NOTICE ON THE PROCESSING OF CANDIDATES’ PERSONAL DATA
Data Controller
“NEO Finance”, AB
Legal entity code: 303225546 Registered office address: Ukmergės g. 126, Vilnius Tel.: +370 700 80075 Email: info@neofinance.com
Data Protection Officer
asmenysduomenys@neofinance.lt
This notice is intended to inform you about the conditions under which your personal data are processed as a candidate for a vacant position at “NEO Finance”, AB (hereinafter – the Company). The Company processes the personal data of candidates participating in recruitment processes, which are provided by the candidates in their submitted curricula vitae (CVs) and other accompanying documents (cover letters, documents confirming education, qualifications, work experience, etc.).
Purpose of Data Processing
(Why do we need to process your personal data?)
The primary purpose of processing your personal data is the selection and recruitment of employees and interns, namely to assess your suitability for the relevant position and/or duties.
Your personal data are also processed in order to enable us to contact you during the recruitment process (for example, to clarify certain information, invite you to an interview, or otherwise communicate with you in relation to your application).
Legal Basis for Data Processing
(On what basis do we process your personal data?)
Your personal data are processed on the basis of:
- Your consent, expressed by applying for the Company’s publicly announced vacancies and submitting your personal data, including your CV and other documents, to the Company and/or to companies providing job search, recruitment or employment intermediation services.
- the Company’s legal obligation to comply with the requirements set out in the Law on Banks of the Republic of Lithuania, the Law on Payment Institutions of the Republic of Lithuania, and the Regulations on the Assessment of Managers and Key Function Holders of Financial Market Participants Supervised by the Bank of Lithuania, including requirements relating to the impeccable reputation, experience, qualifications and independence of the Company’s managers and other persons performing key functions.
Categories of Data (What personal data do we process?)
Basic information about you as a candidate:
- name (first name, last name);
- contact details (telephone number, e-mail address, place of residence);
- information on education (educational institution, period of studies, obtained education and/or qualifications, including diplomas, certificates, attestations, statements and other documents evidencing such education);
- information on work or professional experience (previous employments, periods of employment, positions held, responsibilities, etc.);
- any other information and data provided by the candidate in their curriculum vitae (CV) and/or other submitted documents;
- conclusions and assessments obtained during interviews with the candidate;
- communication with the candidate (correspondence with the candidate);
- technical data (where documents are submitted by electronic means – IP address, location, device, browser, etc.).
For candidates applying for managerial positions and positions performing key functions, the following additional data are processed:
- data relating to criminal convictions;
- data relating to initiated pre-trial investigations, investigations carried out or previously carried out by law enforcement authorities and/or other authorities or professional bodies, and procedural or other coercive measures or administrative sanctions applied to the candidate;
- information regarding civil claims, administrative or criminal proceedings, investments or assumed risks and loans taken out which may have a material impact on the individual’s financial reliability;
- information on any declared or initiated bankruptcy proceedings of the candidate as a natural person;
- information on whether the candidate has been suspended from or dismissed from office or employment, or has lost the right to engage in certain activities, due to failure to meet statutory requirements of impeccable reputation or due to breaches of legislation regulating the financial market;
- information on any refusal to grant the candidate a permit (license) or otherwise confer the right to perform certain actions or engage in a particular professional or other activity, as well as any suspension or revocation of a granted permit (license) or other right to perform certain actions or engage in a particular professional or other activity;
- information on how the candidate has complied and complies with monetary or other obligations, including data on restructuring or bankruptcy proceedings in respect of the candidate, whether ongoing or concluded, and civil claims brought against the candidate in civil cases;
- information on whether the candidate abuses psychotropic, narcotic or other psychoactive substances or alcohol;
- information about links with other companies, business/commercial activities carried out, and positions currently held or previously held with a financial market participant or other legal entities, for the purposes of avoiding and managing potential conflicts of interest;
- personal, professional or other economic ties with members of the governing bodies or management of the same financial market participant, its parent company or subsidiaries, controlling shareholders, and/or the parent company or subsidiaries.
- Other relevant circumstances (for candidates applying for managerial positions and positions performing key functions).
Data Retention Period (How long will we store your personal data?)
We will process your personal data until the completion of the specific recruitment process and for no longer than one (1) month thereafter.
The retention of your personal data for a longer period than specified in this Notice may take place only where:
- your personal data are necessary for the proper resolution of a dispute or complaint – until the dispute or complaint is resolved;
- there are reasonable suspicions of an unlawful act and an investigation is being carried out – until the investigation is completed; or
- retention is required on other grounds provided for under applicable law.
Source of Data
(Where do we obtain your personal data?)
We process only the personal data that you provide to us directly when you respond to our job advertisement and/or submit your curriculum vitae (CV) and other related documents, as well as any personal data provided during the recruitment process (including during interviews, tests and similar assessments)..
We may also obtain information regarding your application, your CV and other related documents from companies providing job search, recruitment or employment intermediation services.
In certain cases, the Company may also obtain or verify specific information or data by contacting other persons, such as individuals who provide references for you, your former employers (having informed you in advance), or your current employer (having obtained your prior consent).
For candidates applying for the position of the Company’s manager or other positions performing key functions, we may also obtain personal data from state registers and information systems administered by public authorities and/or other entities.
Transfer of Data to Third Parties
(To whom may we transfer your personal data?)
As a rule, we do not transfer or disclose the personal data you provide or that we collect to any third parties. However, in the course of the recruitment process the Company may disclose your personal data to engaged partners (data processors) assisting in the recruitment process and/or carrying out candidate testing, or providing a platform or other recruitment software.
If you apply for a managerial position or a position performing key functions within the Company, we are required, pursuant to applicable legal requirements, to provide your personal data to the Bank of Lithuania, which supervises the Company’s activities.
Prior to any disclosure, we will always contact candidates and inform them accordingly and, where required, request their consent for the disclosure of personal data.
Automated Decision-Making.
Your personal data will not be used for automated decision-making, including profiling
Rights of Data Subjects
(What rights do you have?)
You, as a data subject, have the right to:
- be informed about the processing of your personal data;
- access the personal data processed by the us and obtain information on how such data are processed;
- request the rectification of inaccurate, incomplete or incorrect personal data;
- request the restriction of the processing of your personal data or the erasure of personal data processed by the Company;
- receive the personal data relating to you which you have provided to the Company, where such data are processed by automated means and the processing is based on your consent, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller (right to data portability);
- object to the processing of your personal data and/or withdraw your consent at any time by notifying the Company. You are free at any time to object to your personal data being included and further processed in the Company’s candidate database. You may also withdraw your consent at any time and request that the Company erase your personal data. You may exercise your right to withdraw consent by notifying us in writing or by e-mail at: cv@neofinance.com, or by sending a notice of withdrawal by post. Please note that the withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal; and
- lodge a complaint with the State Data Protection Inspectorate if the Company’s actions or failure to act infringe your rights or violate applicable legal requirements.
If you have any questions regarding the processing of your personal data, you may always contact the Company or the Company’s Data Protection Officer at asmensduomenys@neofinance.lt. More information on the processing of personal data, including how you may exercise your rights, is available in our Privacy Policy at https://www.paskoluklubas.lt/en/page/24/privacy-policy
