may request amendments or corrections if your personal information is inaccurate, irrelevant, outdated, or incomplete.
Object to direct marketing and profiling. You can inform us if you want us to cease processing your personal data for the purposes of direct marketing.
Be forgotten. You can let us know if you wish to suspend, withdraw, or order the blocking, removal, or destruction of your personal data.

For Residents or Data Subjects in Japan

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal information. You can contact us by email and request access to your personal information. In normal circumstances, we will give you full access to your personal information. However, there may be some legal or administrative reason to deny you access (for example, where providing access would result in a serious threat to a person’s safety or where the access would be unlawful), in which case we will tell you our reason for the refusal. You may request a copy of your personal data records.
Request correction of your personal information. You may request amendments or corrections if your personal information is inaccurate, irrelevant, outdated, or incomplete.
Request deletion of your personal information if it has been obtained or processed in violation of the PIPA or when individuals’ rights or justifiable interests of data subjects are being threatened.

For Residents or Data Subjects in Singapore

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal information. Subject to certain exceptions, you can contact us by email and request access to the personal information we hold about you. There may be some legal or administrative reason to deny you access (for example, where providing access would result in a serious threat to a person’s safety or where the access would be unlawful), in which case we will tell you our reason for the refusal.
Request correction of your personal information. You may request amendments or corrections if your personal information is inaccurate, irrelevant, outdated, or incomplete.
Withdraw consent. You may withdraw consent at any time by giving reasonable notice, unless it would frustrate the performance of a legal obligation.

Please note that the withdrawal of certain types of consent may affect the ability of Allspring to continue your application process.

10.2 If you want to exercise one of these rights please contact us at AllspringPrivacy@allspring-global.com.

Fees

10.3 You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, subject to applicable data protection laws, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

10.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it.

11. COMPLAINTS

You may have the right under applicable law to make a complaint if you think we have not adhered to this Notice or any of the applicable privacy laws in handling your Personal Data. If you would like to make a complaint, please submit your complaint in writing to the contact details below. We will respond to your written complaint within 30 days of receipt. If you feel that we have not addressed your concern in a satisfactory manner, you may contact the Data Protection Authority in your jurisdiction.

12. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact AllspringPrivacy@allspring-global.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

13. NO AUTOMATED DECISION MAKING

We do not apply automated decision making techniques.

14. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of such Privacy Notice available on our website and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

15. FURTHER INFORMATION

If you require any further information, please do not hesitate to contact AllspringPrivacy@allspring-global.com.

This privacy notice was last updated in October 2022.

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¹Allspring Global Investments is the trade name used by the following entities: Allspring Global Investments Holdings, LLC, Allspring Global Investments, LLC, Allspring Funds Distributor, LLC, Allspring Funds Management, LLC, Allspring Global Investments (UK) Limited, Allspring Global Investments Luxembourg S.A., Allspring Global Investments (Singapore) Pte Ltd, Allspring Global Investments (Hong Kong) Limited, and Allspring Global Investments (Japan) Ltd.

I consent to the use of my personal data as set out in this Privacy Notice.

I consent to my personal data being transferred to or accessed from outside my jurisdiction.

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APAC Job Applicant Privacy Notice