Data protection statement for online applications to DEG

DEG's website offers you the opportunity to apply electronically for job vacancies at DEG. If you submit an online application, DEG will process your personal data, which you provide to DEG electronically for the purposes of the application. The protection of your personal data during the entire application process is an important concern for DEG. DEG will treat all personal data in strict confidence in accordance with the applicable statutory data protection regulations and exclusively for the purposes of the electronic application. As part of our principles of fair and transparent data processing, we would like to inform you in accordance with our information obligations under Art. 12, 13, 14 and 21 GDPR about the detailed circumstances of the processing of your personal data by us.

Unless otherwise stipulated below, the general privacy policy for DEG's website applies, which you can access here: General privacy policy
 

A. Data Controller and Data Protection Officer

Your data will be processed under data protection law by:
DEG - Deutsche Investitions- und Entwicklungsgesellschaft mbH
Kaemmergasse 22
D-50676 Cologne
Phone: + 49 221 4986-0
Fax: + 49 221 4986-1290
In the following: DEG

You may reach our company data protection officer at:

DEG - Deutsche Investitions- und Entwicklungsgesellschaft mbH
attn. The Data Protection Officer
Kaemmergasse 22
D-50676 Cologne
datenschutz@deginvest.de
 

B. Purpose and legal basis for the processing

 I.          Execution of the application procedure

The purpose of our data processing is to carry out the application procedure for the position for which you have applied to us, as well as the associated suitability test and verification of work authorization.

The data collected for the application process will also be processed after the conclusion of the employment contract for the purposes of implementing and, if applicable, terminating the employment relationship. All information on the processing of your personal data in the context of the employment relationship can be found in a separate privacy policy. We collect the following personal data from you as part of our application process:

• Salutation,
• Surname and first name,
• Contact and address data,
• Curriculum vitae, certificates, confirmation of qualifications and other documents uploaded as part of the application,
• Suitability tests, if they are part of the procedure for the position for which you have applied,
• Date of birth,
• Severe disability,
• Notice period with employer,
• Salary expectations,
• Data provided during the job interview.

The application documents may contain special categories of personal data. According to Art. 9 GDPR, special categories of personal data are personal data revealing racial or ethnic origin, political opinions, religious (e.g. information on religious affiliation/denomination) or philosophical beliefs or trade union membership, as well as the processing of biometric data for unique identification (e.g. photographs), health data (e.g. information on the degree of severe disability) or data concerning sex life or sexual orientation. If your CV contains special categories of personal data, we do not intentionally collect them. We expressly ask you not to send us such data.

The legal basis is Art. 6 para. 1 lit. b GDPR; Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 sentence 1 BDSG for the decision on the establishment of an employment relationship. If you voluntarily provide us with special categories of personal data in accordance with Art. 9 para. 1 GDPR as part of your application documents and contrary to our express request (e.g. information on your religious affiliation/denomination), we will store this data on the basis of your consent in accordance with Art. 88 para. 1 GDPR in conjunction with Section 26 para. 3 sentence 2 BDSG. This also applies if you provide us with further special personal data in the further course of the application process. By voluntarily submitting this data, you agree to the processing of this special personal data by us as part of the application process.

II.         Applicant pool and contact

In addition, we will use your data to inform you electronically about future job vacancies that may be of interest to you. However, this will only be done at your request and with your prior consent to use your contact details for this purpose.

The legal basis is your consent pursuant to Art. 6 para. 1 lit. a GDPR in conjunction with Art. 88 para. 1 GDPR.

III.        Pre-Employment-Screening

1.         Money Laundering Check 

As a credit institution, we are obliged to exercise increased due diligence when selecting our employees. Therefore, before an employment relationship is established, checks must be carried out with regard to reliability under money laundering law if you are applying for a position that is fundamentally suitable for facilitating money laundering and terrorist financing. 

For this purpose, the following data is collected from you:

• Police clearance certificate
• ID Card

In this case, the legal basis for the processing is the legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in conjunction with Art. 6 para. 2 no. 5 AMLA to only employ reliable employees within the meaning of the law and to fulfill our compliance obligations pursuant to Art. 6 para. 1 lit. b GDPR; Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 sentence 1 Federal Data Protection Act (BDSG).

2.         Sanctions list check

We process your personal data for comparison with sanctions lists. The comparison is carried out on the basis of our legitimate interests in complying with the ban on provision, according to which business relationships with certain countries and/or persons as well as the provision of financial and/or economic resources to these countries and/or persons are prohibited. These persons and/or countries are listed on the sanctions lists. The comparison enables us to document that we comply with the ban on provision and are allowed to enter into an employment relationship with you.

In a first step, we process your name and country of residence for a comparison with the sanctions lists. If we do not find a corresponding entry, the check is completed without any further consequences for you. If we find an entry, we verify it in a second step and use information on known business activities, date of birth and nationality. If we are then unable to match you with the entry on the sanctions list, the check is completed without any further consequences for you. If we are still able to assign the entry to you after the second stage, we will inform you of this result, give you the opportunity to comment on it and will take your comments on the result of the sanctions list check into account in our decision on the establishment of the employment relationship.

The legal basis for this processing is our legitimate interest in compliance with the ban on provision pursuant to Art. 6 para. 1 lit. f GDPR; the check is also necessary in this respect in order to be able to establish an employment relationship with you, Art. 6 para. 1 lit. b GDPR; Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 sentence 1 Federal Data Protection Act (BDSG).

IV.       Compliance with other legal obligations

In addition, we process your personal data to fulfill other legal obligations, such as regulatory requirements, commercial and tax retention obligations or the verification of your work permit.

In this case, the legal basis for the processing is the respective legal regulations in conjunction with Art. 6 para. 1 lit. c GDPR.

V.        Law Enforcement

We may also process your personal data in order to assert our rights and enforce our legal claims. We also process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data insofar as this is necessary for the prevention or prosecution of criminal offenses.

We process your personal data for this purpose to protect our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or we prevent or investigate criminal offenses. This is also our legitimate interest.

C. Recipient of the aforementioned personal data

Within DEG, those departments that need your data to fulfill our contractual and legal obligations will have access to it. Service providers and vicarious agents employed by us may also receive data for these purposes.

Recipients of your personal data when provided outside DEG may be

• Online platforms for the electronic submission of the required documents
• Online platforms for the electronic completion of an aptitude test, if this is part of the procedure for the position for which you have applied

If one of the above-mentioned recipients processes personal data on behalf of DEG, this shall only be done on the basis of appropriate contractual agreements that also impose the data protection obligations placed on DEG on the recipient. If the data is made available to one of the above-mentioned recipients in such a way that the recipient is responsible for further data processing, appropriate contractual measures will also be taken to protect your data and the transfer will only take place if it is legally legitimized. 

D. Sources

We receive data that we have not collected directly from you from the following sources, to the extent permitted by law:

·        Public authorities or other government agencies, e.g. tax offices, employment agencies,

·        recruitment agencies,

·        your previous employers, if you have consented to us contacting them as part of your recruitment process.

E. Transfer to a third country and/or an international organization

Data is only transferred to countries outside the EU or the EEA if this is necessary in the context of processing our contractual relationships, if it is required by law (e.g. reporting obligations under tax law), if you have given us your consent or as part of order processing. If service providers are deployed in a third country, they are obliged to comply with the level of data protection in Europe in addition to written instructions by agreeing the EU standard data protection clauses. Other recipients, such as affiliated companies or authorized dealers, are also bound accordingly (where necessary) by EU standard contractual clauses. Alternatively, we transfer the data on the basis of an existing adequacy decision of the European Commission or Binding Corporate Rules.

F. Storage duration

Your data will be stored until the end of your application process. After six months, all application documents will be deleted and the personal reference to your profile removed if your application has been rejected. If the application is accepted, your personal data will be processed further for the purposes of the employment relationship. You can find information on this in the privacy policy for employees.

If you give us your consent to include your data in our applicant pool, your data will be stored for one additional year until you revoke this consent. Longer storage periods may also result from the fact that the data is necessary for the assertion, exercise or defense of legal claims before an authority or statutory retention obligations exist. In order to comply with legal obligations, we initially store your data for the duration according to the statutory retention obligations. Corresponding verification and retention obligations may arise from the German Commercial Code, the German Fiscal Code and the German Money Laundering Act, among others. These can range from two to ten years. Further storage may then be considered for legal enforcement purposes. For the purpose of possible legal enforcement, we store your personal data until the conclusion of the respective dispute, defense against claims, legal prosecution, investigations, etc.. The limitation period for claims is generally between one and three years, but can also be up to thirty years.

G. Obligation to provide the aforementioned personal data

The provision of some of the personal data that you submit to us in connection with the application process is required by law or contract or is necessary for the establishment or proper performance of any employment contract that you may subsequently enter into. You are therefore obliged to provide us with this personal data. We would like to point out that if you do not provide us with this personal data, we may not be able to consider you for the further application process or employ you with us.
 

H. Automated decision making/ profiling

There is no automated decision making / profiling.
 
I. Rights of data subjects

You have the following rights vis-à-vis us, which you can assert vis-à-vis the office named in Section 1 or our data protection officer:

• Right to information: You are entitled to request confirmation from us at any time within the scope of Art. 15 GDPR as to whether we process personal data concerning you; if this is the case, you are also entitled within the scope of Art. 15 GDPR to receive information about this personal data and certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage period, your rights, the origin of the data, the use of automated decision-making and, in the case of third country transfer, the appropriate guarantees) and a copy of your data.
• Right to correction: In accordance with Art. 16 GDPR, you are entitled to demand that we correct the personal data stored about you if it is inaccurate or incorrect.
• Right to deletion: You are entitled, under the conditions of Art. 17 GDPR, to demand the immediate deletion of your personal data. The right to deletion does not apply, among other things, if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) to fulfill a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) to assert, exercise or defend legal claims.
• Right to restriction of processing: You are entitled to demand that we restrict the processing of your personal data under the conditions of Art. 18 GDPR.
• Right to data portability: You are entitled, under the conditions of Art. 20 GDPR, to request that we provide you with your personal data that you have provided to us in a structured, commonly used and machine-readable format..
• Right to object: You are entitled to object to the processing of your personal data under the conditions of Art. 21 GDPR, so that we have to terminate the processing of your personal data. The right to object only applies within the limits provided for in Art. 21 GDPR. In addition, our interests may conflict with the termination of processing, so that we are entitled to process your personal data despite your objection.
• Right of revocation: You have the right to revoke your consent at any time. The revocation is only effective for the future; this means that the revocation does not affect the legality of the processing carried out on the basis of the consent until the revocation.
• Right to file a complaint with a supervisory authority: You have the right to file a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR, subject to the conditions of Art. 77 GDPR. The right to file a complaint exists without prejudice to any other administrative or judicial remedy. You can contact the data protection authority responsible for us at:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen

Kavalleriestr. 2-4

40213 Düsseldorf

Phone: 0211/38424-0

Fax: 0211/38424-10

Email: poststelle@ldi.nrw.de

However, we recommend that you always address a complaint to our data protection officer first.

You may reach him / her at:

DEG - Deutsche Investitions- und Entwicklungsgesellschaft mbH

Attn. The Data Protection Officer

Kämmergasse 22

D-50676 Cologne

datenschutz@deginvest.de

If you have any questions regarding the handling of your personal data, you may contact our data protection officer at any time using the contact details above.

H. Amendments

We reserve the right to amend this privacy policy at any time. Any changes will be announced by publishing the amended privacy policy on our website. Therefore, please check this privacy policy regularly to see the latest version.

As of: July 2024