1.1. Processing of personal data in the Credit Bureau System
1.1.a.Legal basis and purpose of data processing in the Bureau of
Credit
The bank is obliged, according to the legal regulations in force, to assess
applicants' ability to repay the loan before concluding a loan agreement.
credit agreement and during its execution. To this end,
processes the information indicated in point 1.1.c below, both in
records and by transmitting them to the Credit Bureau in order to
processing by this institution and their consultation by the Credit Bureau.
any Participant in this system, for the purpose of initiating or carrying out a
credit relationship, as well as for the provision of credit products.
For credit applicants and certain categories of persons in a relationship
with them, the Bank shall, during the analysis stage of a credit application, consult
Credit Bureau System, justifying a legitimate interest in this respect for
to carry out responsible lending activities.
Credit Bureau SA is the private law entity that manages the
Credit Bureau System, in which personal data are processed in
in connection with the credit activity of the Participants.
Participants in the Credit Bureau System are credit institutions,
non-bank financial institutions, insurance companies and credit
which have signed a Participation Agreement with the Credit Bureau and which have signed a
Credit Bureau.
1.1.b. Obligation to provide data and consequences of non-compliance
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The provision of personal data is necessary for the purpose mentioned in
1.1.a. Refusal of the data subjects to provide the data
personal data necessary to achieve the purpose mentioned above will lead to the
the impossibility for the Bank to fulfil its legal obligations in relation to
granting of credit.
1.1.c. Categories of personal data processed in the System
Credit Bureau System
The data processed in the Credit Bureau System are:
- identification data of the data subject: surname, first name, code
personal number, home/residence and correspondence address, telephone
telephone/mobile number, date of birth, country code and passport series/number in
in the case of non-residents;
- data relating to the employer:name and address of the employer;
- data relating to the credit products applied for/granted:
type and name of Participant, type of product, status
product/account, date granted, term granted, amounts granted,
amounts due, due date, currency, frequency of payments, amount paid,
monthly instalment, amounts outstanding, number of instalments outstanding, number of days of
arrears, category of arrears, closing date of the product;
- data relating to events occurring during the period of the
credit product, such as those relating to
restructuring/refinancing, repayment, assignment of the credit agreement
credit agreement, assignment of the claim;
- data relating to relationships with other accounts: information
relating to credit-type products for which the data subject is the
co-creditor and/or guarantor;
- insolvency data: information on
data subjects against whom insolvency proceedings have been opened;
- number of queries: indicates the number of Credit Reports
issued by the Credit Bureau, at the request of one or more
Participants;
1.1.d Recipients of data
The personal data recorded in the Credit Bureau System are
disclosed to Participants in this system, upon request, for the purpose mentioned in
point 1.1.a.
Personal data processed in the Credit Bureau System will not be
disclosed to third parties, with the exception of public authorities and institutions, in accordance with
their competences and applicable legislation, such as the Authority
National Supervisory Authority for the Processing of Personal Data, the Bank
National Bank of Romania, the National Integrity Authority, the courts
courts, notaries public, bailiffs, investigation bodies
criminal prosecution authorities.
1.2. Processing of personal data in the records of Banca Transilvania S.A.
1.2.a. The legal basis and purpose of the processing of personal data
For the purpose of pre-offer and, where appropriate, credit application analysis
made, in accordance with the need to carry out a credit
responsible lending, in addition to the processing of personal data in
system of the Credit Bureau S.A., the Bank processes in its own records
such data on the basis of the legal obligations it must comply with, of
conclusion of the credit/guarantee/assessment/insurance contract, on the basis of
legitimate interest and, where appropriate, with the consent of the data subjects.
1.2.b. Obligation to provide data and consequences of non-compliance
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The provision of personal data is necessary for the purpose of
pre-offer/analysis of a credit application. Refusal to provide data
necessary to achieve this purpose will make it impossible for the Bank to
Transilvania S.A. from fulfilling its legal obligations in connection with the granting of
credit, and the credit application will not be considered.
1.2.c. Categories of personal data processed within the Bank
Transilvania S.A.
The personal data mentioned above as being processed in the system of the
Credit Bureau are processed by Banca Transilvania S.A. and in its own records.
To this data is added information that the Bank learns as a result of
verification of the data subjects in its own records and in databases
public databases such as websites - court portals, ONRC, etc.
1.2.d.Existence of an automated decision-making process, including the creation of
profiling via the BT scoring application
For the purpose of objective verification of compliance with the eligibility conditions
for the pre-offer and, where applicable, the analysis of the credit application - BT processes
in some cases, on the basis of its legitimate interest, personal data
of loan applicants (natural persons and legal representatives of
legal entities) as well as other natural persons participating in the
analysis of the credit application in its own automated system ("credit application").
scoring BT").
In the BT scoring application, data of the following nature are entered and analysed
personal identification data, other data filled in the credit application,
information resulting from checks carried out in the Bank's own records
or in those of the Credit Bureau SA, such as - if the persons concerned by the
this processing receives income in an account opened with the Bank or are
regular customer of the Bank, the level of monthly payment obligations, the history
payment history in the case of other loans contracted with the Bank, etc. Following
analysis of this data/information, the BT scoring application issues a score
which is based on a profile of the borrower/potential borrower
good or bad debtor. The returned score thus determines the credit risk and
probability of future payment of instalments on time.
Based on the score issued by the BT scoring application, to which the result is added
the verification of the relevant personal situation in public databases such as
websites - court portals, ONRC, etc. - the Bank establishes
whether the eligibility conditions set by the Bank are met.
internal regulations and will take the decision of admission or rejection
of the credit application, which is based on the analysis carried out by the Bank's employees.
Bank employees (human intervention).
1.2.e At this stage of the lending process, applicants shall
will be given a form by which they can express their agreement that
the bank to consult the ANAF database, for a limited period - maximum 5 days
working days- regarding the income they have earned, taking into account
that the level of income is an essential element for the determination of
the bank's credit conditions.
Also at this stage, for some types of loan products the Bank wishes to
to consult the records of the Credit Risk Centre, in which case it will send
the credit applicant to complete and sign an agreement form
dedicated.