People of BT privacy policy

Information on the processing of personal data within the People of BT application for the fulfillment of employment formalities at Banca Transilvania

Version applicable from 01.01.2023

I. Who is the controller of the personal data and the data subjects

This information note is addressed to candidates who, following an application for a position with Banca Transilvania ("the bank", "BT"), are offered to become BT employees. The Bank makes available to these selected candidates the possibility to access the job offer and complete certain employment formalities via the People of BT mobile application ("the Application"). The use of the Application involves the processing of personal data and, if you use it, you are the data subject of such processing. If you fill in personal data in the App/ upload documents with personal data of other natural persons (e.g. your children and/or spouse) and they are data subjects of the processing.

The processing of personal data is carried out by the operator Banca Transilvania, S.A.  with the registered office in Cluj-Napoca, str. Calea Dorobanților, nr. 30-36, Cluj County, registered with the Trade Register under no. J12/4155/1993, unique code RO 5022670, contact phone: 02648028.

We hereby inform you which personal data we are going to collect through the application, for what purposes and on what grounds we process them, to whom we disclose them, for how long we keep them and what rights the data subjects have in this processing. If we revise this notice, we will inform you within the application.

We remind you that as a candidate for BT positions, we process your personal data as stated 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/politica-prelucrare-si-protectie-date-personale.

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 the Policy of Banca Transilvania S.A. and of the other entities of the BT Financial Group regarding the processing of the personal data of their employees, 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 to process it

If you decide to use the App to fulfill some of the employment formalities at BT, we will process your personal data that you enter into it based on the following grounds:

• the legal obligations to which BT is subject under the Labour Code and other applicable legislation in the field of labour relations, financial-banking or taxation;
• completing the necessary steps in order to conclude your employment contract with BT;
• the legitimate interest of the bank (e.g. for your identification/authentication in the Application, in view of our legitimate interest in fraud prevention and to prevent disclosure of your personal data contained in the offer to unauthorized persons; to remind you of certain important information, such as dates when you have appointments for occupational medicine or for signing the employment contract, etc.);
• your consent, for the processing of data from the Fields of the Application whose completion is optional. You can also complete the formalities available in the App if you decide not to complete this data.

If you do not want us to process your personal data within the Application, you can go through the employment 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 legislation that is applicable to us obliges us to collect or that is necessary for the conclusion of the employment contract.

III. For what purposes we process personal data, what is the data and from where we collect it

A. For the purposes of ensuring the security of the Application and preventing fraud, we process your personal data as follows:

1. to identify you as a user of the App

In order to be able to use the App, we must verify your identity, to make sure that we send the job offer and collect the necessary data for employment from the candidate we have selected. We make this identification based on the e-mail address and the phone number declared by you during the recruitment process (usually in the CV). We'll check if you have access to these contact details, including whether 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 access it whenever you want based on a user ID (which is the email adreasa) and a password set by you (the original password, which is sent to you by e-mail by BT, you will have to change it after the first login).

2. to prevent fraud and disclosure of data to unauthorized persons

In order to protect your data filled in in the App or found in the documents uploaded to it, we will collect and use data about the phone on which you install your 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 App.

Please note that in order to be able to work, the App will also have permissions to other information on your phone (e.g. permissions to notify you when you do not have an internet connection). These permissions vary depending on the operating system of the phone on which you installed the App and cannot be restricted by BT. Permissions, including those for which your explicit consent as an App user is not required, are detailed in the App's "permissions" section of the Play Store/Apple Store. For permissions that require your consent (e.g. camera, photo gallery), it will be prompted in advance within the App.We assure you that your bank does not have access to all this information in your phone, but only to those files in your phone that you will decide to upload to the App.

B. In order to take the necessary steps for the conclusion of the individual employment contract, we process your personal data thus

1. to provide you with the job offer

As part of the job offer in BT that we provide to you within the Application, we process your name and surname, as well as data about the position you would occupy if you become a BT employee (e.g. the position / title of the job, the direction / department within which you would carry out your activity, the type / duration of the employment contract, duration of the work schedule, income of a salary nature, holidays and other proposed benefits, etc.).

2. to collect data/documents necessary for employment (if you accept the job offer)

In the fields of the Application you will be able to fill in personal data / upload documents with personal data necessary for employment.

If you choose to go through the Employment Formalities through the Application without coming to the bank (appointment for occupational medicine and for signing the employment contract) you need to upload in the application at least the copy of the identity card and the diploma of study.

When uploading documents The application will ask permission to access the storage space of the phone where the documents are located. Banca Transilvania cannot access/read the information or documents stored on the phone used, but only the ones you upload to the Application. 

Find out below what personal data / documents (including the copy of documents) are necessary for your employment and why we need them:

• identity document*

In order to prepare your employment contract, we need your identification data, including being able to prove that we have properly verified your identity. The applicable labor legislation obliges us to keep in your personnel file the documents certifying the legality and correctness of the completion in the register of employees. One of these documents is your ID.

*you will need to upload a picture of your ID card (CI), from where we will automatically retrieve your data through the optical character recognition process. If the data is not retrieved correctly, you will need to contact BT (there is a dedicated button on the App screen that will make it easier for you to contact them). It is mandatory to upload your copy of your ID card in order to be able to schedule an occupational health appointment (mandatory step in the employment process).

• study documents / certificates of qualification

And these documents are mandatory according to the law and are part of the personnel file. If you apply for a driver's position, your driving licence has the value of such qualification certificates.

Other documents that you can upload to the App, if you own them and want to send them to us in this way (if you do not want to upload them to the App, you will have to bring them when you show up for signing the employment contract) are:

• work card or seniority certificate (if you have been employed before)

Based on the data in these documents, your total length of service is established, in order to be able to calculate the number of days of annual leave to which you are entitled according to the law.

We will also ask you to tell us if BT is your first employer because at the 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 present yourself for signing the employment contract you will present us this certificate in original. We have a legitimate interest in collecting data from your criminal record certificate because in the financial and banking field it is essential to make sure that the people we want to hire have a reputation and conduct in society that does not affect the image of the bank and does not create risks for our customers. For some positions, the law applicable to credit institutions obliges us to request this data, including the copy of the criminal record.

• marriage certificate (if applicable)

This document and the personal data contained in it are necessary for us for your employment, only if your spouse does not earn income and you want to declare him/her as a co-insured/dependent person.

• birth certificates for your children (if applicable)

We need a copy of this document (regardless of whether the children are dependent on you or not) in order to be able to apply, according to the obligation we have established by the tax legislation, the deduction from the value of some premiums granted (e.g. the Christmas bonus, Easter bonus, etc.). The document is necessary for this purpose for both your minor children and for the adult children who are continuing their studies, up to and including the age of 26.

Also, if you want to benefit for your minor children from the services offered by the medical service provider presented in the job offer, we will use the data in this document for this purpose as well.

• letter of recommendation

In the application you will find a Letter of Recommendation form. If you have been employed before, it will be useful for us to pass it on to the most recent employer, in order to complete it. Since you have been accepted to a position within a financial institution, where the rigors are very strict, the following information related to your previous professional activity is relevant for us in the hiring process: if your professional performance was as expected for the position held, if your attitude towards superiors and colleagues was a suitable one, if you have been subject to disciplinary sanctions in the last 12 months of your activity, if you have caused material or image damage to the organization for which you worked, if criminal or administrative proceedings have been or are in progress regarding your person in connection with the position you have occupied with the most recent employer.

If you cannot obtain this document from your former employer, when you show up at the signing of the employment contract, we will ask you if you allow us to ask for these references about you directly, in order to complete the recruitment process.

C. for the proper initiation of the employment relationship

• collection of data about personal preferences and image (from profile picture)

If you also agree, we would like us – as an employer– and your future co-workers to know a few things about you, such as how you prefer to be told, what type of chocolate you prefer, other information that you would like the people you will work with to know about you from the beginning, how you look (profile picture) to recognize you when you come to work / on the first day of work.

You are not obliged to provide us with this information either in the App or when you come to sign the employment contract. But we believe that, knowing them, we will be able to prepare a workspace that will be to your liking.

If you decide to upload a profile picture, the App will ask you for permissions to access your device's camera/photo gallery . Depending on the Android/iOS version of the phone you're using, you'll have different ways to grant/deny access.  If you grant access to the camera/photo gallery to upload the photo, you can later remove this permission. In this case, you will not be able to use the functionalities of the App that require the use of the camera, but you will be able to use other sections of it.

Once uploaded, you can delete it at any time.

• transmission of reminders in the App

In order not to miss the necessary appointments for employment (e.g. at occupational medicine, when signing the employment contract) we will send you notifications in the Application when these moments approach , because we have a legitimate interest in the appointments being respected.

• support for using the Application

We have a legitimate interest in contacting you to support you if you fail to complete the employment formalities in the Application. For this, we will use contact details that you have declared to the bank in your CV, such as phone number or e-mail address. You can object to contacting the recruiter for support purposes by communicating this to the recruiter.

All the processed data we have we have from you. The data is not subject to automated decision-making or profiling.

IV. To whom we may disclose the personal data filled in the Application

BT employees who need to know them will have access to the data/documents filled in/uploaded to the Application.

Other destinies of the data are those indicated in the Policy of Banca Transilvania S.A. and of the other entities of the BT Financial Group regarding the processing of the personal data of their employees.

V. How long do we keep the personal data filled in in the Application

The retention period of personal data filled in in the Application differs, as follows:

• If you become a BT employee, the retention periods in the Policy of Banca Transilvania S.A. and of the other entities of the BT Financial Group regarding the processing of the personal data of their employees apply;
• If you fill in the data/documents in the Application but do not become a BT employee (you do not sign the employment contract) we will keep the data for a limited period, until the completion of the recruitment process for the position for which you applied.
  

However, if you have expressed during the recruitment process the option for BT to process your data for any other positions available in BT, the retention periods set out in the BT Privacy Policy, Section C, item 9 apply.

VI. What are the rights enjoyed by data subjects

In accordance with the provisions of the General Data Protection Regulation ("GDPR"), as a person concerned by the processing of 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 delete data, the right to restrict processing, the right to data portability, the right to object, the right to withdraw consent (for data processed on the basis of your consent / consent). You can also find these rights set forth in detail in the provisions of the BT Privacy Policy in section J. 

You can exercise these rights with BT at BT or contact the BT Data Protection Officer (DPO) by sending a request by post to the aforementioned BT headquarters - with the indication - "to the attention of the DPO" - or by electronic means to the e-mail address dpo@btrl.ro.

You also have the right to address to the National Authority for the Supervision of Personal Data Processing (ANSPDCP).