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Job applicants

Below, you will find an overview of the personal data that we may process, including the associated purposes and legal bases.

General
Processing
Processing, assessing and managing applications
Description/purposes
  • Identifying the most suitable candidate for a vacancy
  • Processing applications
  • Assessing whether an applicant qualifies for a position at BNG
  • Maintaining contact with the applicant
Categories of personal data
  • First and last name
  • Contact details, such as the address, telephone number and email address
  • Date of birth
  • Gender
  • CV
  • Cover letter
  • Level of education
  • Professional experience
  • References
  • Salary indication
  • Language proficiency
  • Availability
  • Information that the applicant provides voluntarily, such as their photo, place of birth, marital status, nationality, hobbies and interests
  • Any additional information provided by recruiters, headhunters, employment agencies or intermediaries
  • Information from social media profiles such as LinkedIn
Special category personal data and criminal offence data
Not applicable (unless provided by the applicant on their own initiative)
Basis
Legitimate interest (Article 6 (1)(f) GDPR) – selecting suitable applicants and being able to communicate with applicants
Processing
Conducting job interviews
Description/purposes
  • Scheduling and conducting (online or in-person) job interviews
Categories of personal data
  • First and last name
  • Contact details, such as the address, telephone number and email address
  • Availability and travel information
  • Interview notes
  • Information obtained from interviews
  • Access pass/check of ID proof (for interviews held at BNG’s office)
 
Special category personal data and criminal offence data
Not applicable
Basis
Legitimate interest (Article 6 (1)(f) GDPR) – planning and conducting interviews to determine whether a candidate is suitable and motivated for a position.
 
Pre employment screening
Processing
Pre-employment screening – carried out by International Security Partners (ISP) on behalf of BNG
Description/purposes
A check of the integrity and reliability of applicants by:
  • Having an online integrity questionnaire completed
  • Verifying their identity and verifying that ID documents are genuine and not registered as missing or stolen
  • Checking the highest diploma obtained through DUO to confirm educational claims
  • Carrying out a reference check for two specified references
  • Applying for a Certificate of Conduct (VOG) to assess criminal risks
  • Analysing the CV and employment history for completeness and subsequent periods
  • Consulting the insolvency register to verify financial integrity
  • Checking whether the applicant appears on sanctions lists
Categories of personal data
  • First and last name
  • Contact details;
  • Date and place of birth
  • Copy of ID
  • Diplomas
  • CV
  • Employment history
  • References
  • Data from the insolvency register
  • Information from the integrity questionnaire
  • Test results
 
Special category personal data and criminal offence data
  • Possible criminal data (VOG)
  • Details of whether someone appears on a sanctions list
Basis
Legitimate interest (Article 6 (1)(f) GDPR) – BNG’s interest in establishing the reliability and integrity of applicants. The Dutch Financial Supervision Act (Wft) and the Dutch Prevention of Money Laundering and Terrorist Financing Act (Wwft) require banks to assess the integrity and reliability of employees. Screening against sanction lists is carried out as part of BNG’s legitimate interest to manage integrity risks. 
Processing
Pre-employment screening – carried out by BNG
Description/purposes
A check of the integrity and reliability of applicants by:
  • Checking whether an applicant appears in disciplinary records (violation of the banker's oath).
  • Performing an ‘EVA check’ to determine whether there are signs of fraud or serious incidents within the financial sector (test of the Incidents Warning System for Financial Institutions).
  • Complying with legal obligations under the Dutch Financial Supervision Act (Wft) and the Dutch Anti Money Laundering Act (Wwft) to mitigate risks of fraud, money laundering and integrity violations.
 
Categories of personal data
  • First and last name
  • Contact information
  • Screening results
 
Special category personal data and criminal offence data
  • External referral application (EVA test) hit or no hit
  • Information from disciplinary records (breach of the banker's oath)
Basis
Legitimate interest (Legitimate interest (Article 6 (1)(f) GDPR) – BNG’s interest in determining the reliability and integrity of applicants. The Dutch Financial Supervision Act (Wft) and the Dutch Prevention of Money Laundering and Terrorist Financing Act (Wwft) require banks to assess the integrity and reliability of employees. 
 
Successful application
Processing
Making an offer
Description/purposes
  • Making an offer to successful applicants
Categories of personal data
  • First and last name
  • Contact information
  • Offer details (future salary, terms of employment, job title, start date, working hours, etc.)
  • Employment contract
  • Designation as an insider (if applicable)
Special category personal data and criminal offence data
Not applicable
Basis
Necessary for the performance of a contract to which the data subject is a party, or to take measures to conclude the contract at the request of the data subject (employment contract) (Article 6 (1)(b) GDPR)
Processing
Onboarding
Description/purposes
  • Registering personal data in the personnel file
  • Processing data for payroll, compensation, allowances and legal obligations
 
Categories of personal data
  • First and last name
  • Contact information
  • Citizen service number (BSN)
  • Verification of bank account number/copy of bank card
  • Statement of payroll tax data
  • Travel expenses
  • Home office allowance
  • Copy of ID
  • Emergency contact details
Special category personal data and criminal offence data
Data on medical conditions that are relevant for workplace adjustments or for facilitating a safe and accessible working environment.
Basis
Necessary for the performance of a contract to which the data subject is a party, or to take measures to conclude the contract at the request of the data subject (employment contract) (Article 6 (1)(b) GDPR)
Processing
Access to systems and facilities
Description/purposes
  • Creating and managing accounts for access to business applications
  • Issuing an access pass
Categories of personal data
  • First and last name
  • Business email address
  • Business phone
  • Position
  • IP address
Special category personal data and criminal offence data
Not applicable
Basis
Necessary for the performance of a contract to which the data subject is a party, or to take measures to conclude the contract at the request of the data subject (employment contract) (Article 6 (1)(b) GDPR)
Processing
Communication and introduction
Description/purposes
  • Including new employees in internal communication systems
  • Receiving information about the BNG organisation
  • Sending information packs about relevant compliance regulations and procedures, information about the onboarding day, etc.
Categories of personal data
  • First and last name
  • Contact information 
  • Business email address
 
Special category personal data and criminal offence data
Not applicable
Basis
Necessary for the performance of a contract to which the data subject is a party, or to take measures to conclude the contract at the request of the data subject (employment contract) (Article 6 (1)(b) GDPR)
 
Unsuccessful application
Processing
Talentpool
Description/purposes
  • Contacting applicants for future vacancies at BNG.
  • Assessing applicants’ profiles and matching them to future roles
  • Maintaining contact regarding relevant developments or suitable positions
  • Optimising the recruitment process by gaining insight into available talent.
Categories of personal data
  • First and last name
  • Contact information
  • CV and cover letter
  • Salary indication
  • Wishes and preferences for future positions
Special category personal data and criminal offence data
Not applicable (unless provided by the applicant on their own initiative)
Basis
Consent of the data subject (Article 6 (1)(a) GDPR)
 
Other
Processing
Organising or participating in recruitment events
Description/purposes
  • Meeting potential candidates and informing them about working at BNG.
  • Collecting contact details and CVs to enable follow-up contact.
  • Creating visual recordings for communication purposes and to capture the atmosphere of the event
Categories of personal data
  • First and last name
  • Contact information
  • CV
  • Other information volunteered by participants in the event
  • Visual recordings (photo and video)
Special category personal data and criminal offence data
Not applicable
Basis
Legitimate interest (Article 6 (1)(f) GDPR) – BNG’s interest in recruiting suitable candidates and supporting the recruitment process.
Processing
Contact with (potential) applicants
Description/purposes
  • Responding to questions and maintaining communication with (potential) applicants by telephone, email or web form. This includes providing information on vacancies, application procedures and answering general questions.
Categories of personal data
  • First and last name
  • Contact information
  • Content of the message or question
  • Recording of contact interactions
 
Special category personal data and criminal offence data
Not applicable
Basis
Legitimate interest (Article 6 (1)(f) GDPR) – BNG’s interest in properly informing applicants and acting so that the recruitment process runs efficiently.