Information regarding the processing of personal data within the People of BT application for carrying out employment formalities at Banca Transilvania
Version applicable starting from 01.01.2023
Printable version of the information noteI. Who is the personal data operator and the data subjects
This information note is addressed to candidates who, following their application for a position at Banca Transilvania (“banca”, “BT”), are offered to become BT employees. The bank provides these selected candidates with the opportunity to access the employment offer and to complete some formalities for employment through mobile applicationPeople of BT (“Application”). The use of the Application involves the processing of personal data and, if you use it, you are the data subject of this processing. In case you fill in personal data/ upload documents with personal data of other natural persons (e.g. your children and/ or your husband/ wife) in the Application, they are data subjects of the processing.
Processing of personal data is performed by the operator Banca Transilvania, S.A. with the registered office in Cluj-Napoca, Calea Dorobanților street, no. 30-36, Cluj county, registered at the Trade Registry under no. J1993004155124, unique code RO 5022670, contact phone: 02648028.
We inform you through this information note which personal data we will collect through the application, for what purposes and legal grounds we process them, to whom we disclose them, how long we keep them, and what rights the data subjects have regarding this processing. If we revise this information note, we will inform you within the application.
We remind you that as a candidate for BT positions, we process your personal data as mentioned in the BT Privacy Policy, section C, point 9, which you can find on the website www.bancatransilvania.ro or by accessing the following link https://www.bancatransilvania.ro/policy-processing-and-protection-of-personal-data.
At the same time, if you become a BT employee, you will find details about the processing of your personal data in this capacity within Policies of Transilvania Bank S.A. and other entities of the BT Financial Group regarding the processing of their employees' personal data, from the bank's website or which you can access directly at the following link: https://www.bancatransilvania.ro/politica-BT-date-angajati.pdf.
II. On what grounds we process data and what happens if you refuse their processing
If you decide to use the Application to fulfill some of the employment formalities at BT, we will process the personal data you enter therein based on the following grounds:
- the legal obligations to which BT is subject under the Labor Code and other normative acts applicable in the field of labor relations, in the financial-banking or fiscal field;
- following the necessary steps to conclude your employment contract with BT;
- the legitimate interest of the bank (e.g. for your identification/authentication in the Application, considering our legitimate interest in fraud prevention and to prevent disclosure to unauthorized persons of your personal data contained in the offer; to remind you of certain important information, such as the dates when you have appointments for occupational medicine or for signing the employment contract, etc.);
- your consent, for the processing of data from the Application fields whose completion is optional. You can complete the available formalities in the Application even if you decide not to fill in this data.
If you do not wish us to process your personal data within the Application, you can complete the hiring formalities by bringing the necessary documents to the bank. However, you cannot become a BT employee if you do not provide us with the personal data that the applicable legislation requires us to collect or that are necessary for concluding the employment contract.
III. For what purposes do we process personal data, what data are they, and where do we collect them from
A. For the purposes of ensuring the security of the Application and preventing fraud, we process your personal data as follows:
1. for your identification as a user of the Application
In order to use the Application, we need to verify your identity to ensure that we send the job offer and collect the necessary employment data from the candidate we have selected. We perform this identification based on the email address and phone number declared by you during the recruitment process (usually in the CV). We will verify if you have access to this contact information, including if you can enter the password required for the first login, which is sent by email. If you successfully complete these steps, you will become a user of the Application, and you will be able to access it anytime you want using a user ID (which is the email address) and a password set by you (the initial password, which is sent to you by BT via email, will need to be changed after the first login).
2. for the prevention of fraud and disclosure of data to unauthorized persons
To protect your data filled in the Application or found in the documents uploaded therein, we will collect and use data aboutthe phoneon which you install the Application (the token generated by the device, the manufacturer and model of the phone, the type of its operating system), which will be associated with your user account of the Application. If you refuse to grant access to this data, you will not be able to use the Application.
Please note that, in order to function, the Application will have permissions to other information on your phone as well (e.g. permissions to notify you when you do not have internet connection). These permissions vary depending on the operating system of the phone on which you have installed the Application and cannot be restricted by BT. The permissions, including those for which your explicit consent as an Application user is not required, are detailed in the "permissions" section of the Application in the Play Store/Apple Store. For permissions that require your consent (e.g. camera, photo gallery), it will be requested from you in advance within the Application. We assure you that the bank does not have access to all this information on your phone, but only to those files on the phone that you decide to upload in the Application.
B. In order to carry out some necessary steps for concluding the individual employment contract, we process your personal data as follows
1. to provide you with the job offer
As part of the BT job offer we provide you within the Application, we process your name and first name, as well as data about the position you would occupy if you become a BT employee (ex. function/job title, the division/department within which you would carry out your activity, type/duration of the employment contract, working hours duration, salary incomes, leaves and other proposed benefits etc).
2.for collecting data/documents necessary for employment (if you accept the job offer)
In the Application fields you will be able to fill in personal data/upload documents with personal data required for employment.
In case you choose to carry out the hiring formalities through the Application without coming to the bank (appointment for occupational medicine and for signing the employment contract), it is necessary to upload at least a copy of the identity document and the diploma in the application.
When uploading documents, the Application will request permission to access the phone's storage space where the documents are located. Banca Transilvania cannot access/read the information or documents stored on the phone used, but only those that you upload to the Application.
Find out in the following what personal data/documents (including copies of documents) we need from you for your employment and why we need them:
- identity card*
To prepare your employment contract we need your identification data, including that we can prove that we have properly verified your identity. The applicable labor legislation requires us to keep in your personnel file the documents that certify the legality and correctness of the completion in the employee register. One of these documents is your identity card.
*you will need to upload a photo of your identity card (ID), from where we will automatically retrieve the data through the optical character recognition process. If the data is not retrieved correctly, you will need to contact BT (you have a dedicated button on the Application screen that will facilitate contacting). Uploading a copy of the ID is mandatory in order to schedule your occupational medicine appointment (a mandatory step in the hiring process).
- study certificates/qualification certificates
And these documents are mandatory according to the law and are part of the personnel file. In case you apply for a driver position, your driving license holds the value of such a qualification certificate.
Other documents that you can upload in the Application, if you have them and want to send them to us this way (if you do not want to upload them in the Application, you will have to bring them when you come to sign the employment contract) are:
- work booklet or certificate of seniority (if you have been employed before)
Based on the data from these documents, your total length of employment is established in order to calculate the number of annual vacation days to which you are entitled according to the law.
We will ask you to tell us as well if BT is your first employer because upon first employment certain financial facilities are offered according to the law.
- criminal record certificate
In the Application, we will ask you to fill in the number and date of the criminal record certificate, and when you come to sign the employment contract, you will present us with this certificate in the original. We have a legitimate interest in collecting data from your criminal record certificate because in the financial-banking field it is essential to ensure that the people we want to hire have a reputation and conduct in society that does not affect the bank's image and does not create risks for our clients. For some positions, the legislation applicable to credit institutions requires us to request this data, including a copy of the criminal record.
- marriage certificate (if applicable)
This document and the personal data contained therein are necessary for your employment, only if your spouse does not earn income and you wish to declare them as a co-insured person/dependent.
- birth certificates for your children (if applicable)
We need a copy of this document (regardless of whether the children are in your custody or not) in order to apply, according to the obligation established by tax legislation, the deduction from the value of certain bonuses granted (e.g. the Christmas bonus, the Easter bonus, etc.). The document is necessary for this purpose both for your minor children and for adult children who are continuing their studies, up to and including the age of 26 years.
Also, if you wish to benefit for your minor children from the services offered by the medical service provider presented in the employment offer, we will use the data from this document for this purpose as well.
- letter of recommendation
In the application you will find a form of Letter of recommendation. If you have been employed before, it will be helpful to send it to your most recent employer, to be completed. Since you have been accepted for a position within a financial institution, where the standards are very strict, the following information related to your previous professional activity is relevant to us within the hiring process: whether your professional performances met the expectations for the position held, whether your attitude towards superiors and colleagues was appropriate, whether you have been disciplinarily sanctioned in the last 12 months of activity, whether you have caused material or reputational damage to the organization you worked for, whether there have been or are ongoing criminal or administrative proceedings concerning you related to the position you held at your most recent employer.
In case you cannot obtain this document from your former employer, when you come to sign the employment contract, we will ask you if you allow us to request these references about you directly from them, in order to complete the recruitment process.
C. for the proper initiation of the employment relationship
- data collection about personal preferences and image (from the profile picture)
If you also agree, we would like us – as the employer – and your future work colleagues to know a few things about you, such as how do you prefer to be called, what type of chocolate do you prefer, other information you would like those you will work with to know about you from the beginning, what you look like (profile picture) so we can recognize you when you come to hire/on the first day of work .
You are not obliged to provide us with this information either in the Application or when you come to sign the employment contract. However, we believe that by knowing them, we will be able to prepare a workspace that will be to your liking.
In case you decide to upload a profile picture, the Application will request permissions for access to photo camera/photo galleryof the device. Depending on the version of Android/iOS of the phone you use, you will have different ways to grant/deny access. If you grant access to the camera/photo gallery for uploading the picture, you can later revoke this permission. In this case, you will not be able to use the App functionalities that require the use of the camera, but you will be able to use other sections of it.
A profile picture once uploaded, you can delete it anytime.
- sending reminders in the Application
To avoid missing necessary appointments for employment (e.g. occupational health, signing the employment contract) we will send you notifications in the Application when these moments approach, as we have a legitimate interest in ensuring that the appointments are respected.
- support for using the Application
We have the legitimate interest to contact you in order to provide support in case you fail to complete the hiring formalities in the Application. For this, we will use the contact details you declared to the bank in the CV, such as phone number or e-mail address. You can oppose being contacted for support purposes by communicating this aspect to the recruiter.
All the processed data we have we have from you. The data is not subject to automated decision-making processes or profiling.
IV. To whom can we disclose the personal data completed in the Application
The dates/documents completed/uploaded in the Application will be accessed by BT employees who need to know them.
Other recipients of the data are those indicated within Banking Policies of Transilvania Bank S.A. and other entities of the BT Financial Group regarding the processing of personal data of their employees.
V. How long do we keep the personal data filled in the Application
The retention period of personal data entered in the Application varies as follows:
- If you become a BT employee, the retention periods apply from Banking Policy of Transilvania S.A. Bank and other entities of the BT Financial Group regarding the processing of personal data of their employees;
- If you fill in the data/documents in the Application but do not become a BT employee (do not sign the employment contract) we will keep the data for a limited period, until the recruitment process for the position you applied for is completed.
However, if you have expressed during the recruitment process your option for BT to process your data also for any other available positions at BT, the retention periods provided in the BT Privacy Policy, section C, point 9, apply.
VI. What are the rights that data subjects benefit from
In accordance with the provisions of the General Data Protection Regulation (“GDPR”), as a data subject of the processing of certain personal data, you are guaranteed the following rights: the right to be informed (we fulfill our obligation to inform you through this note), the right of access, the right to rectification, the right to data deletion, the right to restrict processing, the right to data portability, the right to object, the right to withdraw consent (for data processed based on your agreement/consent). You can find these rights detailed also in the provisions of the BT Privacy Policy, in section J.
You can exercise these rights at BT or contact the BT data protection officer (DPO) by sending a request by mail to the previously indicated BT headquarters - with the mention - "attention DPO" - or electronically at the e-mail address dpo@btrl.ro.
You also have the right to address the National Authority for the Supervision of Personal Data Processing (ANSPDCP).