Privacy Notice - EY Trade Connect 2.0

1. Introduction

This Privacy Notice is intended to describe the practices EY follows in relation to the EY Trade Connect 2.0 (“Tool”) with respect to the privacy of all individuals whose personal data is processed and stored in the Tool. This Privacy Notice should be read together with the ey.com Privacy Statement, and in case of any conflict with the ey.com Privacy Statement, the terms of this Privacy Notice will prevail. Please read this Privacy Notice carefully.

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 determine the purposes and means for data processing in its own right (i.e., act as a data controller or in a similar capacity).

The entity that is acting as data controller (or similar capacity) by providing this Tool on which your personal data will be processed and stored is:

For the personal data of EY personnel: The data controller is the EY entity which employs you.
For the personal data of third-party personnel (including EY clients): The data controller is the EY local member firm with which the third party has a relationship.

You can find a list of local EY member firms and affiliates on the ey.com Privacy Statement.

The personal data in the Tool is shared by the above data controller with one or more member firms of EYG (see “Who can access your personal data” section 6 below).

The Tool is hosted on servers in EY Managed MS Azure Data Centres in Amsterdam, Netherlands and Dublin, Ireland.

3. How does the Tool process personal data?

EY Trade Connect 2.0 (`Tool`) is a new platform to support managed services provided by EY related to Global Trade.

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

Personal Data in the Tool is used for registration, authentication, authorization, communication purposes to deliver managed service to EY clients and to record individual user usage data (audit trail). Client confidential information is used to properly classify client products as part of managed service provided by EY to EY clients.
EY relies on the following basis to legitimize the processing of your personal data in the Tool:

Processing of your personal data is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. The specific legitimate interest(s) are conducting client engagements, and Quality and Risk Management, including complying with EY policies.

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you based on the above legitimate interest(s).

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

The Tool processes these personal data categories:

Personal Information Category (Tool users)
1. Identification information: First name or initial and last name
2. Contact information: Email address
Client Information Category
1. 3rd parties: A listing of Vendors, Partners, Suppliers, Customers whom Client deals with
2. Assets: Products
3. Intellectual Property: Methods/Processes (related to technology for classification purposes)
Usage statistics collected by the Tool for individual person
1. number of classifications/work items completed during specific periods of time
2. number of wrong classifications performed
3. time spent on classifications

This data is sourced as follows:

Provided directly by EY Partners, employees or contractors
A feed from other EY systems, including GHRS, myEY and Azure Active Directory
Provided directly by EY clients

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 personal data?

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

External roles:

Client User
Customs Broker
Technical Engineer
Technical Engineer Manager
Governance Manager External

Internal roles:

Requester Internal
Work Buffer Manager
Classifier
Reviewer
Rule Engine Manager
Client Admin
Governance Manager
System Admin
L4 App Support

USER GROUP	LOCATION	PURPOSE	ACCESS	APPROXIMATE NUMBER OF USERS
Client User	Global	Raises classification requests on the client side	Read, Add	Unlimited, dependent on EY Client Requirements
Customs Broker	Global	Raises classification requests on behalf of client	Read, Add	Unlimited, dependent on EY Client Requirements
Technical Engineer	Global	Can be asked by Classifier to provide more details on the products which need to be classified	Read, Add, Edit	Unlimited, dependent on EY Client Requirements
Technical Engineer Manager	Global	Can manage all additional information requests regardless of which engineer they are assigned to	Read, Add, Edit	Unlimited, dependent on EY Client Requirements
Governance Manager External	Global	To control the overall classification process from a client-side and get a summary of the progress by having access to PBI reports	Read	Unlimited, dependent on EY Client Requirements
Requester Internal	India, Argentina, Poland, Philippines, US, China	Raises classification requests on behalf of a client	Read, Add	100+
Work Buffer Manager	India, Argentina, Poland, Philippines, US, China	Decides to whom the classification requests should be assigned	Read	100+
Classifier	India, Argentina, Poland, Philippines, US, China	Performs product/items classification	Read	1k+
Reviewer	India, Argentina, Poland, Philippines, US, China	Quality control level to ensure that classification has been done properly	Read	100+
Rule Engine Manager	India, Argentina, Poland, Philippines, US, China	Responsible for rule configuration and control	Read, Add, Edit, Delete	50+
Client Admin	Global	Responsible for client maintenance	Read, Add, Edit, Delete	20+
Governance Manager	India, Argentina, Poland, Philippines, US, China	To control the overall classification process and track KPI of the team	Read	20+
System Admin	India, Argentina, Poland, Philippines, US, China	To configure and maintain the system level including provisioning new clients	Read, Add, Edit, Delete	5+

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 https://www.ey.com/en_gl/locations). An overview of EY network entities providing services to external clients is accessible here (See Section 2 (About EY) - “View a list of EY member firms and affiliates”). 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.

We transfer or disclose the personal data we collect to third-party service providers (and their subsidiaries and affiliates) who are engaged by us to support our internal ancillary processes. For example, we engage service providers to provide, run and support our IT infrastructure (such as identity management, hosting, data analysis, back-up, security and cloud storage services) and for the storage and secure disposal of our hard copy files. It is our policy to only use third-party service providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and that comply with any applicable legal requirements for transferring personal data outside the jurisdiction in which it was originally collected.

To the extent that personal data has been rendered anonymous in such a way that you or your device are no longer reasonably identifiable, such information will be treated as non-personal data and the terms of this Privacy Notice will not apply.

For data collected in the European Economic Area (EEA) or which relates to individuals in the EEA, EY requires an appropriate transfer mechanism as necessary to comply with applicable law. The transfer of personal data from the Tool to Microsoft Azure is governed by an agreement between EY and Microsoft that includes standard data protection clauses adopted by the European Commission.

7. Data retention

Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “Why do we need your personal data”. Retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.

In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights and for archiving and historical purposes, we need to retain information for significant periods of time.

The policies and/or procedures for the retention of personal data in the Tool are:

The total retention period is defined and will be implemented in accordance with the EY Records Retention Global Policy and the relevant Country Retention Schedule (CRS). Log Data will be retained in accordance with the EY IT Logging Policy.

After the end of the data retention period, your personal data will be deleted.

8. Security

EY protects the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure. Additional information regarding our approach to data protection and information security is available in our Protecting your data brochure.pdf (ey.com) brochure.

9. Controlling your personal data

EY will not transfer your personal data to third parties (other than any external parties referred to in section 6 above) unless we have your permission or are required by law to do so.

10. Your rights in relation to your personal data

Depending on the applicable jurisdiction, you may have certain rights in relation to your personal data, including:

To request details of the personal data EY processes about you and to access the personal data that EY processes about you
To have your personal data corrected, for example, if it is incomplete or incorrect
To restrict or object to the processing of personal data or request the erasure of your personal data
To receive a copy of the personal data which you have provided to EY in a structured, commonly used and machine-readable format which you can re-use for your own purposes (known as “data portability”)
Where you have provided consent to the processing of your personal data, the right to withdraw your consent.
The right to complain to a data protection authority (see section “Complaints”)

If you have any questions about how EY processes your personal data or your rights related to your personal data, please send an e-mail to global.data.protection@ey.com.

11. Complaints

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

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

Certain EY member firms in countries outside the European Union (EU) and the UK have appointed representatives in the EU and the UK respectively to act on their behalf if, and when, they undertake data processing activities to which the EU General Data Protection Regulation (GDPR) and/or the UK General Data Protection Regulation (UK GDPR) applies. Further information and the contact details of these representatives are available below:

EU data protection representative | EY
UK Data protection representative (ey.com)

12. Contact us

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

Terms and Conditions