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EMEA T. Rowe Price Associate and Non-Associate Privacy Notice

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EMEA T. Rowe Price Associate and Non-Associate Privacy Notice

T. Rowe Price International Ltd, 5 Paternoster Square, London EC4M 7DX and T. Rowe Price (Luxembourg) Management Sàrl, 35, Boulevard du Prince Henri, L-1724 Luxembourg, Grand Duchy of Luxembourg (individually and collectively, “T. Rowe Price”) have prepared this EMEA T. Rowe Price Associate and Non-Associate Privacy Notice (Notice) to be provided to individuals like you who are either employed by (Associate) or who are providing services (e.g., on a self-employed or contractor basis) (Non-Associate) to either firm. When we say “T. Rowe Price,” “we” or “us” in this document, we mean the T. Rowe Price entity that you work for or with. In addition, you will see a number of references to the “T. Rowe Price family of companies,” which includes other T. Rowe Price entities globally, such as T. Rowe Price Associates, Inc., and T. Rowe Price Group, Inc., both in the United States and their affiliates and subsidiaries1.

This Notice explains the types of personal data we collect; how we use it; who we share it with; how we protect it; and your legal rights. “Personal data” means information that (either in isolation or in combination with other available information) enables you to be identified as an individual directly or indirectly. Please read the following carefully as it explains our practices regarding your personal data and how it is handled.

Where you are employed as an Associate, T. Rowe Price needs to process your personal data in order to enter into our contract of employment with you and to continue to perform crucial aspects of that contract of employment, such as paying you and providing you with benefits (e.g., health care, pension). There are also statutory and other contractual requirements we have to comply with in relation to your employment.

Where you are providing services as a Non-Associate, T. Rowe Price needs to process your personal data in order for you to provide services to us and continue to perform crucial aspects under the contract under which you provide those services, such as paying you for your services.

If we are not able to carry out the processing activities we describe in this Notice, we may not be able to comply with your contract of employment or with the terms of the contract under which you provide services to us, and in certain very exceptional cases, we may not be able to continue your relationship with us. Of course, we hope it would never come to that; this is simply information we are obliged to provide to you as part of this Notice.

In certain limited circumstances, we may need to ask for your specific consent to process your personal data in a particular way, and in circumstances where that happens it will be clear what we are seeking consent for.

1Certain of our affiliated companies, such as Oak Hill Advisors L.P., may have their own human resources privacy notice or policy that applies to you.

Collection of Personal Data

We may collect personal data directly from you or it may be supplied to us by another party. In most cases, we only allow other parties to carry out the collection of personal data about you when those other parties are acting as a service provider or contractor to us. The retention, use, and disclosure of your personal data by these companies is subject to our contracts and applicable laws. However, depending on your role, certain third parties may carry out collections of personal data under certain circumstances, such as the following:

  • Certain third parties that have had or do have a direct relationship with you and handle or have handled your personal data in accordance with their own privacy notices and applicable laws. Examples include:
    • Employment services;
    • Employee benefit providers, such as health insurance, employee assistance, or financial services benefits providers;
    • Office-related services providers, such as food services and, in some jurisdictions, parking garages;
    • Personalized coaching/training services; and
    • Publications, trade association memberships, or professional licensing organisations.
    In some cases, we may receive personal data in connection with your use of such services, such as when we are paying or reimbursing you for your use of the service.

We may engage professional consulting services or research firms to collect data for us. For example, if you participate in a survey we sponsor, the other firm will provide you with its contact information and privacy notice before you are asked to provide any personal data to it.

We may also collect personal data from other publicly or commercially available sources. We may create personal data about you, such as records regarding leaves of absence. Creation of personal data about you may occur through traditional means or through artificial intelligence (AI), including generative AI. We may also collect information about you from work colleagues or clients, such as in connection with performance reviews or client satisfaction surveys. In each case, we only collect those data elements that are needed for our legitimate interests.

We may use cookies and other technologies to collect personal data regarding interactions with our digital content, such as our websites, mobile applications, or emails. To learn more about how we use cookies and how you can control your digital experiences (as applicable), please see our Cookie Policy.

When you work on our networks and computer systems, we may use logging and other technologies to collect personal data. We process all data we obtain from you or other sources, including data from your previous employer, or that we create, in accordance with this Notice.

Categories of Personal Data

The categories of personal data we may collect, process, maintain, use, and transfer in connection with our current or former work relationships include those set out in the list below. While we have grouped information for Associates and Non-Associates together, not all examples will be relevant and will be dependent on your exact role, for example, the administration of benefits programs and pension plans is relevant for Associates, but it is not relevant for Non-Associates.

  • personal information,such as full name, previous names, and nickname; honorifics and titles; gender; date of birth; place of birth; age; passport details; government-issued numbers; and identification documents, photos, signature, and nationality;
  • contact information, such as your home and work postal addresses, email addresses, contact numbers for telephone and mobile, and emergency contact details;
  • education, work experience, and your views, such as information about your educational background and degree information; your work experience and other experience and skills included on your résumés/CVs, or otherwise collected as part of your employment or work with us (including any professional credentials and licences, certifications, and memberships and affiliations) and other data from résumés/CVs; biographical data relating to past roles, such as work history, business title, position type and level, and reason(s) for leaving a job; data from social media profiles, such as Facebook, LinkedIn, and similar platforms; information provided for company social and professional networks (employee profile data), including alumni programs, professional goals and interests, travel preferences, research/survey data, and other views you have shared with us;
  • information about your role, such as your business title, position type and level, working time information, location, dates of employment, the start and end date of your employment contract or other contract under which you provide services to us, reemployment or reengagement eligibility, reporting information, work history, time and attendance records, leave and absence records and reason for leaving, travel and expense records, training plan records, compliance records, and performance records and reviews;
  • information about your salary and benefits and your financial information, such as your salary, bonus and commission entitlements, salary/payroll records (such as current and expected salary and benefits, bonus, and hourly rate); insurance benefits (including information about you and your dependents that we provide to the insurer); beneficiary and dependent information; benefit plan records for you and your beneficiaries and dependents (such as insurance, retirement plan, equity award, and other employee benefits such as pension plans); benefits recipient numbers, tax withholding/payment codes; reference for invoicing; your bank account details and/or payment card information to facilitate compensation (such as for direct deposit and reimbursement of expenses) and payment dates; and company-issued payment card information (and personal payment card/account information if provided for reimbursement), including transaction records;
  • information about your equity compensation to which you may be entitled, such as units of stock or options awarded, cancelled, or held;
  • information about securities holdings, transactions, and positions for you and close family members, such as securities that you hold or can exercise control over, securities transactions and information about a second job or officer or director position outside the T. Rowe Price family of companies, and similar types of information for close family members;
  • information required for work and immigration visa/permit applications, such as your and your dependents’ full names; contact details; and education and work experience;
  • audio and visual information such as photographs, video images, audio recordings (such as call monitoring records, recorded conference calls), CCTV records, and voicemails;
  • information regarding buildings and property and your location, such as CCTV images (which may include video and voice recordings of you) filmed in and around our EMEA offices, swipe card access, and the location and configuration of your workstation/office when you are on premises and location or region you are in when you are using a company-issued device or when you use another device to interact with our digital systems or content or for telephone calls;
  • • information regarding IT and communications systems and equipment, Internet of Things (IoT), sensor information, such as your system identifiers (e.g., usernames or online credentials); internet protocol (IP) address; MAC address; SSIDs and other device or persistent identifiers; device characteristics (such as browser information); web server and application logs; browsing data; first- and third-party cookies; Web beacons; clear GIFs; pixel tags; records from access control devices, such as badge readers; records from technology monitoring programs, including suspicious activity alerts; records of equipment that is used by you; monitoring of web traffic and emails; information collected from logging and data loss prevention tools regarding activities conducted on systems, networks, and devices we make available to you; data collected by “always on” devices (personal assistants); workplace sensors (such as to gauge occupancy); and other consumer-activated devices;
  • performance and disciplinary information, such as performance reviews; evaluations and ratings; information about disciplinary allegations, the disciplinary process, and any disciplinary warnings; details of grievances and any outcome; and for Non-Associates, service provision reviews and the handling of any complaints in relation to the services you provide;
  • absence information, such as dates of leave of absence/vacation, maternity/paternity/shared parental leave, confirmation of a birth of a child, training/educational leave, family care leave, and medical leave;
  • background check information, such as information obtained through reference checks, confirmation about your work/educational background, work visa details, previous addresses, current and past directorships held by you and members of your immediate family, credit history, international credential verification, public safety verification, and adverse media searches;
  • information about work activities and communications, such as notes and documents regarding corporate matters in which you are or may be involved, emails and other communications you send or receive through a device or network maintained by or for us, and recordings of telephone calls and video meetings (as applicable);
  • information about regulatory actions against you, such as if you are subject to a regulatory action;
  • information about gifts and entertainment, such as gifts you give or receive from others connected with the T. Rowe Price family of companies or business entertainment where you are a host or a guest;
  • information relating to compliance matters, such as data subject requests and supporting documentation; records of reporting as required under the Code of Ethics and Personal Transactions Policy and Global Code of Conduct (collectively, “Codes”); complaints, investigations, incident details, and resolutions of such matters; employment eligibility verification records; background screening records; and other records maintained to demonstrate compliance with applicable laws, such as payroll tax laws, occupational safety records, and workers’ compensation program records; records of privacy and security incidents involving HR records, including any security breach notifications; information obtained through reference checks and/or gathered under company policies; financial regulator, broker-dealer, and bank affiliations for you and close family members; records relating to complaints, investigations, incident details, and resolutions of such matters; and records maintained in connection with legal matters, litigation, or subject to legal holds.

In addition to the collection, processing, and use of the types of personal data described above, T. Rowe Price may collect, process, maintain, use, and transfer the following special categories of personal data about you:

  • health and medical data, such as medical information for job placement and fitness to work examinations, accommodation of disabilities, medical information for leave and absence management (e.g., the number of sick days and the information contained in a doctor's certificate/medical certificate and information on disability leave), and workers’ compensation programs, wellness program data, information pertaining to enrollment and utilization of health and disability insurance programs, information collected in connection with occupational safety programs such as information about accidents and illness incurred at work, information on any disabilities, if you choose to voluntarily provide it to us, and any related workplace accommodations and information on maternity leave for purposes of accommodating the workplace and compliance with legal obligations;
  • religious affiliations, where this has been provided voluntarily to T. Rowe Price for purposes of equal opportunities and diversity monitoring and initiatives or if disclosed by you voluntarily for our business planning for time-off requests;
  • children’s information, while we do not collect any personal data directly from children, we collect children’s information pertaining to children from the parents or guardians of the children, such as child’s name, date of birth, identification numbers, and relationship to you as a beneficiary, and as part of benefit program eligibility and enrollment records;
  • criminal records data, in the event that T. Rowe Price has conducted or received the results of criminal records background checks in relation to you, where relevant and appropriate to your role or where you provide the information to us in line with the annual reporting requirements that you are or may be subject to under our Codes;
  • trade union membership or affiliation, such as for the purposes of administering trade union subscriptions through payroll;
  • race or ethnicity data, such as information contained in your passport or other citizenship and right to work documentation, and information that you have voluntarily provided to T. Rowe Price for the purposes of our equal opportunities and diversity monitoring and initiatives;
  • sexual orientation data, such as marital status and information contained in your marriage/civil partnership certificate for the purpose of administering name changes, and information that you have voluntarily provided to T. Rowe Price for the purposes of our equal opportunities and diversity monitoring and initiatives; and
  • other types of personal data that may be defined as sensitive personal data according to applicable local law.

How We Use Personal Data

We use the personal data we collect from and about you and process it for a variety of purposes related to your role and the running of our business generally, which are based on one or more legal justifications as set out below:

Purpose Justification
To administer and provide compensation, benefits, and other work-related allowances in accordance with your employment contract, or if you are a Non-Associate to provide payment to you (or your employer) for the services that you provide to us. Processing your personal data for these purposes is necessary for performing contractual obligations and complying with legal requirements.
To administer and manage our workforce, including work hours, leave, and equal opportunity and diversity monitoring and initiatives. Processing your personal data for these purposes is necessary for complying with legal requirements, performing contractual obligations, and/or as part of our legitimate interests in running our business effectively.
To evaluate your performance in your current role and potential suitability for other roles within the T. Rowe Price family of companies. It is in our legitimate interests to process your personal data to assess your performance in your current role and potential suitability for other roles.
To arrange required travel or to pay travel expenses or business expenses in connection with your role. It is in our legitimate interests to process personal data in order to facilitate travel administration and payment or reimbursement of business expenses.
To conduct background checks as part of your proposed or current role. We will ask for your explicit consent before processing your personal data in this way when required and as allowed by local data protection or other law. In addition, it is in our legitimate interests to carry out the obligations and to exercise the specific rights of T. Rowe Price or you in the field of employment and social security and social protection law as permitted by local data protection or other law and/or a collective agreement.
To keep internal records and manage our relationship with you. It is in our legitimate interests to keep records of your personal details and update these when necessary. It is also in our legitimate interests to keep records of any correspondence with you.
To manage our risks and legal rights; to help identify illegal activity; and to monitor compliance with applicable policies, procedures, and laws. This processing is necessary for the purposes of complying with legal requirements and/or as part of our legitimate interests in managing risks to which our business may be subject or exercising or defending legal rights.
To comply with legal and regulatory requirements (such as in connection with required screening programs), including disclosures to tax or other regulatory authorities inside or outside your home country, and employment, service provider, and immigration-related requirements along with the administration of those requirements. This processing is necessary for the purposes of complying with legal requirements. Sometimes, legal requirements may apply to another company, or product or service offered, within the T. Rowe Price family of companies, and it would be in our legitimate interests to assist in meeting such requirements.
To maintain safe, secure, and well-functioning IT and communications systems and equipment, which will include the use of appropriate logging and data loss prevention tools that allow us to track and analyse activities you conduct on systems, networks, and devices we make available to you (including your internet usage and related browsing log files) in order to be able to identify malware or other risks in web surfing traffic and to keep our data secure. It is in our legitimate interests to monitor how our IT and communications systems and equipment are used to detect and prevent fraud, other crimes, and misuse, as well as to ensure that they are functioning as intended. In some instances, we may need to process information in this way to comply with laws that require us to keep our IT and communication systems and equipment safe, secure, and well functioning.
To effectively manage our business, such as concerning the products and services offered by the T. Rowe Price family of companies, service provider management, finance, security, information technology and physical infrastructure, and corporate audit, and negotiating and implementing corporate restructuring, mergers, or acquisitions. This processing is necessary for the purposes of complying with legal requirements, performing contractual obligations, and/or as part of legitimate interests in managing our business and risks.
To help assess, manage, and monitor our premises, including to protect against injury, theft, legal liability, fraud, or abuse, and to protect people and property, such as through CCTV, visitor records, issuing of badges and access devices, and other physical security programs. It is in our legitimate interests to maintain the security and orderly functioning of our premises.
To anonymise personal data or create aggregated datasets, such as for consolidated reporting, research or analytics. It is in our legitimate interests to undertake internal research and activities related to maintaining and improving our workforce, including changes to our services and benefits.
To maintain health and safety information, assessments, and related recordkeeping. It is in our legitimate interests to effectively manage our premises and operations consistent with health and safety practices. In some instances, we may need to process this type of information in order to comply with law.

When relying on the legitimate interests basis for processing your personal data, we will balance the legitimate interest(s) pursued by us and any relevant third party with your interest(s) and fundamental rights and freedoms in relation to the protection of your personal data to ensure that it is appropriate for us to rely on legitimate interests and to identify any additional steps we need to take to achieve the right balance.

We may use AI, including machine learning, as part of our business operations for one or more of the purposes set out above, which involve the processing of your personal data. For example, we may use tools powered by AI to assist us with identifying and considering suitable candidates for our vacancies or to assist with our information security programs. When we communicate with you, this may also be powered by or incorporate AI.

Your personal data may also be processed as part of the training, testing, and use of AI to support one or more the purposes set out above. Where we use AI, we do so in accordance with applicable law and our policies and procedures.

To Whom Do We Disclose Personal Data

Your personal data is intended for T. Rowe Price and may be disclosed within the T. Rowe Price family of companies and, in certain circumstances, to other parties as directed by you.

We may disclose your personal data to:

  • T. Rowe Price's family of companies. As the T. Rowe Price entity that you work for, or provide services to, is part of a wider group of companies with headquarters in the U.S. and offices located across the globe, which all partially share management, IT, human resources, legal, compliance, finance and audit responsibility, we may disclose your personal data among the T. Rowe Price family of companies, including our subsidiaries and affiliates, for employment/business reasons and to conduct the other activities described in this Notice. The transfer of personal data within, and among, the T. Rowe Price family of companies is necessary to support the functions in different business contexts. Our family of companies includes subsidiaries and affiliates whose names include "T. Rowe Price," "Oak Hill Advisors," and "OHA."

We may also disclose your personal data to the following types of other organisations:

  • External auditors, accountants, background check service providers, legal, and other professional advisors.
  • Our service providers. We use other companies or contractors (service providers) to perform services on our behalf or to assist us with the operation of T. Rowe Price business. For example, when you use our online portal to apply for employment or perform a self-evaluation, the HR information database is currently operated by a service provider. While we may use a service provider to assist in relation to any of the purposes for which we may collect personal data, they generally fit within one or more of the following categories of service providers:
    • Infrastructure and technology service providers;
    • Analysis, research, event, and communications providers; and/or
    • Providers of administrative services for T. Rowe Price, such as payroll or payment providers, relocation and visa application providers, talent and educational services, benefit providers, and travel services.
    In the course of providing such services, these service providers may have access to your personal data. However, we will only provide our service providers with the information that is necessary for them to perform the services. They will act under our instructions, and we instruct them not to use your personal data for any other purpose. We will always use our best efforts to ensure that all the service providers we work with will keep your personal data secure.
  • Other parties permitted by law. In certain circumstances, we may be required to disclose your personal data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal data to the police, regulators, government agencies, or judicial or administrative authorities). We may also disclose your personal data to other parties where disclosure is both legally permissible and necessary to protect or defend our rights, in matters of national security, for law enforcement purposes, to enforce our agreements, or to protect your rights or those of the public.
  • Other parties in connection with ordinary business activities. We may disclose your personal data, such as your business contact details, photo, and biographical information, to other parties with which we or another member within the T. Rowe Price family of companies interact in the ordinary course of business, such as when you are included on an email with others.
  • Other parties connected with business transfers. We may transfer your personal data to other parties (including existing or newly formed companies in the T. Rowe Price family of companies) in connection with a reorganisation, restructuring, merger, acquisition, or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Notice.

Where We Store Your Personal Data 

The personal data that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction in which you are located.

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), this means the personal data may be transferred to, stored at, and accessed from, a destination outside the EEA or UK, including to T. Rowe Price Associates, Inc., in the United States. It may also be processed by staff operating outside the EEA or UK and who work for us, an affiliate, or one of our service providers. If you are located outside the EEA or UK, then in addition to the above, this means that personal data may be transferred to, and stored at, a destination in the EEA or UK.

For transfers to T. Rowe Price entities that are not in the EEA or UK, T. Rowe Price will be bound by the EU Standard Data Protection Clauses (pursuant to Article 46(2)(c) General Data Protection Regulation) or the UK’s International Data Transfer Addendum to such Clauses (as applicable) or other appropriate safeguards to ensure that your data is protected adequately. You can ask for a copy of our appropriate safeguards by contacting us as set out below under "Contact us."

Your Choices/Your Privacy Rights

You have various rights in connection with our processing of your personal data, each of which is explained below. If you wish to exercise one or more of these rights, please contact us as stated below under "Contact us," and include your name, email, and postal address, as well as your specific request and any other information you think would be useful in order for us to process your request.

  • Access. You have the right to confirm with us whether your personal data is processed and, if it is, to request access to that personal data, including the categories of personal data processed, the purpose of the processing, and the recipients or categories of recipients. We do have to take into account the interests of others, however, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
  • Rectification/Correction. You have the right to request that we rectify/correct inaccurate or incomplete personal data concerning you. In addition, where you have used an online portal to load your personal data, and where there is functionality that allows you to do so, you may access, review, and update your personal data directly.
  • Deletion. You have the right to ask us to erase personal data concerning you, except that we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
  • Restriction. You have the right to request that we restrict processing of your personal data. This may apply where you believe such data to be inaccurate, that our processing is unlawful, or that we no longer need to process such data for a particular purpose; however, this right is not absolute. Where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it, we would mark stored personal data with the aim of limiting particular processing for particular purposes in accordance with your request or otherwise restrict its processing.
  • Portability. You have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and you may have the right to transmit that data to another entity.
  • Objection. You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us, and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision (when applicable) so that you can express your view and to contest the decision. This right is not absolute and may not apply in certain circumstances.
  • Make a Complaint. You also have the right to lodge a complaint with the competent data protection supervisory authority, which in Luxembourg is the Commission Nationale pour la Protection des Données (CNPD) or in the UK is the Information Commissioner's Office (ICO). If you are based in, or the issue you would like to make a complaint about took place elsewhere in the EEA, a list of other local data protection authorities in these locations can be found here and for Switzerland can be found here. If you are based in, or the issues you would like to make a complaint about relates to any other location, please contact us as stated below under "Contact us."

If we need additional information to verify your identity, we will let you know. We will endeavour to respond to a verified request no later than a month after receipt, unless there are grounds for extending our response time frame by up to two further months. In the event of an extension, we will explain to you why the extension is necessary. In some cases, your ability to exercise a right will be limited, as required or permitted by applicable law. If we cannot fulfill your request because we cannot verify your identity or due to exceptions under applicable law, we’ll let you know in our response.

For How Long Do We Keep Your Personal Data

We will only retain your personal data for as long as it is necessary for the purpose for which the data was collected and to the extent permitted by applicable laws. For example, we may retain certain details and correspondence until the time limit for claims arising from the interaction has expired or to comply with regulatory requirements regarding the retention of that data. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Security

We have implemented technical and organisational security measures in an effort to safeguard personal data in our custody and control. Such measures we have implemented include limiting access to personal data only to Associates, Non-Associates, and authorised service providers who need to know such information for the purposes described in this Notice; training for our Associates and Non-Associates; as well as other technical, administrative, and physical safeguards. While we endeavour to always protect our systems, sites, operations, and information against unauthorised access, use, modification, and disclosure, due to the inherent nature of the internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

Language 

This Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version, the English version shall prevail.

Contact Us

If you have questions about this Notice or if you would like to exercise your rights as a data subject, please use one of the following methods (as available to you) to submit an enquiry:

  • Use MyHR through the internal T. Rowe Price Exchange;
  • Send an email to International_HR@troweprice.com; or
  • Through the post to: International HR, T. Rowe Price International Ltd, 5 Paternoster Square, London EC4M 7DX.

Date and changes to this Privacy Notice  

This Notice is the most recent version, and the date it was last updated is located below. We reserve the right to change our Notice from time to time. If we decide to make a material change to our Notice, we will endeavour to make you aware of that fact by, for example, notifying you of these changes via email and/or posting an alert on an internal website. If we make a change that we are required by law to inform you of in other ways (such as by email), we will do so.

Last Updated: 5 February 2025

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