Privacy Notice – Global Tax News Update

1.Introduction

This Privacy Notice is intended to describe the practices which EY follows in relation to the Global Tax News Update ("Tool") with respect to the privacy of all individuals whose personal data is processed and stored in the Tool.

2.Who manages the Tool?

"EY" refers to one or more of the member firms of Ernst & Young Global Limited ("EYG"), each of which is a separate legal entity and can act as a data controller in its own right. The entity that is acting as data controller by providing this Tool on which your personal data will be processed and stored is EY Global Services Limited, an EY global entity.

Ernst & Young Electronic Publishing Services Inc. ("EYEP") (which is 100% owned by EY LLP, the EY Canada Member Firm) owns the Tool and licenses it to EY Global Services Limited (which will make it available to EY member firms globally).

The personal data you provide in the Tool is shared by EY Global Services Limited with one or more member firms of EYG (see "Who can access your information" section below).

The Tool is hosted on servers in an external data centre in Toronto Canada hosted by Q9 Networks. The SSO component of the Tool will be located in EY Canada's local data centre in Toronto, Canada.

3.Why do we need your information?

The purpose of the Tool is to provide EY Partners, EY Employees, EY's Clients, and Non-Clients with an online Tool for accessing globally-relevant tax alerts from EY countries around the world.

Your personal data processed in the Tool is used as follows:

  1. Authentication (profile information)
  2. Personalization (user preferences tied to profile)
  3. Email generation (tax updates are emailed to user's email address)

EY relies on the following basis to legitimize the processing of your personal data in the Tool: The data subject has given consent to the processing of their personal data for one or more specific purposes.

The provision of your personal data to EY is optional. However, if you do not provide all or part of your personal data, we may be unable to carry out the purposes for processing..

EY gives you choices regarding the collection and usage of your personal information. If you have opted in for any EY related updates through this Tool, and do not wish to receive future e-mails, please visit the Tool's unsubscribe page via the link which can be accessed in each e-mail alert you receive from the Tool.

4.What type of personal data is processed in the Tool?

The Tool processes these personal data categories.

EY's Clients and non-clients:

  1. Company Name
  2. Full Name (Last and First)
  3. Email address (also used as user name for login)
  4. Title
  5. EY Contact [EY Corporate Clients only]
  6. Country
  7. Industry
  8. Management Unit [internal only]
  9. Sub Management Unit [internal only]
  10. City Name [internal only]
  11. Location [internal only]
  12. Grade [internal only]
  13. Logs of user's profile changes
  14. Cookie IDs associated with user's activities on the Tool

EY Partners and employees (through Active Directory):

  1. Full Name (Last and First)
  2. User Name
  3. Password

This data is sourced from a feed from other EY Systems (Active Directory), and sourced directly from (i) EY Partners, employees or contractors, (ii) EY's Clients, and (iii) other parties (non-client users).

5.Sensitive Personal Data

Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.

EY does not intentionally collect any sensitive personal data from you via the Tool. The Tool's intention is not to process such information.

6.Who can access your information?

Your personal data is accessed in the Tool by the following persons/teams:

  • EYEP Senior Developer (EY): Four senior members of the EYEP development team with access to the web and database servers, and, therefore, all of the data which is processed and stored within the Tool. These individuals are located in Toronto, Canada. EYEP Senior Developers have read/write access to all data processed and stored in the Tool, including tax content and all user profiles and usage data logs.
  • Content Admin (EY): Approximately 25,000 EY Partners and employees with read/write access to all tax content on the site. These individuals are located globally. Content Admin have read/write access to all tax content on the site.
  • Profile Admin (EY): Six EY Partners and employees along with EY Help Desk with read/write access to manage user profiles on the site. These individuals are located globally. Profile Admin have read/write Access to user profiles.
  • EY Professional (EY): EY Partners and employees with read/write access to their own profile, read access to tax content. These individuals are located globally.
  • Tax Client (non-EY): Clients with read/write access to their own profile, read access to tax content. These individuals are located globally.
  • Non-clients with read/write access to their own profile, read access to tax content. These individuals are located globally.

The access rights detailed above involves transferring personal data in various jurisdictions (including jurisdictions outside the European Union) in which EY operates (EY office locations are listed at www.ey.com). EY will process your personal data in the Tool in accordance with applicable law and professional regulations in your jurisdiction. Transfers of personal data within the EY network are governed by EY's Binding Corporate Rules. EY is entitled to appoint (sub)processors for the processing of personal data.

7.Data retention

The policies and/or procedures for the retention of personal data in the Tool are: Data retention and data disposal are handled in accordance with EY Records Retention Global Policy. Data is manually deleted. Data will be retained in a separate archive system before it is permanently deleted. Database backups are stored as per the firm's data retention policies. If a user's profile becomes inactive they will immediately be blocked from login. The user information is not deleted, rather just set inactive so they can no longer access the Tool. After first bounce-back email user accounts remain active, but the Tool will no longer send emails to that email address.

After the end of the data retention period, your personal data will be deleted. Your personal data will be retained and maintained in accordance with applicable privacy laws and regulations.

8.Cookies

The Tool uses first party "Cookies" in order to conduct data analytics and to collect data about content you interact with on the Tool to create marketing profiles used to send personalized marketing information.

A "cookie" is technology that allows the Tool to store tokens of information (an 'identifier') on your device while you are using the Tool. Cookies serve to help us track a user's preferences when they use the Tool. Cookies are also used to provide assurance that access to certain proprietary and third party content is limited to only authorized users of the Tool.

How do I disable cookies?

By using the Tool you agree that we can place cookies in your browser. If you do not want to receive a cookie from the Tool, you have the option of setting your browser to notify you when you receive a cookie, so that you determine whether to accept it or not. However, please be aware that if you do turn off 'cookies' in your browser, you won't be able to fully experience some of the features of the Tool and you'll be denied access to protected content items.

What cookies do we use?

The cookies used by the Tool perform four functions, as classified below:

  1. Essential/Strictly Necessary Cookies - Some cookies we use are essential to the functioning of the Tool. For example, remembering your log-in details to allow access to protected content items.
  2. Performance Cookies - Some cookies help us with the performance and design of the Tool. This allows us to measure whether and how many times a page has been visited.
  3. Functionality Cookies - Some cookies help us to remember your settings which you have selected, or assist with other functionality when you browse and use the Tool. This helps us to remember what you have selected, so that on your return visit we remember your preferences.
  4. Tracking Cookies - we use cookies to track user activity and sessions, which helps us to understand your interests as you browse the content on the Tool, so we can tailor and deliver to you personalized marketing information and a more personalized service in the future.

9.Security

EY is committed to making sure your personal data is kept secure. To prevent unauthorized access or disclosure, EY has appropriate technical and organizational measures to safeguard and secure your personal data. All EY personnel and third parties that EY engages to process your personal data are obliged to respect your data's confidentiality.

10.Controlling your personal data

EY will not transfer your personal data to third parties unless we have your permission or are required by law to do so.

You are legally entitled to request details of EYs personal data about you.

To confirm whether your personal data is processed in the Tool or to access your personal data in the Tool, email your request to global.data.protection@ey.com.

11.Rectification, erasure, restriction of processing or data portability

You can confirm your personal data is accurate and current. You can request rectification, erasure, restriction of processing or a readily portable copy of your personal data by contacting your usual EY representative or by sending an e-mail to global.data.protection@ey.com.

12.Complaints

If you are concerned about an alleged breach of privacy law or any other regulation, contact EY's Global Privacy Officer, Office of the General Counsel, 6 More London Place, London, SE1 2DA, United Kingdom or via email at global.data.protection@ey.com. An EY Privacy Officer will investigate your complaint and give you information about how it will be handled.

If you are not satisfied how EY resolved your complaint, you have the right to complain to your country's data protection authority. You can also refer the matter to a court of competent jurisdiction.

13.Contact us

If you have additional questions or concerns, contact your usual EY representative or email global.data.protection@ey.com.

 


 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 2018, Ernst & Young LLP.

 

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Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.

 

"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.

 

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