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    Processing and Protection of Personal Data as employer

    Information on processing and protecting personal data of employees, job applicants and individuals under service, internship or other contracts.

    KBC Bank Bulgaria EAD (the Bank), registered in the Commercial Register of the Registry Agency under UIC 831558413, having its registered office and principal place of business at: Sofia 1407, 55 Nikola Vaptsarov Blvd, Expo 2000, website: www.kbcbank.bg, phone: 0700 10 000, processes your personal data as a data controller within the meaning of the Personal Data Protection Act and the General Data Protection Regulation. 

    This information aims to outline the approach to lawful processing and protection of your data as part of the activities conducted by KBC Bank Bulgaria EAD as an employer within the meaning of §1(1) of the Additional Provisions to the Labour Code. The information includes the following:

    1. What data we process

    What data we process

    In the course of its activities as an employer, KBC Bank Bulgaria EAD processes various types of personal data of job applicants, employees, individuals under service, internship and other contracts, which are grouped into the following categories.

    Depending on the specific activity and/or the position you hold, KBC Bank Bulgaria EAD processes some or all of the data listed below.

    • Personal information (full name, personal number/date and place of birth, personal number of a foreigner/, nationality, address(es), including country, identity document details, signature specimen, telephone number, email address, customer number, IBAN of customer accounts, etc.) 
    • Economic information (salary, previous place of work, related persons, etc.)
    • Social information (education, qualifications, work and professional experience)
    • Family identity (marital status, kinship, etc.) 
    • Information collected when you use information and communication technologies 
      • IP addresses, online identifiers, username, passwords, log data
      • Location (e.g. from a business mobile phone, IP address)
      • Device-specific information (e.g. hardware model, operating system version, unique device IDs and mobile network data, including phone number)
      • Cookies that can uniquely identify your browser 
    • Communication information (the information we find out about you from correspondence between us) and information about your job performance.
    • Special categories of personal data – biometric data (facial images), health data, data concerning convictions and offences for the purpose of deciding whether to hire you for a certain position or not, where doing so is allowed by applicable law.

    In many cases, we collect and process your data when you are not our employee/individuals under service, internship or other contract, or job applicant, for example:

    • When you are a family member of our employee, e.g. data contained in doctor’s notes for caring for a sick family member, etc.
    • When you are a family member of or person economically related to our employee (administrator within the meaning of §1(1)(1) of the Credit Institutions Act, etc.).
    • Where you have been designated as an emergency contact by our employee.
    • When you are employed by a temping agency and are sent to temporarily work at the Bank as a legal entity – user company (staff leasing).

    In all cases where we have access to and process your data, we undertake to comply with the principles described in this document and the requirements of applicable data protection legislation.

    2. Data sources

    Data sources

    We collect the data mentioned above in the following ways:

    • Information you provide to us.
    • Information provided to us by third parties (e.g. government authorities/institutions, financial institutions, our partners (e.g. recruitment agencies), former employers), persons related to you, etc.).
    • Information available in public registers.
    • Cookies and similar technologies.
    • Internet.
    • Video and audio surveillance and recording in and around the Bank’s locations.
    • Other sources.

    Before providing us with data belonging to a third party, you must ensure you have informed them of this and obtained their consent or have another legitimate reason to do so. You must also provide them with this information, which is applicable to the processing and protection of their data within our organisation.

    In case it is established, with or without the assistance of the competent authorities, that data concerning a third party have been provided without a legal basis or without the consent and/or knowledge of their subject or in another unlawful way, KBC Bank Bulgaria EAD will delete such personal data, making every effort to inform the data subject without delay, insofar as possible.

    3. For what purposes we process your data

    For what purposes KBC Bank Bulgaria EAD process your data

    KBC Bank Bulgaria EAD processes your personal data for the following purposes:

    • To select internal and external job applicants, including for conducting tests as part of the selection process.
    • To identify a job applicant/employee.
    • To conclude an employment, service, internship and/or other contract, sign an amendment thereto and terminate it, submit information to the National Revenue Agency (NRA) and the National Social Insurance Institute (NSII) about the execution of contracts and the payment of social insurance contributions.
    • For the purposes of inspections by the Labour Inspectorate, NRA, NSII, Ministry of Interior, court, internal and external audits.
    • For reporting purposes, e.g. during a check by or at the request of regulatory or supervisory authorities; in connection with the implementation of the work processes, etc.
    • For professional and other training of employees/individuals under service and/or other contracts, as organised by KBC Bank Bulgaria EAD or by third parties hired by the Bank to provide the necessary professional and other qualifications of the employees/individuals under service and/or other contracts.
    • For the preparation and notarisation of powers of attorney of employees/individuals under service and/or other contracts, who have been designated to represent the Bank and/or its affiliates.
    • For the purposes of verifying information in connection with the conclusion of a bank loan and the administration of such loan and/or other products and services provided by the Bank.
    • To ensure access to the Bank’s offices is controlled, including by issuing a security pass for employee access and identification.
    • To comply with regulatory requirements on ensuring workplace health and safety.
      • In connection with monitoring the observance of workplace rules and attendance during work hours.
      • In connection with the calculation and payment of salaries agreed in contracts and according to internal rules and policies.
      • In connection with the administration of absence documents, e.g. holiday leave, sick leave, etc.
    • To keep an employee file and to fulfil all other obligations and rights of the Bank as an employer under the Labour Code and other laws and regulations.
    • For the purposes of the job performance management process.
    • To protect your vital interests or those of another individual.
    • For the purposes of protecting the legitimate interests of KBC Bank Bulgaria EAD (in cases of suspicion of abuse and/or fraud related to the legal relationship between you and KBC Bank Bulgaria EAD; in case of any legal disputes concerning the legal relationship between you and KBC Bank Bulgaria EAD, etc.).
    • To conduct an internal audit at KBC Bank Bulgaria EAD according to the statutory and specific minimum national standards, which are compliant with the International Standards for Internal Audit.
    • To audit the activity of KBC Bank Bulgaria EAD, exercising control and reporting by KBC Bank Bulgaria EAD, including at group level.
    • For the purposes of making travel arrangements for secondments, training, workshops and socially-oriented initiatives.
    • To send you information in paper and electronic form about employment and other legal relationships between you and the Bank.
    • For data quality management in order to correct information in the systems maintained by the Bank and to maintain accurate and up-to-date data.
    • To organize and control over ensuring the security of the Bank its employees and customers and control over the implementation, including by creating physical security systems in accordance with the BNB Ordinance on Organization and Control in Providing Security of Banks and Financial Institutions.
    • To establish, exercise or defend the Bank’s legal claims.
    • To store and archive documents.
    • In connection with the implementation of internal banking procedures and instructions (Code of Conduct, Employee/Applicant Verification Procedure, Procedure for Verification by the Security Department, etc., including with a view to identifying conflicts of interest).
    • For the purpose of authorising employees to conclude investment brokerage contracts with clients in accordance with the regulatory requirements to be met by individuals who directly trade, under contract, in financial instruments and give investment advice on financial instruments.
    • For statistical and analytical purposes (e.g. data processing with a view to improving workplace conditions and the performance of KBC Bank Bulgaria EAD as an employer, in connection with the implementation of work processes, in connection with the preparation of employee professional development plans, etc.).
    • To conduct marketing research (obtain information about brand perception and employee behaviour, needs and expectations in order to improve working conditions, work processes, etc.).
    • To provide and administer employee social benefits approved by the Bank's management (e.g. insurance, vouchers, sports cards, etc.).
    • To participate in corporate events (workshops, conferences, etc.) and charitable initiatives, as well as to promote to internal audiences corporate events held with the participation of Bank employees – photos of teambuilding, sports holiday, Bank anniversaries, trainings, workshops, socially-oriented events, etc.

    4. Direct marketing

    Direct marketing

    For the purposes of creating a personal dialogue with job applicants and our current employees/individuals under service and/or other contracts, we use and process your personal data to inform you of our vacancies and/or latest products and services, to offer you better terms than those already applicable to you or to offer you products you do not use, but we believe would be of interest to you, as well as special offers prepared for employees/individuals under service and/or other contracts (direct marketing).

    If you do not wish to receive marketing messages, you have the right to object to the processing of your personal data for direct marketing purposes in any of the following ways:

    • By written statement submitted at the Bank's office or emailied to call.center@kbcbank.bg, as well as by electronic statement available on the KBC Online Bulgaria e-banking platform. This statement can be obtained at a Bank office or downloaded from the Bank’s website.
    • By calling 0700 1000 (for Vivacom subscribers)/17 21 (for A1 and Yettel subscribers).

    When the Bank receives an objection from you, it will stop processing your data for these purposes. 

    5. Bases on which we process your data

    Bases on which KBC Bulgaria EAD process your data

    KBC Bank Bulgaria EAD lawfully processes your personal data on the legal bases provided for in Article 6 of the General Data Protection Regulation.

    Contract performance

    As an employee/individual under service and/or other contracts/job applicant at KBC Bank Bulgaria EAD, we process your personal data in fulfilment of the contract concluded between us or in order to make arrangements for the conclusion of the relevant contract, as well as staff recruitment is done on this basis.

    Compliance

    In cases where KBC Bank Bulgaria EAD must fulfil a number of statutory obligations provided for in various legislation, both national and EU law, with view to their implementation KBC Bank Bulgaria EAD processes your personal data to fulfil the relevant obligation that applies to it, e.g. to submit information to the NRA and NSSI on the conclusion, amendment and termination of an employment contract and information concerning the payment of social insurance contributions, workplace health and safety, etc.

    Legitimate interest 

    In many cases your data is processed on the basis of the legitimate interests of KBC Bank Bulgaria EAD. Before processing your data for these purposes, KBC Bank Bulgaria EAD checks whether a balance has been struck between its legitimate interest and your fundamental rights and freedoms or interests, and if the latter prevail, suspends the processing of your data, unless you expressly consent to their processing. For example, marketing research.

    Consent

    In other cases, for example for the purposes of using discounts and social benefits provided by the Bank and its partners; processing, including by publishing photos featuring you for external use, KBC Bank Bulgaria EAD processes your personal data only on the basis of and after obtaining your express consent.

    6. Third parties to whom we provide personal data

    Third parties to whom KBC Bank Bulgaria EAD provides personal data

    KBC Bank Bulgaria EAD will not provide your personal data to third parties, except to the recipients/categories of recipients listed below and if one of the following circumstances is presented:

    Processing by a sub-processor of KBC Bank Bulgaria EAD

    We provide personal information to affiliates or other trustees, so they can process it for us under a contract concluded between us, based on our instructions and in accordance with the applicable data protection legislation.

    This includes the following third parties who process your data on behalf of KBC Bank Bulgaria EAD:

    • Bulgarian Posts EAD and/or any other entities providing postal services (couriers) for the purposes of communication between us.
    • Potential and existing partners of the Bank for the purposes of the activities carried out by the Bank, including partners of KBC Bank Bulgaria EAD under contracts for legal services, document translation services, etc.
    • Providers of systems/services for the management and support of our activities and the quality of our services, including those related to information technologies, with which KBC Bank Bulgaria EAD has concluded a contract (e.g. marketing and marketing research companies, IT and telecommunications service providers, software suppliers, debit/credit card manufacturers, computer support providers, printing houses, document storage and destruction companies, administrative service providers, back-up service providers, etc.).
    • The mobile operator with which the Bank has concluded a subscription contract for the provision of mobile communication services, TerraCommunications AD and/or any other entity providing telecommunications, SMS, MMS, JAWA or other related services, with which KBC Bank Bulgaria EAD has concluded a contract for the conduct of notification activities.
    • The Occupational Medicine Service, with which the Bank has concluded a contract in order to provide services to employees in connection with the requirements of the Health and Safety at Work Act.
    • Consultants, auditors, affiliates from the KBC Group.
    • Travel agencies, hotel companies, airlines, insurers and insurance brokers in connection with the organisation and implementation of business trips, secondments, workshops, etc.
    • Third parties – training organisers and entities conducting surveys and marketing researches.
    • Recruitment and staff leasing agencies; companies conducting psychological and/or professional tests used in the recruitment process.

    KBC Bank Bulgaria EAD takes the necessary measures to ensure that the persons involved in personal data processing strictly comply with data protection legislation and the instructions of KBC Bank Bulgaria EAD, as well as that they have implemented appropriate technical and organisational measures for personal data protection.

    For the performance of a regulatory obligation

    We share your data with government authorities/institutions, regulators and supervisors (including Bulgarian National Bank, NRA, NSII, Labour Inspectorate, Financial Supervision Commission (FSC), National Security State Agency, courts, prosecutors and investigators, Consumer Protection Commission, Competition Protection Commission, Personal Data Protection Commission, public and private bailiffs, etc.), auditors, companies, organisations or external persons, if we have reasonable grounds to believe that access, use, retention or disclosure is necessary to:

    • Comply with an applicable law or any other binding regulation.
    • Respond to an inquiry made by a supervisory body, regulator or any other government institution in connection with or for the purpose of performing its statutory functions, or an initiated check, complaint, inspection, etc.
    • Detect, prevent or any other actions related to fraud, money laundering, terrorist financing, technical or security issues.
    • Take measures for protection against violations of the rights, property or safety of KBC Bank Bulgaria EAD, our clients/employees/individuals under service or other contracts, or the public, as required and permitted by law.

    For the performance of a contract 

    In connection with the fulfilment of the commitments undertaken by you under the contract concluded between us, we provide your personal data to third parties, without the involvement of which it would be impossible to fulfil the commitments undertaken by the parties to the contract, e.g. potential and existing third party clients of the Bank, for the purposes of the activities carried out by the Bank; notaries, officials from the Notary Chamber of the Republic of Bulgaria, Registry Agency, Central Pledge Register, Central Depository, FSC, Customs Agency, correspondent banks, financial institutions, etc.

    With your explicit consent 

    In addition to the cases listed above, we will share your personal data with companies, organisations or third parties when we have your consent to do so (e.g. to third parties providing social benefits for the Bank’s employees (e.g. insurance, vouchers, sports cards, etc.) with which the Bank has concluded a contract).

    7. What your rights are as a data subject

    Your rights are as a data subject whose data is processed by KBC Bank Bulgaria EAD

    You have the right to:

    • access your personal data processed by KBC Bank Bulgaria EAD and the right to request that KBC Bank Bulgaria EAD correct and update your stored personal data. You can do this by submitting a request in a form approved by the Bank to the following email address: dpo@kbcbank.bg or at any bank office of KBC Bank Bulgaria EAD.
    • Withdraw at any time your consent to the processing and storage of your personal data where they are only processed on the basis of consent (for example, direct marketing, products/services of your partners). The withdrawal of your consent will not affect the lawfulness of the processing of your data carried out so far.
    • Submit a request for the deletion of your personal data stored and processed by KBC Bank Bulgaria EAD where there are no bases for their processing.
    • Request a restriction on the storage and processing of your personal data by KBC Bank Bulgaria EAD and object to the processing.
    • Receive your personal data that you have provided to KBC Bank Bulgaria EAD, in a structured, widely used and machine-readable format, and transfer this data to another controller, where the data are processed on the basis of your consent or in compliance with a contract concluded between you and KBC Bank Bulgaria EAD, as well as where the processing is performed by automated means.
    • lodge a complaint with the Personal Data Protection Commission at the following address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd, phone: 02/91-53-518, email: kzld@cpdp.bg and/or with another supervisory/regulatory authority, when you believe that a violation has been committed in connection with the processing of your personal data by KBC Bank Bulgaria EAD.

    We will respond to all your requests without undue delay, within 30 days of receipt.

    If we are unable to fully process your request within the specified period (due to its complexity, the need for assistance from a third party or the number of requests), we may extend this period and explain the reasons for doing so. In certain cases stipulated by law, KBC Bank Bulgaria EAD may delay, limit or refuse to provide the requested information and/or refuse to correct/delete the data, in which cases you may also exercise your rights through the Personal Data Protection Commission at the following address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd, phone: 02/91-53-518, email: kzld@cpdp.bg.

    8. Data retention period

    Your data retention period

    We will retain your personal data for no longer than 50 years from the year following the year of termination of the relationship between you and KBC Bank Bulgaria EAD. If you do not have a contractual relationship with us, but we process your data on another lawful basis, we will retain your personal data for no longer than 3 years from the year following the year of termination of the relationship in connection with which your personal data were collected. If you have concluded a service or internship contract with us, we will store your data for no longer than 5 years from the year following the year of termination of the relationship in connection with which your personal data were collected.

    If you are an applicant for a job at the Bank and we have processed your personal data in connection with your participation in a recruitment and selection procedure, but we have not entered into a contractual relationship with you, we will store your data for no longer than 6 months from the date on which the bases for their processing cease to exist (e.g. as of the date of completion of the staff recruitment and selection procedure in which you participated), unless you have given your consent to the storage of your data for a longer period.

    We will store your data for the following reasons:

    • To fulfil the statutory obligations KBC Bank Bulgaria EAD has regarding the retention of data on employees and documents proving years of service and payment of social insurance contributions, and accounting information such as payrolls, as well as documents related to the establishment and maintenance of employment, professional and other relationships.
    • To be able to meet your requests for information.
    • To be able to answer your questions and process your complaints.
    • To be able to prove the fulfilment of our commitments to you.
    • To pursue our legitimate interests, such as establishing, lodging and defending legal claims.

    Your data may be stored and processed after the period specified above where they cannot be deleted due to legal, regulatory or technical reasons. This includes cases of litigation or other disputes related to the legal relationship between you and KBC Bank Bulgaria EAD, changes in regulatory requirements regarding the storage of a particular type of information and other objective reasons that require a delay in deleting your data.

    9. Data protection officer

    Data protection officer

    In order to protect your data in the course of their processing by KBC Bank Bulgaria EAD, the Bank has designated and appointed a data protection officer: Nikoleta Atanasova, phone: 02/91985790, 0884 225 200, еmail: dpo@kbcbank.bg

    You can contact the Data Protection Officer on all matters concerning the processing of your personal data and the exercise of your rights under the applicable data protection legislation.

    10. Changes to this information

    Changes to this information

    We will periodically update the text of this document in order to provide you with the most up-to-date and accurate information regarding the processing of your data in accordance with our policy and in compliance with current data protection legislation. You will be explicitly informed of any change via the intranet site of KBC Bank Bulgaria EAD, by email, etc.

    KBC Bank Bulgaria EAD (the Bank) considers the protection of the personal data it processes a top priority.

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