Information on the processing of your personal data during the recruitment process

We, “Citadele”, take care of the privacy and protect the personal data of persons who wish to enter into an employment relationship or other legal relationship with us, therefore we provide you with information on the processing of your personal data during the recruitment process.

We provide you with information on the processing of your personal data in “Citadele” companies, i.e. any information which directly or indirectly concerns you, your right to privacy and the protection thereof, as well as your right to the availability of information.

Terms

You – applicant or trainee whose personal data we process.
Citadele or we – AS “Citadele banka”, including the Estonian and Lithuanian branch, IPAS “CBL Asset Management”, AAS “CBL Life”, AS “CBL Atklātais pensiju fonds”, Limited Liability Company “Citadele līzings un faktorings”, OU “Citadele Leasing and Factoring”, UAB “Citadele faktoringas ir lizingas”, Limited Liability Company “Citadeles moduļi”, Limited Liability Company “Hortus Land”, Limited Liability Company “Hortus Residential”, Limited Liability Company “Hortus RE”. 
Processing – any activities we perform with your personal data, e.g. personal data collection, registration, retention, viewing, use, disclosure by sending, disseminating or otherwise making available thereof, harmonisation, deletion or destruction etc.
Document – information on the processing of your personal data during the recruitment process.
Personal Data – any information concerning you, e.g. your name, surname, personal identification number, address, phone number, e-mail address, information included in your CV, your interests.
Consent – any approval that you freely and intentionally give when agreeing to the Processing of your Personal Data for a particular purpose(s).
Regulation – Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Supervisory Authority – an independent authority supervising application of the Regulation in the respective country (in Latvia – Data State Inspectorate, in Estonia – Estonian Data Protection Inspectorate, in Lithuania – State Data Protection Inspectorate).

Who processes your Personal Data?

Your Personal Data is processed by one or several of the following Citadele companies with which you wish to enter into a legal relationship by submitting a corresponding application to the company.

AS “Citadele banka”, Reg. No. 40103303559, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67010000, e-mail: info@citadele.lv, e-mail of the data protection officer: gdpr@citadele.lv

• AS “Citadele banka” Estonian branch, Reg. No. 11971924, registered office: 63/1 Narva mnt., 10152, Tallinn, Harjumaa, Estonia, phone: +372 7700000, e-mail: info@citadele.ee, e-mail of the data protection officer: gdpr@citadele.ee
• AS “Citadele banka” Lithuanian branch, Reg. No. 112021619, registered office: 12 K. Kalinausko Str., Vilnius, Lithuania, LT-03107, phone: +370 852219091, e-mail: info@citadele.lt, e-mail of the data protection officer: dap@citadele.lt
• IPAS “CBL Asset Management”, Reg. No. 40003577500, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67010810, e-mail: asset@cbl.lv., e-mail of the data protection officer: gdpr@citadele.lv
• AAS “CBL Life”, Reg. No. 40003786859, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67010129, e-mail: life@cbl.lv, e-mail of the data protection officer: gdpr@citadele.lv
• AS “CBL Atklātais pensiju fonds”, Reg. No. 40003397312, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67010147, e-mail: pfonds@cbl.lv, e-mail of the data protection officer: gdpr@citadele.lv
• Limited Liability Company “Citadele līzings un faktorings”, Reg. No. 50003760921, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67778777, e-mail: lizings@citadele.lv, e-mail of the data protection officer: gdpr@citadele.lv
• OU “Citadele Leasing and Factoring”, Reg. No. 0925733, registered office: 63/1 Narva mnt., 10152, Tallinn, Harjumaa, Estonia, phone: +372 7700000, e-mail: info@citadele.ee, e-mail of the data protection officer: gdpr@citadele.ee
• UAB “Citadele faktoringas ir lizingas”, Reg. No. 126233315, registered office: 13 K. Kalinausko Str., Vilnius, Lithuania, 03107, phone: +370 852219091, e-mail: lizingas@citadele.lt, e-mail of the data protection officer: dap@citadele.lt
• Limited Liability Company “Citadeles moduļi”, Reg. No. 400003397543, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67778878, e-mail: citadeles.moduli@citadele.lv
• Limited Liability Company “Hortus Land”, Reg. No. 40103460961, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67778000, e-mail: hortus@citadele.lv
• Limited Liability Company “Hortus Residential”, Reg. No. 40103460622, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67778000, e-mail: hortus@citadele.lv
• Limited Liability Company “Hortus RE”, Reg. No. 40103752416, registered office: 2A Republikas laukums, Riga, Latvia, LV-1010, phone: +371 67778000, e-mail: hortus@citadele.lv

Which types of Personal Data do we process?

According to the purposes and to the necessary extent specified in the Terms and Conditions, we process the following sets (categories) of your Personal Data.

Set of Personal Data (categories) Types and description of Personal Data
Your identification data​​​​​​​ Your name, surname, personal identification code, date of birth, your photo.
Your private contact information​​​​​​​ Address of place of residence, phone number, e-mail address.
Information regarding your evaluation as an applicant Curriculum Vitae (CV), application letter and other documents required by legislation for particular position categories. Our written notes during a job interview, an audio recording or a video-conference during a remote job interview. Feedback from your previous employer(s). Information on you verified in publicly available registers (validity of an identity document, information on employment, in separate cases – data on debt history, absence of criminal records etc.). Information on a potential conflict of interest which may arise before entry into an employment relationship in Citadele, upon occupying a position in public administration (information on you and the status of a public officer of your relatives, degree of relatedness, positions in the status of a public officer during the last two (2) years, name of state or local authority, name of structural unit (division, unit, department), job title, date when duties were taken up and resignation date, date until which the position was occupied). Notification regarding recruitment results etc.
Information regarding your professional activity and education​​​​​​​ Information included in your CV: work experience (employers), profession(s), position(s), occupation type(s), length of service; education, language skills, driving experience, additional education (training, courses, workshops, awarded certificates etc.) and other skills; participation in professional and other associations.
Information regarding the provision of communication and effective work organisation by Citadele​​​​​​​ The Personal Data included in correspondence (applications, Consent to data processing etc.) and information produced and retained during communication (via phone and e-mail) in both hard copy and electronic form.
Personal Data of special categories​​​​​​​ Legislation specifies Personal Data of special categories which we will process if the Processing thereof for the respective purpose is permitted by legislation. It is data of special categories revealing race or ethnic origin, religious or other beliefs, political views, health data, participation in trade unions, criminal records.

 

Why do we process your Personal Data and what is the basis of such Processing?

Before we begin the Processing of your Personal Data, we always assess the purposes for which your Personal Data needs to be processed. The Processing of your Personal Data is legitimate if we perform it according to one of the following grounds, i.e., we process your Personal Data:

  • to fulfil statutory obligations imposed on Citadele;
  • based on your Consent;
  • to pursue legitimate interests of Citadele or a third party, assessing beforehand whether the interests to process your Personal Data are consistent with your right to privacy;
  • for the protection of your vital interests or those of a third party;
  • to fulfil a task in the public interest or to exercise official authority, which has been legally granted to Citadele.
Purpose of Processing of your Personal Data Grounds for the Processing of your Personal Data​​​​​​​ Set (categories) of Personal Data, which we process​​​​​​​
Recruitment (internal and/or external) and assessment of suitability for the vacancy​​​​​​​ Pursuing of your legitimate interests or those of Citadele or a third party. During the recruitment process, we select an applicant who is most suitable for Citadele and assess your suitability for the vacancy: Curriculum Vitae, application letters, job interviews, assessment of feedback from previous employer; assessment of potential conflicts of interest, prevention of fraud or other criminal offences against Citadele by the verification of your data in publicly available registers and reliable publicly available information sources according to the internal regulations of Citadele. Your Consent to request feedback from your previous employer(s). Fulfilment of statutory obligations imposed on Citadele. For specific position categories, to ensure a good reputation for Citadele, to prevent the involvement of Citadele in illegal activities, to identify and prevent other risks significant to Citadele, to keep the identity of the customer secret, his/her accounts, deposits and transactions, we assess your suitability for the vacancy in Citadele. Your identification data; your private contact information; information regarding your assessment as an applicant; information regarding your professional activity and education.
Participation in a competition for another vacancy Your Consent to the repeated use of the Curriculum Vitae in another competition. Your identification data; your private contact information; information regarding your professional activity and education.
Processing of received requests and complaints regarding recruitment​​​​​​​ Fulfilment of statutory obligations imposed on Citadele. Your identification data; your private contact information; information regarding the provision of communication and effective work organisation by Citadele.
Satisfaction of claims arising from the recruitment process​​​​​​​ Pursuing of your legitimate interests or those of Citadele or a third party. Citadele protects its rights if a dispute with you arises during the recruitment process. Your identification data; your private contact information; information regarding your assessment as an applicant; information regarding your professional activity and education; information regarding the provision of communication and effective work organisation by Citadele; Personal Data of special categories.
Processing of requests made by state/local/investigative and other law enforcement authorities, as well as other state authorities and public officers specified by legislation​​​​​​​ Fulfilment of statutory obligations imposed on Citadele. Your identification data; your private contact information; information regarding the provision of communication and effective work organisation by Citadele.
Archiving​​​​​​​ Fulfilment of statutory obligations imposed on Citadele. All sets (categories) of Personal Data specified in the Document.

 

How do we obtain your Personal Data?

We obtain your Personal Data:

  • when you submit your data:
    • when responding to a job advertisement (e.g., information from your CV, application letter and other documents requested by and submitted to Citadele;
    • by contacting Citadele or involved partner specialists during the recruitment process, including job interviews via phone, in person at our office, via e-mail and mail;
  • when your Personal Data is made available by job advertisement websites;
  • when your data is submitted by third parties:
    • when recommending you as an applicant for an announced vacancy;
    • by our partners who process your Personal Data on our behalf;
    • based on Citadele request – by providers of public databases and other registers specified by legislation;
    • by state/local institutions and law enforcement authorities and public officers thereof.

Who do we transfer your Personal Data to?

We transfer your Personal Data to:

  • Citadele companies, e.g. based on agreements concluded as part of mutual cooperation;
  • our partners (processors, controllers, common controllers) who are related to the Processing of your Personal Data and whom we have carefully examined before cooperation, e.g. partners who provide support during the recruitment process;
  • providers of databases developed according to procedures specified by legislation (e.g., database of the Information Centre of the Ministry of Interior);
  • in cases specified by legislation – state/local authorities, law enforcement authorities (investigative authorities, prosecutor’s office, subjects of operative activity), courts, Supervisory Authorities (Data State Inspectorate and other authorities), based on written requests or other obligations laid down by legislation, which are binding to the Company, as well as other persons defined by legislation;
  • audit firms, providers of legal services.

Within the Processing of your Personal Data, access to your Personal Data is only provided to employees authorised by us and our partners who require it for the fulfilment of their work duties and process your Personal Data solely for the purpose and on the grounds of Personal Data Processing specified in this Document, complying with technical and organisational requirements of Personal Data Processing defined by Personal Data protection legislation and internal regulations of Citadele.

Do we perform the automated adoption of decisions, including profiling?

When we process your Personal Data for the purposes specified in this Document, we do not adopt automated individual decisions, including profiling.
If we begin such Processing of your Personal Data, we will inform you about it.

Do we transfer your Personal Data outside the EU/EEA?

We ensure the retention of your Personal Data within the territory of the European Union and the European Economic Area.

Taking into account the global nature of business and the technological solutions used to provide the Processing of your Personal Data for the purposes specified by the terms and conditions, your Personal Data may be transferred for Processing to Personal Data recipients outside the territory of the European Union and the European Economic Area, e.g. if services are provided by a partner (processor, separate controller, common controller). Any such international transfer of Personal Data is performed in compliance with the requirements of the Regulation, and in such cases we provide the procedure for Personal Data Processing specified by legislation, as well as a level of protection equivalent to the one established by the Regulation.

For how long do we retain your Personal Data?

The period of retention of your Personal Data without the deletion thereof depends on the Processing purposes and the criteria according to which we consider the period of retention of your Personal Data.

When we determine the period of retention of your Personal Data, we assess the need for the retention of your Personal Data:

  • within different document retention periods established for Citadele by legislation;
  • for pursuing your legitimate interests and those of third parties, after the recruitment process Citadele retains documents submitted by you as a rejected applicant for 6 months, taking into account the potential filing of claims against Citadele according to the procedures laid down by labour legislation;
  • if the Processing of your Personal Data is performed on the basis of Consent, Citadele will retain this Document and the related information for 5 years after the withdrawal of Consent to provide proof of legitimate Personal Data Processing in the previous period.

When considering Personal Data retention periods, we take into account the requirements set out by legislation and guidelines developed by industry associations, if such are applied in the respective country, to determine retention periods of different documents. If during this process, we identify different grounds for the determination of the retention period of your Personal Data, e. g. differences between a retention period specified by legislation and period specified for the protection of our rights exist, these will be sufficient grounds for the retention of your Personal Data for the longest of both periods.

If at least one of the specified criteria applies, we will ensure the deletion or anonymisation of your Personal Data.

What are the consequences if you do not provide us with your Personal Data?

We request you to provide Personal Data, only because we require it for any of the purposes specified in this Document. If you do not provide us with your Personal Data, it might restrict or prevent Citadele’s cooperation with you, e.g. Citadele will be unable to fully assess your suitability for the vacancy, which could prevent you from entering into an employment relationship with Citadele.
We process your Personal Data solely for the respective purpose and to the extent required according to the requirements established by legislation. We do not request you to submit more Personal Data than we require. We also guarantee non-disclosure and safety of your Personal Data.

What are your rights regarding the Processing of your Personal Data?

Within compliance with the requirements established by legislation governing the protection of privacy and Personal Data, we provide you with the following rights upon your written request:

  • to access your Personal Data;
  • to rectify your Personal Data if you have reason to believe that your Personal Data is inaccurate or incomplete;
  • to delete your Personal Data (“right to be forgotten”) if:
    • you believe that your Personal Data is no longer necessary or cannot be used for the initial purposes of Personal Data Processing;
    • if you have a reason to believe that your Personal Data is being processed illegally, e.g. you have not given Consent to Personal Data Processing in the respective case;
    • deletion of your Personal Data is required according to the data retention periods specified for us by legislation;
  • to restrict the Processing of your Personal Data, including the deletion of Personal Data, if:
    • you challenge the accuracy of your Personal Data; the restriction will only apply to the period during which we will be able to verify the accuracy of your Personal Data;
    • you believe that the Processing of your Personal Data is illegal and object to the deletion of Personal Data, requesting to restrict the use of Personal Data; the restriction will only apply to the period reasonably specified by you;
    • we no longer require your Personal Data but it is necessary for you to pursue or protect your legitimate rights and interests, invoke claims etc.; the restriction will only apply to the period reasonably specified by you;
    • you object to the Processing of your Personal Data, which we perform based on our legitimate interests; the restriction will only apply to the period when we repeatedly consider such legitimate interests;
  • to transfer your Personal Data if there are no obstacles to such Personal Data transfer;
  • to object to the Processing of your Personal Data justified by the legitimate interests of Citadele;
  • to refuse the automated individual adoption of decisions, including profiling – during the Processing of your Personal Data for the purposes specified by these terms and conditions we do not adopt automated individual decisions. If we begin such Processing of your Personal Data, we will inform you about it;
  • to withdraw Consent to the Processing of your Personal Data for the specific purpose for which it was provided at any time.

However, you must take into account that such withdrawal of Consent will not affect the legitimacy of Processing of your Personal Data before the withdrawal.

What should you do if you believe that your privacy has been breached?

Citadele certifies that it provides the Processing of your Personal Data according to the requirements of the Regulation, other requirements specified by European Union and national legislation, and this Document. However, if you believe that we have breached your right to privacy by processing your Personal Data, you are entitled to protect your interests by filing a complaint to be handled by the respective Citadele company or Supervisory Authority, or by bringing an action before court.

How can you contact us?

If you have any questions regarding the Processing of your Personal Data, you may contact us by writing to the e-mail address of the respective Citadele company and contact the Personal Data protection officer – you will be provided with all the necessary information regarding the Processing of your Personal Data, including answers to your questions. All the information will be communicated to the responsible employee who will respond to your request.