Privacy Notice for Employment Candidates

General Information

1. Partners Group is committed to protecting the privacy and security of personal data collected and processed in connection with our recruitment processes.

2. For the purposes of this Privacy Notice, “Partners Group”, “our”, “we”, or “us” refers to the Partners Group entity with the position or opportunity for which you have applied or are being considered, and is involved in your recruitment process.

3. Where we refer to “you” or “candidate”, this refers to an individual that has applied or is being considered for a position with Partners Group (and related persons such their contacts and referees), including permanent, fixed term, or any other form of employment, or participation in programs such as internships or apprenticeships.

4. This Privacy Notice outlines how we collect and process personal data during and after the recruitment process and it explains your rights and obligations. Personal data is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual. Processing includes all actions that can be performed on personal data such as collecting, organizing, storing, using, disclosing or otherwise making available, restricting or destroying.

What information do we have about you?

5. We primarily obtain your personal data directly from you. For example, data will be collected from your application forms; your curriculum vitae; correspondence with you, or through interviews, meetings, or other assessments you may be invited to attend (whether by telephone, video conference, or in person). Partners Group may receive personal data about you from third parties. For example, we may obtain information about you from references you supply; a recruiter with whom you may be working; publicly available resources such as LinkedIn, eFinancial Careers, and other job boards; or third-party background screening (where permitted by law and necessary based on the nature of the position for which you are applying).

6. We may process various types of personal data about you, including:

Information provided in your application including supporting documents (e.g., resume, curriculum vitae, reference letters and contacts, education certificates, transcript of grades, work certificates);
your personal data (e.g., full name, gender, personal contact details such as email address, postal address, and phone number, emergency contact information, hobbies and interests);
your qualifications, employment details, interests, and career development goals (e.g., work history, experience, professional memberships, education, languages spoken and preferred language, certifications, employment references, career development goals and interests);
compensation information (e.g., salary expectations including base pay, bonus amounts, currency, long-term incentives);
if you are invited to interview in person and incur reimbursable expenses, certain financial information (e.g., bank account details, travel and expense information including supporting documents);
the results of any assessments that we may carry out as part of the recruitment process (e.g., personality or case study);
once you progress in the recruitment process and have received an offer of employment
your work eligibility and other required information for the country where you are being considered for employment (e.g., nationality / immigration status, national identification documents, work permits, passports, visas, social security number, tax identification number, and any other document or information as may be required in that country, to apply for the necessary work permits or confirm your work eligibility for the position to which you are applying, or as may be necessary in relation to applicable employee insurance, pension, benefits, or taxation);
candidate due diligence information (e.g., reference checks, and other checks that may be required for regulatory purposes); and
Any other information necessary for the purposes of managing our recruitment processes, and interactions with you.

This is not an exhaustive list of types of personal data that we may process.

7. In connection with your application, Partners Group usually does not request or require sensitive personal data under the applicable law, which is personal data identified under applicable law as being of a higher risk due to its sensitive nature (e.g., under the GDPR, data relating to racial or ethnic origin). To the extent that you provide us with sensitive personal data, you expressly authorize us to handle such information in accordance with this Privacy Notice. For example, if you have a disability and would like for us to consider an accommodation, you may provide that information during the recruitment process.

8. In certain jurisdictions, based on the sensitive nature of our work in the financial service industry, your function, or your seniority, we may, following your receipt of an offer of employment, obtain information about criminal allegations, convictions and offences as well as your credit history as part of our ongoing employee due diligence process.

9. If you intend to provide us with personal data about other individuals (e.g., your emergency contacts, referees), you must provide a copy of this Privacy Notice to them.

How do we process your personal information and why is this justified?

10. We process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. We may process your personal data for other purposes that are consistent with the purpose for which your personal data was originally collected. Some of the purposes for which we may process your personal data include:

to assess your skills, qualifications, and suitability for the role to which you have applied or are being considered;
to complete background and reference checks, where applicable;
to communicate with you about the recruitment process;
to initiate the employment relationship (if you are selected for the position);
to monitor our facilities to protect the safety and security of our personnel, guests, property and assets and to ensure compliance with applicable policies and laws;
to control access to our facilities (e.g., visitor logs);
to comply with legal or regulatory requirements; and
to respond to and defend against claims.

11. We will process your personal data with a legal basis under the applicable law. Generally, we process your personal data under one or more of the following bases where applicable:

the processing is necessary to comply with our legal or regulatory obligations (e.g., we are required to check a candidate's eligibility to work in the country of hiring before employment starts, and if necessary, apply for required work permits; and to perform checks required under financial services laws and regulations to which we are subject);
it is necessary for our legitimate interest and does not unduly affect your interests or fundamental rights and freedoms. Please note that, when processing your personal data on this basis, we always seek to maintain a balance between our legitimate interests and your privacy. Specifically, we believe that it is in our legitimate interest to process personal data about you during the recruitment process and to keep records of that process. Processing personal data from candidates allows Partners Group to manage the recruitment process, assess and confirm a candidate's suitability for employment, and select the best-qualified candidate for a job opportunity;
we have obtained your prior consent (where legally required);
we have provided you with the requisite notification; and/or
we are otherwise permitted or required by law to do so.

Where Partners Group relies upon your consent to process your personal data, you may have the right to withdraw your consent. If you withdraw consent, Partners Group will stop promptly any processing based upon consent. However, your withdrawal of consent does not affect the lawfulness of any processing up to that point.

12. To the extent Partners Group processes your sensitive personal data, we will do so in compliance with applicable law.

13. Partners Group may aggregate and anonymise personal data and process it thereafter to develop recruitment statistics and allow for the continuous improvement of our recruitment process. As the information is aggregated and anonymized, it does not constitute personal data and is not subject to this Privacy Notice.

14. If you fail to provide personal data which is necessary for us to achieve any of the purposes outlined in this Privacy Notice, this may result in consequences. For instance, if during the recruitment process, you fail to provide personal data when requested which is necessary for us to consider your candidacy (e.g., evidence of qualifications), we may not be able to evaluate you as a candidate and may be required to end the recruitment process.

Who has access to your personal data and to whom are your personal data transferred?

15. We will never sell your personal data.

16. In the course of our activities and for the purposes listed in this Privacy Notice, your personal data may be accessed by or transferred to the following categories of recipients on a need to know basis to achieve such purposes:

Partners Group personnel (e.g. members of the human resources and recruitment team, interviewers with whom you speak or meet, managers or other personnel in the business area with a vacancy or with whom you are expected to interact if you are selected for the position, finance if you are invited to interview in person and require travel related reimbursements, and technology, administrative, or security staff with whom you interact if you are invited to an interview at our facilities or using our technology (e.g., video conference)). These individuals may be employed by Partners Group or affiliated companies or they may be representatives from one of our service providers;
other related Partners Group group entities (e.g., operating entities, or management companies);
service providers (e.g., recruitment agencies, corporate expense management providers, or if you are successful in your application and you accept our offer of employment, where permitted by law, we may obtain a background and / or credit check from specialized third-party service providers);
technology systems providers, including cloud and database providers, and related consultants;
governmental bodies, financial or tax regulatory authorities, judicial authorities, or law enforcement, when legally required;
any third party to whom we assign of our rights or obligations; and professional advisors and external lawyers.

Such recipients are obligated to protect the confidentiality and security of your personal data.

17. The personal data we collect from you may also be processed by Partners Group in a different country than where you are located. Your personal data may be transferred by Partners Group to the EEA, to the countries where Partners Group has an office, or to any country in the world where Partners Group’s service providers are located, including for example the US. The data protection law in such other country may not give you as much protection as the data protection law in the country where you are located.

18. We ensure that any transfer is made in accordance with applicable law. For example, for transfers to a country deemed by a privacy authority to not offer the same level of protection, we ensure that the transfers are governed by appropriate safeguards, such as the European Commission Standard Contractual Clauses.

19. You may request additional information in relation to such cross-border transfers and obtain a copy of the appropriate safeguard put in place by Partners Group as described in the section titled "Who can I contact if I have any questions or concerns?".

How do we protect your personal data?

20. We have implemented appropriate technical and organizational measures to protect the security and confidentiality of your personal data, and our measures are aligned with international standards.

21 .While we take reasonable care to implement such measures, remember that the internet is inherently unsafe, and we cannot guarantee the security of your personal data when transmitted over the internet or email.

22. If during your recruitment process there is a change in your circumstances, please update your information directly on the application portal.

How do we store your personal data?

23. We retain your personal data for as long as necessary in connection with the purposes described in this Privacy Notice and in accordance with Partners Group’s retention schedule and applicable law.

24. If you are successful in your application, the information collected as part of the recruitment process will be transferred to your employee personnel file and retained during your employment. You will receive a new Privacy Notice specific to your employment.

What are your data subject rights and how can you exercise them?

25. We recognize that you may have rights regarding our processing of your personal data. While the nature and extent of these rights will differ based on the applicable law, we have processes in place to respond in a timely manner to any valid request. Your rights may include:

the right to access the personal data about you that we process;
the right to request the correction of personal data that you believe is incorrect, obsolete, or incomplete;
the right to request the erasure of your personal data;
the right to restrict the use of your personal data to specific categories of processing;
if your personal data is processed based on your consent, you have the right to withdraw your consent at any time (please note that if you withdraw your consent, processing based on your consent that took place before your withdrawal will remain lawful);
the right to object, in whole or in part, to the processing of your personal data; and
the right to request that the personal data you provided us be returned to you or transferred to the person or entity of your choice in a structured, commonly used and machine-readable format without hindrance from us.

26. You may exercise your rights at any time by using the details in the section "Who can I contact if I have any questions or concerns?". To the extent permitted by applicable law, we reserve the right to charge an appropriate fee in connection with the exercise of your rights.

27. We may request specific information from you to help us confirm your identity. This is to ensure that personal data is not disclosed

to any person who does not have authority to receive it. We also may request further information in relation to your request to help us
to locate the personal data processed in relation to you, including, for example, the nature and location of your relationship with us.

Who can I contact if I have any questions or concerns?

28. The Partners Group entity responsible for the application portal is Partners Group AG, Zugerstrasse 57, 6341 Baar, Switzerland.

29. If you have any questions about how your personal data is processed (including if you are unsure of which Partners Group entity is the controller), or if you want to exercise the above rights, you may contact Partners Group’s Data Protection Officer by email at DPO@partnersgroup.com.

30. You have the right to complain to the relevant data protection authority in relation to our processing of your personal data.

How will you be informed of the changes to our Privacy Notice?

31. We may modify or amend this Privacy Notice from time to time and you are advised to visit our candidate platforms regularly to check for any amendments. You will be informed of any amendments through updates to this Privacy Notice available on our candidate platforms or otherwise in accordance with applicable laws. This Privacy Notice has an effective date as shown at the end of the document.

Effective Date 20 April 2024