Who processes your personal data?
Your personal data are processed by the controller – insolvent AS PNB Banka (hereinafter – the Bank). Bank’s contact information – address: Riga, 15-2 Elizabetes Street (Latvian: Elizabetes iela 15-2), LV-1010, e-mail: personnel@pnbbanka.eu; phone: 67011577.
How the Bank ensures lawfulness of your personal data processing?
Your personal data are being processed based on the European Union General Data Protection Regulation, Personal Data Prcessing Law of the Republic of Latvia, special legal norms included in various laws and regulations of the European Union and the Republic of Latvia (e.g. Labour Law, Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing), the Bank’s Employee and Candidate Data Processing Policy, the Bank’s Provisions for Employee and Candidate Data Processing, and other Bank’s regulatory documents.
The laws and regulations provide that the Bank has the right to process your personal data only if it: (i) has determined the purposes of such personal data processing first, (ii) has determined the amount of your personal data required to accomplish the set objective first, (iii) has a legal basis to process your personal data and (iv) has provided you with information on your rights within the context of personal data processing.
Normally, upon recruitment the Bank processes your personal data relying on the following:
1. serving the Bank’s legitimate interests;
2. the necessity to fulfil a legal obligation applicable to the Bank;
3. implementing activities at your request prior to conclusion of an agreement, to which you are a party;
4. your consent to processing of your personal data for one or several specific purposes.
When the Bank has legal interest to process your personal data that is based on serving legitimate interests of the Bank, your personal data are processed taking into account your interests or fundamental rights and freedoms that require protection of personal data.
The Bank also processes special category data, such aspersonal data revealing political opinions, trade-union memberships, health data, and information on criminal convictions and offences or related security measures. The Bank has the right to collect and process special category data only with your consent, except for the cases when the laws and regulations explicitly allow or oblige the Bank to collect and process such personal data. This being the case, the Bank will process the special category data relying on:
1. significant public interests arising from the laws and regulations of the European Union or the Republic of Latvia that are proportionate to the purpose advanced, considering the essence of the rights to data protection and providing for appropriate and specific measures for the protection of your fundamental rights and interests;
2. the necessity to establish, exercise or defend legal claims.
In the table below, please find the purposes, legal basis and the Bank’s legitimate interests in processing your personal data:
| Reasons why the Bank processes your personal data: |
Legal basis for processing your personal data: |
The Bank’s legitimate interests when processing your personal data: |
| Ensuring of recruitment process |
- to manage business relationships with a candidate during the recruitment process;
- to hold recruitment activities;
- to communicate throughout the recruitment process with a candidate or a reference provider specified by him.
|
- legitimate interests of the Bank or a third party;
- holding of activities prior to conclusion of an agreement;
- fulfilment of a legal obligation applicable to the Bank;
- candidate’s consent.
|
- collecting, summarizing, analysing and evaluating information about a candidate’s suitability for the vacant position;
- maintaining accurate and updated information in the Bank’s information systems, databases and registers;
- obtaining your consent when the Bank needs it to communicate with you or your reference provider during the recruitment process;
- ensuring efficiency as the Bank fulfils its legal or contractual obligations.
|
| Improvement of recruitment process |
- to monitor the way the Bank works with candidates or the way other service providers, which assist the Bank in ensuring the recruitment process, work on the instructions of the Bank.
|
- holding of activities prior to conclusion of an agreement;
- legitimate interests of the Bank or a third party;
- fulfilment of a legal obligation applicable to the Bank.
|
- ensuring efficiency as the Bank fulfils its legal or contractual obligations.
|
| Management of recruitment process |
- to hold activities related to the recruitment process – manage stages of the process, incl. communication with the Bank’s structural units, summarize and provide different kinds of information;
- to collect and summarize different kinds of information, facilitating the recruitment process;
- to hold activities related to drafting an agreement with the candidate.
|
- holding of activities prior to conclusion of an agreement;
- legitimate interests of the Bank or a third party;
- fulfilment of a legal obligation applicable to the Bank.
|
- ensuring efficiency as the Bank fulfils its legal or contractual obligations.
|
| Security and risk managementa |
- to identify, investigate and report crimes, as well as to attempt to prevent them;
- to manage the Bank risks;
- to comply with the laws and regulations and other regulatory framework applicable to the Bank;
- to be capable of responding to and resolving complaints;
- to be capable of protecting the Bank’s interests in court proceedings.
|
- holding of activities prior to conclusion of an agreement;
- legitimate interests of the Bank or a third party;
- fulfilment of a legal obligation applicable to the Bank.
|
- developing and improving functionality of the activities that the Bank is carrying out to prevent crimes, as well as developing and improving the enforcement of legal obligations applicable to such activities;
- ensuring efficiency as the Bank fulfils its legal or contractual obligations;/span>
- implementation of actions related to the possible filing of a lawsuit or enforcement of a defence in court proceedings.
|
| Management of special category data |
- to carry out activities related to significant public interests.
|
- by using special category data, the Bank shows and certifies that it has correctly appreciated your compliance with job requirements within the recruitment process.
|
What personal data are processed by the Bank?
In order to ensure the Bank’s activity, its employees should meet the requirements of professional qualification, knowledge, experience, and personal qualities. Initially, compliance with the raised requirements is evaluated within the reqruitment process, whereby the Bank uses differend types of personal data. Personal data processed by the Bank are grouped into categories for the Bank to be able to manage them in the most efficient way and for you to be able to see the amount of information about candidates managed by the Bank. The Bank does not use all personal data the same way – certain types of personal data are useful for evaluating a candidate’s professional knowledge,, other – for evaluating personal qualities or for fulfilment of the Bank’s legal obligations. At the same time, the Bank assures candidates that personal data controlled by the Bank are processed according to the highest security standards in the field of personal data processing.
| Personal data categories |
Description |
| Basic (identification) data |
Name, surname, identity number, date of birth, picture, language of communication, etc. |
| Professional activity records |
Documents (information) on education and professional qualifications (trainings), job interview notes, resumes, application forms, references, evaluations, etc. |
| Tele- and e-communication data |
Traffic data, location data, identification information, etc. |
| Special category data |
Health data, a.o. |
| Data collected upon fulfilling legal obligations |
Information collected at the request of state institutions, a.o.. |
How the Bank obtains your personal data?
1. Personal data you provide to the Bank yourself:
- when you apply for the job competition – from your application, motivation letter, CV (description of the course of professional life), and documents attached thereto;
- when you contact the Bank and speak over the telephone with the Bank’s HR representative or meet the Bank’s HR representative at a job interview incl. from records of telephone conversations or notes made by the Bank’s HR representative during the meeting, whenever applicable from video usrveillance devices;
- when you use the Bank’s homepage, mobile applications, online conversations, etc.;
- from your e-mails and letters delivered by post or by courier;
- from your applications, proposals, and other submitted documents.
2. Personal data the Bank obtains from third parties (incl. external databases)
- Recruitment service providers, such as SIA CV-Online Latvia;
- social networks (e.g. by clicking on one of our Facebook or Google ads);
- Bank’s representatives or other third parties that process personal data on behalf of the Bank on the instructions thereof;
IMPORTANT: The persons or organisations mentioned herein support the Bank in maintaining, for instance, its IT infrastructure, as well as advise the Bank on opportunities for recruitment process development.
- reference providers, former employers;
- state (incl. law enforcement) authorities.
How long the Bank stores your personal data?
Normally, the Bank has the right to store your personal data for 2 years from the end of job competition (i.e. including the result announcement term), unless there is another statutory data storage term. The Bank complies with this general personal data storage term in order to:
- respond to questions or complaints, or demonstrate that the Bank has prudently fulfilled its commitments to you;
- conduct the Bank’s in-house research;
- meet statutory requirements for storage of various types of documentary information.
IMPORTANT: Storage period of certain categories of personal data (incl. documents containing personal data) may be shorter than 2 years. Upon expiry of the data storage term, your personal data are destroyed in a secure way.
What are possible consequences of refusing to provide your personal data (or other information) when requested by the Bank?
The Bank may need your personal data (or other information) to meet statutory requirements, or to conlude an agreement with you. If you decide not to provide information (incl. personal data) requested by the Bank, this may curtail the Bank’s capacity to evaluate your suitability for the vacant position, or delay or preclude the Bank from fulfilling legal obligations applicable thereto as required by laws and regulations.
IMPORTANT: The Bank may request you to submit information that it finds useful for the purposes other than execution of the Bank’s legitimate interests, fulfilment of legal obligations applicable to the Bank, or implementation of activities prior to conclusion of an agreement. If in the abovemebtioned cases the Bank requests you to provide information about yourself, the Bank will first inform you about the purposes of suchpersonal data processing and will explain, whether you are obliged to provide such additional personal data (or any other information), as well as the effects it will have on you.
What are your rights as to processing of your personal data?
You have the following rights:
1. to access and forward your personal data ; in particular:
- to obtain additional information about the processing of your personal data irrespective of what type of information you already have;
- to receive an electronic copy of your personal data processed by the Bank.
IMPORTANT: The Bank is not obliged to provide candidateswith the copies of documents at the Bank’s disposal, and the Bank does not provide candidates with the information that contains third party data. The Bank may provide you with a copy of your personal data in an electronic form, which you may reuse, incl. submit to other institutions or request the Bank to forward.
2. to amend or delete your personal data:
- you are entitled to amend your personal data, if there has been a change thereto, or if you have grounds to believe that your personal data processed by the Bank are inaccurate.
IMPORTANT: The candidate is responsible for precision, accuracy, and validity of the submitted personal data (or other information). The Bank may not amend a candidate’s personal data at its own discretion, as well as to search at its own discretion for a candidate’s personal data in third party databases to maintain accuracy and relenace of its databases.
- You may request the Bank to delete your personal data, and the Bank will do so, if it no longer needs these personal data to serve the purposes the data were collected or processed for.
IMPORTANT: The Bank will not be able to delete a candidate’s personal data if the laws and regulations provide for a legal obligation to store such personal data or the Bank’s legitimate interests override a candidate’s rights infringed by non-deletion of the data.
3. to limit processing of your personal data:
- you may request the Bank to limit processing of your personal data (or certain processing activities), meaning that the Bank could store and process your personal data only to establish, exercise or defend the Bank’s legal claims. You are entitled to limit the processing of your personal data if: (i) the data are inaccurate, (ii) the data are processed unlawfully, but you do not want to delete them, (iii) data processing is no longerrequired, but you want to establish, exercise or defend your legal claims, (iv) you have already exercised your right to object to processing of your personal data but you await the Bank’s opinion on whether the latter is entitled to continue processing your personal data based on the legitimate interests of the Bank or a third party.
IMPORTANT: By exercising the right to limit processing of your personal data, processing of your personal data within the recruitment process could be temporarily curtailed – i.e. the Bank might be unable to evaluate your compliance with the requirements of the vacant position and make a relevant decision.
4. to object to processing of your personal data:
- you are entitled to object to processing of your personal data if such processing pursues the Bank’s or a third party’s legitimate interests, and your rights, interests and freedoms override the aforementioned legitimate interests of the Bank or a third party.
Does the Bank process your personal data, taking automated individual decisions?
The Bank does not use automated systems in making decisions concerning you.
Whom can your personal data be transferred to?
During the recruitment process, your personal data are processed by the Bank’s HR Department employee. The Bank did not outsource candidate evaluation within the recruitment process, therefore your personal data (incl. other information) are processed exclusively by the Bank.
The Bank may forward your personal data (incl. other information):
- to the Bank group’s companies – if you have applied to a vacant position at one of the Bank Group’s companies.
IMPORTANT: The Bank processes candidates’ personal data through various information systems, whose technical maintenance may be outsourced on the instructions of the Bank to personal data processors. In addition, notifications on job competitions (job ads) are published on www.cv.lv, managed by SIA CV-ONLINE Latvia.
Are your personal data communicated beyond the European Union or the European Economic Area?
The Bank does not transfer your personal data (incl. information about you) beyond the European Union or the European Economic Area within the recruitment process.
What regulatory documents of the Bank govern processing of your personal data?
Your personal data processing is governed and your rights in the field of protection and legality of processing of personal data are protected by:
- the Bank’s “Employee and Candidate Data Processing Policy”(effective from May 25, 2018);
- The Bank’s Provisions for Employee and Candidate Data Processing (effective from May 25, 2018).
Are you entitled to file a proposal or a complaint?
The Bank is the responsible controller of your personal data. To demonstrate clearly that the Bank performs a lawful, fair and transparent processing of your personal data, the Bank has created and maintains an accountability system that is based on:
1. timely informing of candidates about processing of personal data and enforcement of candidates’ access rights;
2. assessment of the impact of personal data processing, if the planned activities related to such personal data processing jeopardize your rights and freedoms, as well as on registration of personal data processing activities;
3. timely detection and comprehensive investigation of security incidents related to personal data protection, as well as reporting of personal data protection breaches to the Data State Inspectorate and candidates;
4. transparent cooperation with service providers ensuring candidates’ personal data processing on the instructions of the Bank;
5. regular training of the Bank’s employees, and compliance assessment of the personal data protection system and legality assessment of personal data processing.
However, if you have any suggestions or objections regarding processing of personal data performed by the Bank, you may file a proposal, a feedback, an application or a complaint. You may file an application or a complaint as you find most convenient:
- by sending an electronic document to the Bank’s e-mail dati@pnbbanka.eu, ensuring that the application is signed in accordance with the statutory requirements as to electronic document preparation;
- by filing in person in paper format at the Bank’s office in Riga, 15-2 Elizabetes Street (Latvian: Elizabetes iela 15-2), ensuring that the application is signed;
- delivering by post (incl. by courier) in paper format to the Bank’s correspondence address in Riga, 15 Elizabetes Street (Latvian: Elizabetes iela 15-2), LV-1010, ensuring that the application is signed.
Apart from the above, you have the right to file a complaint to the Data State Inspectorate regarding non-compliance of personal data processing performed by the Bank with the statutory requirements as to personal data protection. A complaint may be filed to the Data State Inspectorate:
- by placing it in the mail box of the Data State Inspectorate in Riga, 11/13 Blaumaņa Street (Latvian: Blaumaņa iela 11/13), 1st floor;
- by sending it electronically (according to Section 1(2) of the Electronic Documents Law, signed with a secure electronic signature) to the e-mail address info@dvi.gov.lv;
- by sending it by post to 11/13-15 Blaumaņa Street (Latvian: Blaumaņa iela 11/13-15), Riga, LV-1011.
+371 67041100 (I-V 9:00-13:00)