Personal Data Processing Notice for Candidates for employment at doValue Greece

The controller of your personal data is doValue Greece, a special purpose Société Anonyme for the servicing of receivables deriving from loans and credits pursuant to the provisions of Greek law 4354/2015, duly authorised and supervised by the Bank of Greece (Decision no. 220/2017 of the Credit and Insurance Committee of the Bank of Greece, published in the Government Gazette’s Issue Β’ 880/16.3.2017).

This Notice refers to natural persons who search for a job vacancy within doValue Greece and have expressed relevant interest by sending an application and/or submitting their curriculum vitae along with other information or supporting documentation.

A. Categories of personal data processed by doValue Greece

doValue Greece informs you that it processes personal data included in your job application and in general any information provided by you during the evaluation process carried out for recruitment purposes. This information includes all the information provided through online platforms where you submit your recruitment request, via email, in person during the interview process and/or via any other means. It is hereby noted that not all information listed below does necessarily concern you.

Indicatively doValue Greece processes the following categories of personal data:

i)    Identification data: name and surname, father’s name, identity card and identity card number or passport and passport number, tax identification number, competent tax authority, social security number (in Greek: A.M.K.A.), date and place of birth, sex, foto, family status data, etc.

ii)    Contact data: postal and e-mail address, fixed and mobile telephone number, etc.

iii)  Data related to your education and skills: education level and diplomas, educational institution, seminars, professional certifications, participation in educational programs etc.

iv)  Data related to your work experience: information about your previous work experience, letters of recommendation etc.

v)    Other data that may be required for your recruitment to doValue Greece including data which belong to special categories (e.g. health data) and/or data relating to criminal convictions and offences which shall be collected by you as part of an assessment of your suitability for the coverage of a specific position and data relating to the fulfillment of your military obligations.

vi)    Other data included in your applications for a job offer within doValue Greece as well as information collected as part of the placement process: data related to any affiliation with doValue Greece employees as well as data related to any other employment relationship you maintain or intend to maintain.  

vii)    Information you provide to doValue Greece during telephone or electronic communication with us. doValue Greece may keep a copy of such communication or register the information related to such communication in its records.

viii)  Data derived from your browsing on the online platform through which you submit your application for employment in doValue Greece, including, inter alia, doValue Greece’s website.

Β. Sources from which doValue Greece collects your personal data

doValue Greece collects your aforesaid personal data from the following sources:

i)    Directly from you.

ii)   From other persons (natural or legal) specifically authorized by you, including employment agencies acting on your behalf.

It is noted that doValue Greece is not responsible for any illegal processing of your personal data carried out by employment agencies and third parties in general pursuant to the abovementioned.

iii) From your previous employers, in accordance with the recommendation letters you have provided.

It is noted, that in case you provide doValue Greece with third parties’ personal data, including former employers, collaborators etc. you must have ensured that you have duly informed such third parties with regard to the transfer of their personal data and the processing thereof by doValue Greece, prior to such transfer (indicatively via reference to this Notice of doValue Greece), and that you have obtained their necessary consent, if required.

iv)    From online platforms where you submit your recruitment request. It is noted that these platforms, in some cases, allow doValue Greece to link the data you provide with information about you available to public, which you have published online – this may include sources such as LinkedIn and other social networks. In order to identify potential candidates for the coverage of a specific opening, doValue Greece either itself or through its collaborators, may inspect various social networks accounts, which may include personal data depending on the privacy and security settings you have set on such social network account, and collect personal data from the said sources in accordance with the applicable legislation.

doValue Greece processes your personal data for purposes related to the assessment of your application prior to the conclusion of an employment agreement, for compliance with its legal obligations, for the purposes of the legitimate interests pursued by doValue Greece or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, as well as where you have provided your consent. It is noted that doValue Greece, in principle, is not based on your consent to process your personal data unless this is specifically provided for in the relevant legislation or is required by the circumstances and nature of the specific processing activity. In particular, doValue Greece processes your personal data for the following purposes:

i)   The assessment of your suitability for the job for which you have applied.

ii)  To contact you as part of your evaluation process for recruitment.

iii) To improve the services of finding and evaluating candidates for recruitment in doValue Greece.

iv)    For compliance with any obligations imposed by the applicable legal, regulatory and supervisory framework as well as the decisions of authorities (public, supervisory, prosecutorial, etc.) or courts.

v)    To prevent and detect fraud, or any other illegal act against doValue Greece.

vi)    To contact you in case we organize workshops or presentations, which are related to the work environment or finding a job.

vii)     In the context of exercising the legal interests of doValue Greece or a third party.

viii)    For the exercise of the legal rights of doValue Greece before a court or other authority.

ix)    In order to respond to requests from any future employers for recommendations.

x)    For the purpose of avoiding situations of conflict of interest, indicatively in case of your kinship with an employee of doValue Greece or your parallel employment in a company that has the same object as doValue Greece or with which doValue Greece cooperates.

xi)    Any other cases for which you have given your consent to the processing of your data.

Where doValue Greece has requested and received your consent, the processing of your personal data is based on such consent. In these cases, you have the right to withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on your consent provided before its withdrawal.

It is noted that doValue Greece does not make decisions based solely on automated processing of personal data.

Within the context of the processing of your personal data, doValue Greece may transfer such data to the following recipients:

i)    The management of doValue Greece and/or the competent employees of the General Directorate of Human Resources of doValue Greece, as well as the companies affiliated with the doValue Group to which doValue Greece belongs, based in Greece and in other countries of the European Union, within their responsibilities.

ii)   for the data that doValue Greece is entitled or obliged to disclose by law, court or regulatory decision as well as for the data the disclosure therof is absolutely necessary to satisfy the legal interest of doValue Greece in the public, supervisory, auditing, independent, judicial, prosecutorial, public and / or other authorities or institutions within their legal powers, duties and responsibilities, in insurance funds, trade unions and associations, public officials, lawyers, law firms, notaries, bailiffs, or as the case may be, other third parties.

iii)    To the (natural or legal) persons to which doValue Greece delegates the performance of specific tasks on its behalf (processors), including providers of online platforms and any subcontractors thereof, as well as IT products and/or services providers and/or technical support providers of all kinds of information and electronic systems and networks, including online systems and platforms, companies for storage, filing, management and destruction of files and data, provision of consulting services.

doValue Greece will not transfer your personal data directly to third countries or international organisations, unless such transfer is required by the applicable regulatory or legal framework.

If applicable, doValue Greece may transfer your personal data to third countries under the following circumstances:

i)    Where the European Commission has decided that the third country, a territory or one or more specified sectors within that third country or international organisation ensure an adequate level of protection, or

ii)    If appropriate safeguards have been provided from the recipient, in accordance with the national and European legislation.

In the absence of the abovementioned circumstances a transfer may take place if:

i)    You have provided your express consent to doValue Greece; or

ii)    the transfer is necessary for the performance of a contract between you and doValue Greece, such as for the execution of your orders, or

iii)    the transfer is necessary for the establishment or exercise or defense of legal claims and rights of doValue Greece, or

iv)    there is a relevant obligation arising from a legal provision or an international convention to which doValue Greece is subject. In order to fulfill such obligation, doValue Greece may transfer your personal data to competent national authorities so that such data are delivered through them to the respective authorities of third countries.

doValue Greece retains your personal data for the entire period of time required to process your application and cover the relevant work position. After coverage of the work position, and if you have not been selected, your personal data will be kept for a period of six (6) months, after the lapse of which they will be deleted. Further retention and processing of this data will be carried out only if provided by law or if you explicitly request it for the purpose of future job search. In this case, your data will be kept for a period of thirty-six (36) months starting from the completion of the recruitment process for which you submitted your application and your relevant personal data. In case of recruitment, your personal data will be processed in accordance with the provisions of «Personal Data Processing Notice of doValue Greece Employees pursuant to Regulation (ΕU) 2016/679 and the relevant Greek and European legislation » which is constantly posted on the intranet of doValue Greece. Especially in case a shorter or longer retention period of your data is provided by law or regulations, the above retention time will be reduced or increased accordingly. In the event of a legal dispute with doValue Greece and/or the respective receivables entity, or relevant administrative dispute, said storage period will be extended until the issuance of an irrevocable court decision. In case of lapse of the above time period your data will be deleted safely.

i)    Right of access to your personal data that are retained and processed by doValue Greece, as well as to information concerning the processing thereof (origin of the data, purposes of processing, categories of recipients, storage period).

ii)    Right to rectification of your personal data, in the event of inaccurate data or for the purposes of completing incomplete personal data.

iii)    Right to object on grounds relating to your particular situation unless the processing is necessary for the purposes of the legitimate grounds of doValue Greece or a third party.

iv)    Right to restriction of processing of your personal data where the accuracy of the personal data is contested by you or the processing is unlawful or doValue Greece no longer needs your personal data for the purposes of processing, or you have objected to the processing and the verification whether the legitimate grounds of doValue Greece override yours, is pending.

v)    Right to erasure of your personal data from doValue Greece’s records.

vi)    Right to data portability of your personal data and transfer thereof to another controller, provided that the processing is based on your consent or on a contract and is carried out by automated means.

Please note the following with regard to your abovementioned rights:

i)    Your above rights may not be fully or partially satisfied if the processing or retention thereof is necessary for the establishment, exercise or defense of the rights of doValue Greece.

ii)    The right to data portability (point vi above) does not include the erasure of the personal data from the records of doValue Greece. The erasure is subject to the conditions of point (v) above.

iii)    The exercise of the rights above is valid for the future and does not affect the processing already performed on your personal data.

For the exercise of your rights, you may address your relevant requests in writing, to the Human Resources Department of doValue Greece, 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece or via email at [email protected]

The abovementioned period may be extended by two (2) further months, if deemed necessary at reasonable discretion of doValue Greece, taking into account the complexity and number of requests. doValue Greece shall inform you in case of such extension within one month from the receipt of the request.

The abovementioned service is provided by doValue Greece free of charge. However, where requests are manifestly unfounded, excessive or repetitive, doValue Greece may, after relevant information, either charge a reasonable fee or refuse to act on the request/requests.

You may contact the Data Protection Officer of doValue Greece for any matter regarding the processing of your personal data, in writing at 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece or via email at [email protected].

You have the right to lodge a complaint before the Hellenic Data Protection Authority for any matter regarding the processing of your personal data.

For the respective competence of the Authority and the procedure to be followed for filing a complaint, you may visit the Hellenic Data Protection Authority website: www.dpa.gr (My Rights > Complaint to the Hellenic DPA), where detailed information is available.

doValue Greece implements appropriate technical and organisational measures to ensure the lawful protection and processing, as well as the effective protection of your personal data from unauthorised access to, disclosure of, processing, loss, alteration, accidental or unlawful destruction or corruption, prohibited transmission by third parties as well as any other form of unlawful processing.

doValue Greece may in accordance with its applicable policy on the protection of personal data and pursuant to the applicable legal and regulatory framework, modify or amend this Notice, the updated version of which will always be posted on the  doValue Greece website.

Last update: 10/7/2021