Internal Privacy Notice

This Privacy Notice is effective as of April 29, 2024.

At Raymond James we recognize the importance of, and are fully committed to protecting, the information we collect about our affiliates, including temporary staff and contractors, as well as applicants, even after the termination of the contractual relationship with Raymond James, where applicable.

This Internal Privacy Notice is issued to you by Raymond James, to explain how, in connection with your affiliation, we process your personal information. Your Raymond James affiliate entity is the entity that is considered the controller with respect to your information.

In this Policy where we refer to "Raymond James", "we" or "us", we mean the entity with which you are affiliated.

This notice includes information about how Raymond James collects, processes, stores and otherwise uses information about you, and about your rights in relation to that information.

Information We May Process About You

"Personal information" means any information relating to you. Raymond James will process and use the following categories and types of information relating to you in connection with your employment, which we describe as "Employee Information":

• Contact and general employment information, such as your name, postal and/or email address, phone number, date of birth, gender and your photo (if you provided it to us);
• Professional information, such as your education credentials and professional qualifications, professional networks, training employment history, board memberships and employment status;
• Other employment information such as government issued identification number, tax status, bank account details, travel and expenses, performance management, emergency contact details, compensation, hours of work, holidays and benefits related information; and
• Communications from company-managed and monitored devices, including email, instant messaging, internet browsers and texts.

In addition to the collection, processing and use of the Employee Information, Raymond James collects, processes and uses the following special categories of personal information about you which we describe as "Sensitive Employee Information":

• Health, welfare, leave of absence and medical information, such as the number of sick days taken and the information contained in a doctor's certificate/medical certificate and details of any known disability/workplace accessibility needs for purposes of salary payment, workforce planning and/or compliance with legal obligations; information on work-related accidents for purposes of insurance compensation, work safety and compliance with legal obligations (such as reporting obligations);
• Criminal and credit records data in the event that Raymond James has conducted or received the results of background checks in relation to you, as permitted by applicable laws;
• Race, gender and ethnicity data, such as information contained in your passport or other citizenship and right to work documentation or information collected for visa and immigration purposes, where required per applicable laws. This also includes information you have voluntarily provided to Raymond James for the purposes of our equal opportunities and diversity monitoring and initiatives or to manage an application, visa or permit on your behalf;
• Marital and familial data where permitted or required by applicable law and you have voluntarily shared it with us, such as marital status, dependents and information contained in your marriage/civil partnership certificate for the purpose of administering name changes and benefits. This also includes information that you have provided voluntarily to Raymond James for the purposes of our equal opportunities and diversity monitoring and initiatives.
• Biometric identifiers, such as fingerprint data and facial geometry scans where applicable;
• Personal, private or sensitive information transmitted, received or stored in any company electronic communications device or system;
• Political contributions data collected for compliance and regulatory purposes;
• Religious accommodation requests, such as requests for time off for religious observance.

Why and How We Collect and Use Your Personal Information

We may collect your personal information in connection with your employment application and employment relationship with us, in connection with another relationship with Raymond James, to get access to our systems, or to work on our premises.

Raymond James needs to process your personal information in order to affiliate with you and perform crucial aspects of your affiliation such as paying compensation, conducting due diligence for safety and security purposes, and providing benefits. There are also statutory requirements and other contractual requirements we have to comply with in relation to your employment as well as business and operational needs we have to meet including:

• Talent development and recruitment purposes, such as talent acquisition for Raymond James and to conduct background screening checks on prospective new hires.
• Managing our professional relationship with you, e.g. to administer benefits programs and wellness initiatives, to record working time, to evaluate employee performance, to manage promotions and talent development, to administer training and awareness activities, to register employee emergency contacts and emergency notifications in the event of business continuity response measures, to determinate incentive and corporate credit card eligibility, to establish worker location, to manage internal transfers within Raymond James and upon off-boarding/termination, and for business travel purposes.
• Compliance and regulatory purposes, e.g. to ensure affiliates meet corporate compliance requirements and policies; to manage, review and respond to complaints, investigations and disciplinary matters; to monitor monetary compensation and/or transactions with clients for fraudulent activity; to establish, exercise or defend legal claims and enforce our terms of use or other legal rights; to comply with applicable laws (such as tax deductions and declarations), regulations and requests from governmental agencies, and to adhere to industry standards.
• Access Controls, Information Security, Acceptable Usage purposes and Fraud Detection and Prevention, to ensure the security and integrity of Raymond James facilities, IT systems and appropriate usage of such systems by affiliates.

Raymond James will generally only process your Sensitive Employee Information for the following Processing Purposes: 

• Salary payment, workforce planning, leaves administration, compliance with legal obligations, and insurance claims and compensation, which may require health and medical data, such as the number of sick days and the information contained in a doctor's certificate/medical certificate, information on work-related accidents, information on disability and information on maternity and parental leave.
• Criminal and credit records background checks, in relation to you, where permitted or required by applicable laws.
• Equal opportunities monitoring and diversity monitoring and initiatives may involve us using race, gender, and/or ethnicity data such as information contained in your passport or other citizenship and right to work documentation or information collected for visa and immigration purposes, or other diversity statistics where this has been provided voluntarily to Raymond James.

If we are not able to carry out the processing activities described in this Privacy Notice we may not be able to affiliate or continue affiliating with you.

Sources of Information

In most cases, Raymond James will collect information directly from you, although sometimes we will obtain information about you from alternative sources including but not limited to: other affiliates and service providers (such as recruitment agents and background check vendors); IT data collected through your use of Raymond James’ equipment, systems, VPN, or networks; and government bodies where required by law (such as tax authorities).

If the requested information is not provided, we may be unable to conduct certain business operations or comply with applicable requirements.

Sharing of Personal Information

As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, Raymond James has implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Privacy Notice.

Between Raymond James controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, Raymond James uses suppliers located in various countries to collect, use, analyze and otherwise process personal information on its behalf.

Where appropriate, Raymond James may also share your personal information with partners, prospective or current financial advisors, or prospective or current clients in connection with transactions, providing services, collaboration in connection with business projects or in connection with their advice or assistance.

If Raymond James decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is Raymond James’ practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order or legal process. In appropriate circumstances, Raymond James may disclose personal information to regulators. We may also share your personal information to protect the rights or property of Raymond James, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

International Transfers

Raymond James operates internationally and may involve transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Where required, Raymond James implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties.

Information Security and Accuracy

Raymond James takes the protection of personal information seriously and we intend to protect your personal information and to maintain its accuracy. Raymond James implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure. Raymond James has established internal policies and instructions in relation to security as located on RJnet.

Retention Period

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing, complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.

How to contact us

If you have a question related to this Privacy Notice, please contact us at Privacy@raymondjames.com. Your message will be forwarded to the appropriate member of Raymond James’ Global Data Privacy & Protection Office.

For the purposes of the EU General Data Protection Regulation (GDPR), the controller of your personal information is the Raymond James subsidiary (legal entity) that is affiliated with you.

Your Rights

You can request to access, update, limit, correct, or delete your personal information in PeopleWorks or by contacting Human Resources at 727-567-4529 or HRDataManagement@RaymondJames.com.

You may have additional rights pursuant to local laws applicable to the processing of your personal information. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (GDPR), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

Right to Lodge a Complaint

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint:

Directly with Raymond James by contacting us via Privacy@raymondjames.com.

With the competent data protection authority. The name and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. 

Changes to our Privacy Statements

We may occasionally update this Privacy Notice, as well as any other specific privacy statement. When making changes to this Privacy Notice we will add a new date at the top of this Privacy Notice.