ING - PRIVACY STATEMENT TO APPLICANTS
ING Groep N.V., along with its affiliates and subsidiaries, is a global organisation domiciled in Europe, South and North America, Asia and Australia (see also www.ing.com) (hereinafter referred to as “ING Group”). ING Group is committed to protecting the privacy of external and internal applicants. When an applicant visits the ING Group career website or uses the internal job vacancies site, ING Group collects information (personal data) about the applicant (e.g. via web forms).
Protecting the privacy and personal data of applicants is of the utmost importance to ING Group and is a significant aspect of the way ING Group creates, organises and implements its recruiting activities.
Please read this Recruitment Privacy Statement (hereinafter referred to as “the Privacy Statement”) carefully.
1. What is the scope of this Privacy Statement ?
This Privacy Statement concerns all candidates who apply for a job within one of the following legal entities:
- ING Belgique SA/ING België NV, with registered offices at 1000 Brussel, Marnixlaan 24, with company number 0403.200.393;
- ING Bank NV Belgian Branch, with registered offices at 1000 Brussel, Marnixlaan 24, with company number 0828.223.909; and,
- ING Lease Belgium SA, with registered offices at 1000 Brussel, Marnixlaan 24, with company number 0402.918.402.
The three legal entities above are hereinafter referred to as “ING”.
This Privacy Statement explains why and how ING collects information about you, how we protect it and for how long we retain it. We keep your data as safe and secure as reasonably possible protecting it against loss and unauthorised disclosure or access and we will handle your personal data in strict compliance with applicable data protection laws, in particular the General Data Protection Regulation 2016/679 of 27 April 2016 (‘GDPR’).
This Privacy Statement has been set up as a Q&A list.
2. Who will process my personal data?
Each legal entity acts as a separate data controller for the data related to an application within them.
The processing of applications is centralized within one sole entity, i.e. ING Belgique SA/ING België NV that acts as “data processor” for the applications to ING Bank NV Belgian Branch and ING Lease Belgium SA.
3. What is the purpose and legal ground for processing my personal data?
The purpose for processing your personal data is to register your application for a job within ING and, if this application leads to start our selection procedure, make a profile of you, meaning that ING will process all the necessary data that is required for us to assess your job application in view of a potential recruitment (which may also imply an evaluation by a third party).
The processing of your data is therefore necessary in order to take steps prior to entering into an employment contract .
In case of positive evaluation and decision to hire, we will also use your personal data to prepare an employment contract.
During the recruitment process we might also process data in view of our legitimate interest, such as in the case of an open sources screening which will be carried out to protect us against fraud and reputational damages, or in the case of data transfer to assessment centers or screening agencies (in order to enable such service providers to assess or screen you). In case of a decision not to hire you, we will retain your personal data for a period of time as well in order to be able to contact you if any future job opportunities would seem to match your profile and with a view to the management of possible disputes. This is also in the legitimate interests of ING. We will ensure that your interests or fundamental rights and freedoms don't prevail and will permanently monitor this.
4. Which categories of my personal data will be processed?
Personal data is all information relating to you or on the basis of which you may be identified. Anonymous data, without possibility to identify you, could thus not be considered as personal data.
ING collects and processes applicant data (required and optional) which an applicant provides directly, via forms and attached resume’s, on the ING recruitment website with URL www.ing.jobs. ING also collects and processes applicant data through personal contacts, phone calls or e-mail. In the course of the recruitment process, we may also receive personal data relating to you from third parties or generate personal data relating to you (e.g. evaluations and assessments).
For the purposes referred to here above, the processing of personal data will include the following:
- standard data related to your identity (surname, name(s), address…);
- personal data (date and place of birth, nationality, gender, phone number, email address, hobbies and interests, …);
- your picture, if you decide yourself to provide us with one (e.g. included in your CV);
- memberships (eg: to professional associations, youth movement, etc) ;
- data with regard to your professional experience (profile, data on previous employers, termination of last employments and work carried out, special projects, …), including reference checks if you have consented to this;
- data with regard to your education (diploma’s, certificates, internships, special trainings, …)
- language skills;
- if applicable, whether you possess a permit of working and/or reside in the European Economic Area (EEA);
- any other personal data that you present us with as part of your application, related to the exercise of the role;
- data regarding your suitability (evaluations, assessments…).
- digital assessment through the internet (social media presence, search engines and other websites), insofar as this presence is open for us to see and the information is relevant to the position ("online presence screening"). In the context of the online presence screening, ING may in particular:
- carry out automated internet searches to screen publicly available data regarding an individual person which is relevant for the position;
- create screening reports based on these searches.
- Online sources checks are necessary for ING to verify the applicant's reliability and suitability taking into account the specific risks of a financial institution. When assessing your suitability for the function, the screening reports will be taken into consideration together with all other relevant factors.
any other personal data (than mentioned above) that require processing by virtue of the law.
ING may occasionally process sensitive applicant data (such as data that reveals your race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sex life), but we will only do this to the extent that we can invoke a valid exception ground (e.g. if the data are manifestly made public by you, if this is necessary to fulfil obligations in the field of employment law or for the assessment of your working capacity in accordance with applicable law etc.).
Because of ING's activities, you may be subject to a criminal background check. We will however only process personal data relating to criminal convictions and offences when such processing is authorised by Belgian or European law.
5. Who will have access to my personal data?
HR and your envisaged hierarchic superior(s) will have access to your personal data on a strict ‘need-to-know’ basis for the purposes described above.
We may further share your data with:
- ING Group for profiles that may imply international careers, for more details see 6 hereunder;
- External service providers and agencies including assessment centres to assist ING in the recruitment process;
We have concluded appropriate Data Protection Agreements with all these parties.
We may also share your data with authorities if provided by law or when necessary for dispute management purposes..
Prior to disclosing any information to any third party, ING will ensure that all third party recipients are bound to strict standards of security.
ING does not sell or trade applicant data to any third party
6. Will my personal data be transferred outside the European Economic Area?
To operate as a global business and to promote an applicant’s career within ING Group, it may be necessary to process and transfer applicant data within ING's worldwide operations to another country where ING Group operates and/or any service provider ING is working with has its operations.
ING has implemented appropriate safeguards in line with the GDPR for the transfer and processing of applicant data to any third countries outside the European Economic Area (such as third countries where ING operates) such as Standard Contractual Clauses (art. 46, c GDPR) If you wish to receive more information, please contact ING-BE-PrivacyOffice@ing.com
7. Will ING make use of automated decision-making?
Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects or that significantly affect the individuals involved.
As a rule, ING does not make use of automated decision-making as described above. ING does not base its decision whether or not to hire you solely on automated processing of your personal data.
8. How long will my personal data be retained?
We will only hold your personal data for as long as it is necessary for the purposes described above. As general rule, in case the recruitment does not result in an employment relationship, your personal data will be retained for a maximum period of two years after the end of the job application procedure for the purposes described under pt. 3.
If the recruitment results in an employment relationship, your personal data will be retained in accordance to the retention policy for employees’ personal data. You will be informed about this by means of a separate privacy notice for employees.
ING uses a number of technical, physical and organizational security measures to assure the integrity, confidentiality and availability of your data. ING has implemented security technologies to protect your stored data from unauthorised access, improper use, alteration, unlawful or accidental destruction and accidental loss. ING continues to enhance its security procedures as new technology becomes available. Access to your data is limited to ING staff members who are involved in ING recruitment activities and external service providers who are involved during the process (see above under 5.). ING staff members who have access to your data are obliged to respect the privacy of applicants visiting ING’s website and the confidentiality of their data. ING ensures adequate security to protect manual and electronic processing of your data and prevent its misuse, all in accordance with applicable local legal requirements. ING also ensures (contractually) that third parties and affiliates processing your data on ING’s behalf, will observe similarly adequate security measures again in accordance with applicable local legal requirements.
10. What are my rights with regard to the processing of my personal data by ING and who can I contact?
You have at any time the possibility to contact ING should you need any support while applying or managing your personal data. Additionally, you have at any time the right to contact ING if you want to:
- Access (this also includes the right to obtain a copy) or rectify your personal data. ING facilitates access to applicant data and the correction thereof through an on-line self-service system accessible via www.ing.jobs ;
- Erase your personal data data if there is no (longer a) lawful ground for ING to process it
- Restrict the processing of your personal data, if you were to object to the processing or to the accuracy of the processed data or if you wish to retain certain personal data in the context of a possible claim while ING no longer needs the data in the light of the purposes referred to above;
- Object to the processing and transfer of your personal data in sofar the processing is based on our legitimate interests. ING will then cease the processing unless it has compelling legitimate grounds for the processing
- Withdraw your consent to the processing or transfer of your personal data when based on consent (however, this will not affect the lawfulness of earlier processing activities);
- Receive your data in a structured, commonly-used and machine readable format in order to transmit them to another controller (‘right to data portability’). This is only possible insofar we process the data in an automated way related to your employment contract or the prior steps thereto and insofar this does not affect the rights and freedoms of others, including ING ;
- Lodge a complaint with a supervisory authority, if you feel that ING has not acted in line with data protection legislation.
Please send any questions, comments or issues about this Privacy Statement or ING’s applicant data collection and processing activities to Human Resources: ING-BE-PrivacyOfficeHR@ing.com
Please note that this contact information can only be used to handle privacy related enquiries. Information about ING positions or other non-privacy issues will not be answered.
If you feel that your request was not handled in line with the data protection legislation, you may contact the data protection officer (DPO) of ING Belgium: ING-BE-PrivacyOffice@ing.com
When submitting your application, you will be asked to confirm having read and understood this ING Recruitment Privacy Statement.