Privacy statement for Germany - Asset Based Finance N.V.

1 Who is responsible for your personal data?

Subject to your selection with respect to “make my profile visible to”, either the individual entity in Germany the application is submitted to (which is the standard), or multiple entities of ABN AMRO worldwide will be responsible for your personal data.Should you select the option “Only recruiters managing jobs I apply to”, your application-related data will only be made available to recruiters of the ABN AMRO entity in Germany which you have applied to and will be processed in accordance with the applicable German data protection laws and regulations. The individual entity in Germany, and therefore controller of your personal data in case of this application is either:

ABN AMRO Asset Based Finance N.V. I Niederlassung Deutschland
Gereonstraße 15–23
50670 Köln, Deutschland
(im Folgenden genannt "ABF")

Bethmann Bank AG 
Mainzer Landstr.
160329 Frankfurt am Main, Germany
(hereinafter "Bethmann Bank")

ABN AMRO Bank N.V., Frankfurt Branch
Mainzer Landstr.
160329 Frankfurt am Main, Germany
(hereinafter "ABN AMRO Bank Frankfurt Branch")

individually also called „entity in Germany” or together “the entities in Germany”.

Should you select the option “Any company recruiter worldwide”, your application-related data will also be made available to recruiters of all other entities of ABN AMRO worldwide (hereinafter, together with the entities in Germany, “ABN AMRO entities”), and will be processed in accordance with the applicable local data protection laws and regulations. You will find an overview of ABN AMRO entities here: https://www.abnamro.com/en/about-abnamro/our-company/subsidiaries/index.html.

2 Data Protection Officer and Privacy Officer

DABN AMRO entities have a designated Data Protection Officer. The Data Protection Officer monitors the application of, and compliance with, data protection legislation. The contact details of the Data Protection Officer are

ABN AMRO Bank N.V.
Chief Privacy Officer
Gustav Mahlerlaan 10
1082 PP Amsterdam, Niederlande
Email: privacy.office@nl.abnamro.com

You can contact the local representative of the Data Protection Officer, the Privacy Officer of the entities in Germany at:

(external Data Protection Officer mandated by ABF)
UIMC Dr. Voßbein GmbH & Co. KG
Datenschutzbeauftragter
Otto-Hausmann-Ring 113
42115 Wuppertal, Deutschland
Telefon: +49 202 9467726200
E-Mail: consultants@uimc.de

3 Source of personal data

Most of the personal data relating to you, that is processed by ABN AMRO entities you apply to, is personal data that it obtained directly from you. In addition, ABN AMRO uses personal data relating to you that it obtains possibly from other sources. Personal data may be collected from sources such as:

• An employment or recruitment agency
• Public sources such as search engines and public sections of social media accounts
• In case of an application for a job within ABN AMRO worldwide you may undergo a screening before you join the bank. In that context, the bank receives personal data relating to you from the agency that performs the screening. You can read more about this screening under ‘Pre-employment screening’ below.

4 On what legal ground does the bank process your personal data?

ABN AMRO entities you submit your application to use your personal data for employment related purposes. For the entities in Germany, the legal ground for such processing of personal data is Sec. 26 of the Federal German Data Protection Act.ABN AMRO entities also process your personal data in accordance with their relevant national laws for one or more of the following reasons.

Rules and regulations

Your personal data might be processed because it is required to do so under various laws and regulations. Banks are governed by many rules. ABN AMRO entities must have sound and controlled operational policies and processes in place in order to manage integrity risk and guarantee the integrity of the bank and the financial sector as a whole. One aspect of sound and controlled operational policies and procedures is the selection of ethical employees.

Legitimate interest

ABN AMRO entities may also use your personal data if it has a legitimate interest in this. For this to apply, the relevant ABN AMRO entities’ interest in using your personal data must outweigh your right to privacy. In situations such as these, the relevant ABN AMRO entity balances all the interests. The following are examples of legitimate interests that ABN AMRO entities have in using your personal data in the recruitment and selection process: 

• The recruitment and selection of suitable, qualified employees
• Protecting the bank's property and data
• Ensuring the security and safety of the bank and its employees

5 What do we use your personal data for?

We use your personal data for the following purposes:
1. Recruitment and selection of suitable, qualified employees. ABN AMRO entities use your personal data in order to assess your suitability for the relevant role. If you are given an employment agreement, ABN AMRO entities use your personal data to draw up this contract.

2. Ensuring security and safety. ABN AMRO entities also use personal data to protect themselves, their property, their data and their employees from all kinds of breaches, damage and losses insofar as possible.

• These include your access pass, which ABN AMRO entities use to keep track of your presence in the relevant entities’ buildings.
  
• They also include security cameras within ABN AMRO entities' buildings and in their surroundings.
  
• ABN AMRO entities perform pre-employment screening. You can read more about this screening in Section 6 below. Should you select the option “Only recruiters managing jobs I apply to”, i.e. you only apply to either of the entities in Germany, no employment screening during the application phase is performed.

3. HR management. ABN AMRO entities use personal data relating to candidates so that it can pursue a responsible, effective and efficient HR policy.

• For example, it may carry out with studies in the area of people analytics. Such statistical analyses look at the impact of HR strategy. The results of such studies and the related recommendations can never be traced back to an individual.
  
• Another example concerns ABN AMRO's diversity policy. ABN AMRO entities seek to ensure that greater diversity within society is reflected throughout the bank. It is therefore keen to monitor the level of diversity among candidates in the recruitment and selection process. To this end, ABN AMRO entities use aggregate data about their gender and age. Aggregate data cannot be traced back to an individual.
  

4. Rules and regulations. Finally, ABN AMRO entities use personal data relating to employees in order to comply with applicable legislation and regulations, Under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft) and subordinate legislation, ABN AMRO entities must have sound and controlled operational policies and processes. One aspect of sound and controlled operational policies and procedures is the selection of ethical employees.

6. Pre-employment screening

As guaranteeing the reliability, professionalism and security of its organisation is important to ABN AMRO, the final phase of the application process consists of pre-employment screening. Personal data obtained from public sources may also be used for this purpose. ABN AMRO entities’ pre-employment screening consists of the following as a minimum:

• investigation of irregularities;
• identity check;
• address verification;
• own statement on integrity;
• certificate check;
• employment background check covering the past five years;
• Certificate of Good Conduct (VOG).

The screening process consists of internal and external screening. ABN AMRO entities perform the internal screening, and in that context it will request, access and verify information relating to you. In the case of external screening for a role at ABN AMRO that is based in the Netherlands, ABN AMRO uses a specialist screening agency, Validata (for more information go to Home – Validata (validatagroup.com). ABN AMRO does not transfer your personal data to that agency: you must enter and upload your personal data on that party’s website yourself. If you apply for a role in a country other than the Netherlands, a local screening agency performs the screening or, alternatively, the organization in the relevant country follows its own screening procedure.

7 Does ABN AMRO use your personal data for other purposes than the purpose for which it was initially obtained

ABN AMRO may also use your personal data for a purpose other than the purpose for which you initially provided it. This is, however, subject to the condition that the new purpose must be in line with the purpose for which you initially provided your personal data to us. To determine whether this is the case, ABN AMRO looks at the following aspects as a minimum: 

• Is this purpose clearly related to the purpose for which you initially provided the personal data? Is the new purpose appropriate to the initial purpose?
• How was the personal data originally obtained from you? Was the personal data obtained directly from you or in another way?
• What kind of personal data is concerned exactly? Does it concern sensitive data, or data that is not so sensitive?
• What would be the implications for you if ABN AMRO were to use the personal data in another way? Would you benefit, suffer or neither?
• What can ABN AMRO do to ensure the highest possible level of data protection when reusing your personal data? Examples include anonymisation and encryption.
  

8 Does ABN AMRO share your personal data with others?

IWithin the entities in Germany, those departments that need your data with respect to the purposes specified above have access to it, especially Human Resources and the management responsible for the relevant vacancy.Furthermore, contractors used by the entities in Germany (Art. 28 GDPR) may also receive or have access to your personal data for the purposes foreseen in the contract with them. These are in particular companies in the categories of banking services, IT services, logistics, printing services, telecommunications, consulting and sales and marketing.
ABN AMRO entities may share your personal data with suppliers of assessments, for instance so that a personality test and employment screenings can be conducted. ABN AMRO entities take due care when selecting the companies with which they work and enter into clear contractual agreements with these companies on how they should handle your personal data in accordance with the relevant data protection laws. ABN AMRO entities continue to be responsible for your personal data when and where they engage another company to carry out work on their behalf.

9 Is your personal data processed outside the EEA too?

Should you select the option “Only recruiters managing jobs I apply to”, your application-related data will only be processed by the entities in Germany and its contractors in accordance with the applicable data protection laws. If in the course of processing, your personal data is supposed to be transmitted to third countries (countries outside the European Economic Area - EEA), the entities in Germany enter into appropriate contractual agreements with the relevant contractor to ensure an adequate level of data protection. This is currently achieved through EU standard contractual clauses which are available on this website of the European Commission.Should you select the option “Any company recruiter worldwide”, your application-related data will also be made available to recruiters of all other ABN AMRO entities. The sharing of personal data with ABN AMRO entities outside the EEA is governed by the bank's global internal policy, the Binding Corporate Rules (BCRs). This policy has been approved by the Dutch Data Protection Authority (Dutch DPA). Each ABN AMRO entity may also make use of contractors that are based outside the EEA or that also offer services from countries outside the EEA. In that case, the relevant ABN AMRO entity will ensure that personal data is transferred in accordance with the relevant data protection laws. 

10 How does the bank determine the period for which your personal data is stored?

When determining the storage periods for such personal data, the guiding principle is that the personal data is kept as long as it is necessary in order to fulfil the purpose for which that personal data was obtained. The entities in Germany retain the personal data of a candidate in principle for four months as of the date of rejection of a candidate. If we enter into an employment agreement with a candidate, the application-related data becomes part of your personnel file, otherwise it will be deleted.In most cases, data protection legislation does not stipulate specific storage periods for personal data. Other legislation may specify minimum storage periods, however. If it does, ABN AMRO entities must observe these periods. In principle, ABN AMRO entities keep the personal data of rejected candidates for a period of four months starting from the date on which their application is rejected. If your application has been rejected and you want your personal data to be removed before the end of that period, you can request this via datenschutz@bethmannbank.de. If you are hired as an employee, ABN AMRO entities will keep your personal data for the same length of time as personal data relating to other employees. Most personal data relating to employees of the entities in Germany is kept for a period of ten years following the termination of employment. 

11 What rights do you have?

Right of access, right to rectification, right to be forgotten, right to restriction  You have the right to be informed about the processing of your personal data and the right to access this data. You can also ask ABN AMRO entities to correct any inaccuracies in your personal data. To do this, please submit a request via www.abnamro.nl/en/personal/overabnamro/privacy/your-rights.html.

In some cases, you can also ask ABN AMRO entities to delete your personal data. ABN AMRO entities are not obliged to grant your request for the deletion of your personal data in all cases. For example, it is not under an obligation to do so if the law requires it to keep your personal data for a longer period of time.

You can also ask ABN AMRO entities to restrict the use of your personal data on a temporary basis. This is possible in the following situations:

• You think that your personal data are incorrect;
• ABN AMRO entities use your personal data wrongfully;
• ABN AMRO entities want to destroy your personal data (for instance after the storage period has ended) but you still need it.

Requests for the deletion of your personal data or the restriction of its processing can also be submitted through abnamro.com/clientrights. Always clearly indicate the reason for your request.More information about your rights and how to submit a request can be obtained from abnamro.com/clientrights.With respect to the processing of your personal data by the entities in Germany, the restrictions pursuant to Sections 34 and 35 of the German Federal Data Protection Act apply, namely with respect to the right of access and the right to erasure.Please direct requests to the entities in Germany relating to the above rights to the Privacy Officer using the contact details in Section 2 above.Right to data portability ABN AMRO can arrange for you to obtain your personal data that you provided to it and which is stored by automated means. It will not do this unless it processes your personal data on the basis of your consent or the contract it has concluded with you. This is referred to as data portability.Please keep your personal data secure. Check whether any party you want to provide your personal data to can be trusted and keeps your personal data as safe as ABN AMRO entities do. If you want to receive your personal data, please make sure that your own equipment is adequately secure and has not been, or cannot be, hacked. If you use email communication, please be aware that without encryption such communication is not safe and the content of such communication might become known to others. If you contact us by email, we assume that this way of communication is fine for you despite the technical uncertainty and will also communicate with you by unencrypted email. Otherwise, please inform us about the way you want to communicate with us.

12 Is anything unclear?

Please contact us if you have any questions about this privacy statement. Our Privacy Officers are here to help. Please use the contact details of the Privacy Officer in Section 2 above.

13 Do you have a complaint?

If you do not agree with the way in which ABN AMRO entities handle your personal data, you can lodge a complaint.Should you select the option “Only recruiters managing jobs I apply to”, please lodge a complaint with the Complaints Management department at:
ABN AMRO Asset Based Finance N.V., Niederlassung Deutschland
Beschwerdemanagement
Postfach 10 02 05
50442 Köln
Deutschland

14 Changes to the Privacy Statement

The way your personal data is used may change over time due to changes in laws and regulations or in internal procedures or systems that will directly affect the use of your personal data by the entities in Germany. If this happens, this Privacy Statement will be changed. In that case, the changes will be published on the website www.workingatabnamro.com.