Information about processing of personal data during the recruitment process
Your personal data are processed by a controller – AS PNB Banka (hereinafter – the Bank).
Bank’s contact information – address: Riga, 11 Raiņa Boulevard, LV-1050, e-mail: email@example.com; phone: 67011577.
Data Protection Officer – address: Riga, 11 Raiņa Boulevard, LV-1050, e-mail: firstname.lastname@example.org; phone: 67011410.
Your personal data are being processed based on the European Union General Data Protection Regulation, Law of the Republic of Latvia on the Processing of Personal Data, special legal provisions included in various laws and regulations of the European Union and the Republic of Latvia (e.g. Labour Law, Credit Institutions Law, Law on the Prevention of Money Laundering and Terrorism Financing), Bank’s Data Processing Policy in Respect Employees and Candidates, Bank’s Data Processing Regulations in Respect Employees and Candidates and other Bank’s regulatory documents.
The laws and regulations provide for that the Bank is entitled to process your personal data only if (i) the Bank has established in advance the purposes of processing of your personal data, (ii) the Bank has established in advance the amount of your personal data required to accomplish the pre-determined purposes, (iii) the Bank has a legal basis to process your personal data and (iv) has provided you with the information on your rights with regard to the processing of personal data.
The Bank processes your personal data according to the standard procedure of the recruitment process based on the following:
(a) consideration of legitimate interests of the Bank;
(b) necessity to fulfil a legal obligation applicable to the Bank;
(c) taking measures at your request prior to conclusion of an agreement you are a party to;
(d) your consent to the processing of your personal data for one or several specific purposes.
In cases when the Bank has a legitimate concern to process your personal data, based on observance of the Bank’s legal interests, your personal data are processed taking into account your interests or fundamental rights and freedoms, which require the protection of personal data.
Requirements of the laws and regulations oblige the Bank to process the special categories of data according to special procedure – i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; genetic data and biometric data, obtained to perform unique identification of a natural person, health data or data concerning sex life or sexual orientation of the individual, as well as data on convictions and offences or related security measures. The Bank has the right to obtain and process the special categories of data only with your consent, except for the cases when the laws and regulations directly allow or oblige the Bank to obtain and process such personal data. In the cases above, the Bank will process the special categories of data based on the following:
(a) significant public interests arising from the laws and regulations of the European Union or the Republic of Latvia that are proportionate to the purpose pursued, considering the essence of the data protection rights and providing for appropriate and specific measures for the protection of your fundamental rights and interests;
(b) the necessity to establish, exercise or defend the legitimate requirements.
Please see below the purposes, legal basis and the Bank’s legitimate interests in the processing of your personal data:
To allow the Bank to ensure its clients the continuing high quality of financial and other services it provides, the Bank’s employees should meet the requirements set in respect of the professional qualification, knowledge, experience and personal qualities. Conformance to the set requirements is initially assessed during the recruitment process during which the Bank uses various types of personal data. The personal data processed by the Bank are grouped into categories to allow the Bank to manage them in the most efficient way and to allow you to see the amount of the information about candidates managed by the Bank. The Bank does not use all personal data in the same way – some types of personal data are suitable for assessment of the candidate’s professional knowledge, while others – for assessment of the candidate’s personal qualities or for fulfilment of legal obligations applicable to the Bank. At the same time, the Bank guarantees to the candidates that the personal data, managed by the Bank, are being processed according to the highest security standards regarding the processing of personal data.
(1) Personal data provided to the Bank by yourself:
(2) Personal data obtained by the Bank from third parties (incl. external data bases):
IMPORTANT: This is a reference to the persons and institutions that the Bank uses to help the Bank, for instance, with the maintenance of IT infrastructure, as well as which advise it on the development and improvement possibilities of the recruitment process.
According to the general procedure, the Bank is entitled to retain your personal data for 2 years as from completion of the recruitment competition (i.e., including the term for announcement of the competition results), unless the laws and regulations prescribe for other personal data retention period. The Bank complies with the general retention period for client’s personal data:
IMPORTANT: Various categories of data (including categories of documents, containing personal data) may have the retention period that is less than 2 years. Upon expiry of the retention period your personal data are destroyed in a secure way.
The Bank might need to obtain your personal data (or any other information) in accordance with the requirements of the laws and regulations, or to enable the Bank to conclude an agreement with you. If you choose not to provide the information (incl. personal data), requested by the Bank, it may limit the Bank’s possibilities to assess your conformance to the requirements of the vacancy, or delay or preclude the Bank from fulfilling legal obligation applicable thereto according to the requirements of the laws and regulations.
IMPORTANT: The Bank may request you to submit information that it finds suitable for the purposes other than serving the Bank’s legitimate interests, fulfilling legal obligations applicable to the Bank or carrying out measures prior to conclusion of an agreement. If in such cases the Bank requests you to provide information about yourself, the Bank will inform you in advance regarding the purposes of processing of your personal data and will explain separately whether it is mandatory for you to provide these additional personal data (or any other information) and how it will affect the delivery of service to you.
You have the following rights:
(a) to access your personal data and forward them
IMPORTANT: The Bank is not obliged to provide a candidate with copies of the documents at the Bank’s disposal, and the Bank does not provide a candidate with the information that contains data of a third party.
(b) to amend or delete your personal data
IMPORTANT: The candidate is liable for accuracy, precision and veracity of his/her personal data (or another information) provided. The Bank is not entitled to amend at its discretion the candidate’s personal data, as well as the Bank is not entitled to search at its discretion the personal data of candidate in third parties’ databases with the aim to maintain the Bank’s databases accurate and updated.
IMPORTANT: The Bank will not be able to delete the candidate’s personal data if the laws and regulations provide for a legal obligation to retain such personal data or the Bank’s legitimate interests are more important than the candidate’s rights infringed by non-deletion of the personal data.
(c) to restrict the processing of your personal data
IMPORTANT: By exercising your rights to restrict processing of your personal data, processing of your personal data during the recruitment process may be temporarily restricted, i.e. the Bank might become unable to assess your conformance to the requirements of the vacancy and make the decision.
(d) to object to the processing of your personal data
Does the Bank process your personal data for marketing purposes, in particular, to prepare commercial offers for you?
The Bank does not use your personal data or any other information (including information about other persons, obtained during the recruitment process) for marketing (direct marketing) purposes.
The Bank does not use in the recruitment process any automated systems to make decisions regarding you.
During the recruitment process your personal data are processed by recruitment specialists of the Personnel Department of PNB Group. The Bank has not entrusted assessment of the candidates during the recruitment process to any external organisations, therefore your personal data (incl. any other information) are processed exclusively by the Bank. However the Bank may have to transfer the candidate’s personal data at the request of the public authorities to fulfil the legal obligation applicable to the Bank (for example to supervisory authorities).
The Bank may transfer your personal data (incl. any other information):
IMPORTANT: The Bank processes the candidate’s personal data in various information systems, technical maintenance of which, commissioned by the Bank, may be performed by outsourcers - controllers, attracted by the bank. Likewise, the announcements of vacancy competitions (advertisements) are published on the portal www.cv.lv, maintained by SIA CV-ONLINE Latvia.
The Bank does not during the recruitment process communicate your personal data (incl. information on you) beyond the European Union or the European Economic Area.
The processing of your personal data is regulated and your rights relating to the protection and legality of processing of personal data are ensured by:
The Bank is a responsible controller of your personal data. To demonstrate that the Bank performs a lawful, fair and transparent processing of your personal data, the Bank has created and maintains a system of accountability that is based on the following:
(a) timely informing of candidates about the processing of personal data and exercising of the candidates’ access rights;
(b) assessment of the impact of the processing of personal data if the planned activities related to the processing of personal data might put at high risk your rights and freedoms, as well as on the registration of personal data proceedings activities;
(c) timely detection and comprehensive investigation of safety incidents related to the protection of personal data, as well as reporting on personal data breaches to the Data State Inspectorate and candidates;
(d) implementation of transparent cooperation with the service providers that ensure processing of candidates’ personal data, commissioned by the Bank;
(e) regular training of the Bank’s employees and assessment of the lawfulness of personal data processing and conformity of the personal data protection system.
AS PNB Banka