Privacy Policy for users and candidates of ABANCA's employment portal
1. Who is responsible for processing your personal data?
The controller responsible for processing your personal data is ABANCA Corporación Bancaria, S.A. (hereinafter, “ABANCA” or the “Entity”), holder of Tax ID No. A70302039 and with registered office in Betanzos (A Coruña), at Calle Cantón Claudino Pita, No. 2, Postcode 15300.
At ABANCA we have a formally appointed Data Protection Officer (hereinafter, “DPO”), whom you may contact in writing, if necessary, to obtain further information about any of the points included in this Privacy Policy and to submit any doubts, queries or complaints related to the processing of your personal data, through the following email address: privacidad@abanca.com.
2. What is the source of your personal data and what data do we process?
We must distinguish between the sources from which your personal data originate and the categories of personal data that we process:
2.1. Sources from which your personal data originate
Your personal data processed by ABANCA may come from you directly (when you provide or submit them as a user of ABANCA's employment portal, job applicant or candidate in recruitment processes in which you participate, as an intern or as a participant in talent attraction programmes promoted by ABANCA), be generated within ABANCA (as a user of the employment portal or derived from the development and management of the aforementioned processes), or originate from external sources (that is, come from third parties from whom we obtain data relating to you under the consent you have granted for this purpose, or under any other legally established legal basis that permits it). Below, we provide detailed information regarding the aforementioned internal and external sources from which your personal data may originate:
Data provided by you directly as a user of the employment portal, job applicant or candidate in recruitment processes in which you participate, as an intern or as a participant in talent attraction programmes promoted by ABANCA.
Data generated about you during your browsing of the employment portal, as well as those derived from the management and development of the recruitment processes in which you participate as a job applicant or candidate, as an intern or as a participant in talent attraction programmes promoted by ABANCA.
Training and/or educational institutions (such as Universities, Business Schools, etc.).
Employment portals.
Talent scouts (headhunters) or recruitment agencies.
Professional associations.
Service providers specialised in carrying out selection tests (e.g. psychometric tests).
Open social networks and, in particular, those geared towards business, commercial and employment use (e.g. Linkedin, Xing, Viadeo, Womenalia, etc.).
2.2. Categories of personal data
At ABANCA we process different types of personal data in order to achieve the purposes set out in section 3 “Why and on what legal basis do we process your personal data?” of this Privacy Policy.
In order to provide you with clear and detailed information in this regard, we have grouped the personal data we process into the following categories:
Identification and contact data: first name, surname(s), identity document (DNI, passport or NIE), postal address, email address and landline or mobile telephone number.
Data relating to your voice and image obtained through the capture of your image and/or voice by photograph and/or video during the selection procedure(s) and/or interview(s) that may, where applicable, take place as part of the relevant selection procedure and/or interview or to assess the suitability of your application for the position offered. In these cases, and prior to the start of the capture of your image and/or voice, you will be informed of this circumstance and may object to such capture.
Data relating to personal circumstances contained in your identity document: sex, nationality, place and date of birth and the names of your parents.
Data relating to family and social circumstances: marital status and family situation.
Academic data: education/qualifications and, where applicable, membership of professional associations and/or bodies.
Employment data, if the candidate has previous work experience (e.g. employment history, type of contract, job position, length of service, professional experience, etc.).
Additional data provided by the candidate; e.g. CV or a cover letter and/or letter of recommendation.
Data inferred or deduced from the analysis and processing of the other categories of personal data: grouping job applicants or candidates into categories and segments based on objective criteria such as age, level of education and/or similar.
Special categories of data: we refer to data which, by their nature, are particularly sensitive in relation to fundamental rights and freedoms and which, therefore, deserve special protection, since their processing could entail a greater risk for the individual. At ABANCA, as a general rule, we do not collect or use this type of personal data; we may only collect and process them if you apply for vacancies on the employment portal aimed at persons with disabilities, in which case, in the context of that selection process, we may request information about your degree of disability.
The candidate guarantees, under his/her sole responsibility, that all data provided to ABANCA within the framework of the relevant recruitment process, as an intern or as a participant in talent programmes promoted by ABANCA, will be truthful, accurate, complete and up to date, undertaking to notify ABANCA of any changes thereto and assuming responsibility for any inaccuracies or errors therein.
3. Why and on what legal basis do we process your personal data?
Below we inform you about the different processing activities involving your personal data for which ABANCA is responsible, specifying the purposes and legal bases for each of them. Additionally, and in accordance with the provisions of the previous subsection 2.2. (“Categories of personal data”), the specific categories of data used in each processing activity are detailed.
3.1 Processing necessary in your capacity as a candidate within the framework of recruitment processes or in your capacity as an intern or as a participant in talent programmes promoted by ABANCA.
In this subsection we refer to the purposes of processing whose legal basis lies in the development and/or execution of the processes and pre-contractual relationships that you request and/or maintain with ABANCA.
Below are the purposes of the aforementioned processing activities, indicating their respective purposes, as well as the categories of personal data used in each of them:
To be able to contact you in order to send you job offers that specifically match your professional profile on the basis of the information you have provided on ABANCA's employment portal.
To assess the suitability of your application in those recruitment processes or talent attraction programmes promoted by ABANCA in which you apply to participate. The application to participate in the aforementioned recruitment processes may be made: (i) directly, by completing the corresponding form on ABANCA's employment portal (empleo.abanca.com) or on any other online platforms established by ABANCA from time to time; or (ii) indirectly, when you ask third parties (such as Universities, Business Schools, Professional Associations, etc.) to communicate your personal data to us for inclusion in a specific selection process, subject to those third parties having previously obtained the corresponding consent.
To analyse the suitability of the candidate's professional profile for the vacancy through the information contained in his/her CV, the psychometric tests that, where applicable, he/she may have taken during the relevant selection process, as well as any additional information that, where applicable, he/she may have provided during the same.
To assess the candidate's application for professional internships at ABANCA, following registration in ABANCA's “University Internships” programme through its online platform or through any means that may be established by the Universities, Business Schools or professional associations with which ABANCA has signed a collaboration agreement.
To assess the candidate's application to participate in ABANCA training programmes, following registration on the corresponding online platform or through any means that may be established by the Universities or Business Schools with which ABANCA has signed a collaboration agreement.
If you provide us with third-party data, such data will be processed solely for the purpose of checking and verifying the references and background information that, where applicable, you may provide to us.
For the fulfilment of the purposes indicated above, we may process personal data corresponding to the following categories detailed in section 2.2 (“Categories of personal data”) of this Privacy Policy: Identification and contact data; Data relating to your voice and image; Data relating to personal circumstances contained in your identity document; Data relating to family and social circumstances; Academic data; Employment data; Additional data provided by the candidate; Special categories of data (in accordance with the provisions of subsection 2.2).
3.2. Processing carried out for compliance with legal obligations.
In this subsection we refer to those processing activities whose legal basis lies in compliance with legal obligations to which ABANCA is subject by law or by application of the relevant collective bargaining agreement.
Below are the processing operations involving your personal data that we may carry out in the context of the aforementioned processing and depending on the legal framework applicable to ABANCA in each case:
Disclosure of information to public administrations as determined by the legislation in force at any given time, such as Labour Authorities, the State Public Employment Service, the State Foundation for Training in Employment, the General Treasury of the Social Security, the Spanish Tax Agency, as well as judicial bodies and trade union bodies.
Communication of information to the Legal Representation of Workers (RLT) in labour matters, as established by the labour legislation in force at any given time, in compliance with the legal duty to inform.
In order to comply with the obligations imposed by law, we may process personal data corresponding to the following categories detailed in subsection 2.2. (“Categories of data”) of this Privacy Policy: Identification and contact data; and Data relating to personal circumstances contained in your identity document.
3.3. Processing based on ABANCA's legitimate interest
In this section we refer to the processing of your personal data whose legal basis is the satisfaction of legitimate interests pursued by ABANCA, provided that such legitimate interests do not override your own interests or fundamental rights and freedoms.
For this reason, prior to carrying out the processing described in this subsection 3.3., we have carried out a balancing test between your rights and ABANCA's legitimate interest, concluding that the latter prevails. You may consult the balancing test we have carried out by contacting our DPO at the following email address: privacidad@abanca.com.
3.3.1 Anonymisation of your data
Prior to the deletion of your personal data, according to the criteria detailed in section 6 (“How long do we keep your personal data?”) of this Privacy Policy, at ABANCA we will carry out processing consisting of the anonymisation of your data.
The anonymisation of data itself constitutes processing of personal data and its purpose is to enable ABANCA to carry out statistical studies and improve its recruitment processes.
The anonymisation of your data will be complete, making it impossible after such process to link the retained information to you.
3.4. Processing based on your consent as a user of ABANCA's employment portal
In this subsection we refer to the purposes for processing your personal data that we will carry out exclusively if we have requested and obtained your prior consent for that purpose.
The legal basis for processing your data therefore lies in the consent that, where applicable, you have granted us for each of them.
We remind you that such consent is revocable, that is, you may withdraw it whenever you wish and, in that case, ABANCA will cease carrying out the corresponding processing. However, withdrawal of consent will not have retroactive effects, so it will not affect the lawfulness of the processing previously carried out. To revoke or withdraw the consent that, where applicable, you have granted us, you may contact ABANCA's Recruitment Department in writing in the manner indicated in section 7 (“What are your rights?”) of this Privacy Policy.
3.4.1. Managing your request for access, sign-up and registration on ABANCA's employment portal
We will process your personal data to handle your request for sign-up and registration on ABANCA's employment portal, to carry out all procedures arising from such request, as well as to facilitate your access to ABANCA's employment portal.
For the purposes indicated, we may process personal data corresponding to the following categories detailed in section 2.2. (“Categories of personal data”) of this Privacy Policy: Identification and contact data; Data relating to personal circumstances contained in your identity document; Data relating to family and social circumstances; Academic data; Employment data; Additional data provided by the candidate; Special categories of data (in accordance with the provisions of subsection 2.2).
3.4.2. Offering you information about job vacancies
In order to receive information relating to job vacancies, you must configure the sending of notifications through your user profile on ABANCA's employment portal. In these cases, we will request your consent in order to offer you, by any means, including electronic means, information about new job vacancies, talent programmes promoted by ABANCA or upcoming recruitment procedures carried out by ABANCA or by the other companies of the ABANCA Economic Group that may be of interest to you according to your profile.
The information referred to in the previous paragraph will be provided while your user account on the portal remains active and you have not revoked your consent for this purpose.
For the purposes indicated, we may process personal data corresponding to the following categories detailed in section 2.2. (“Categories of personal data”) of this Privacy Policy: Identification and contact data.
4. With whom do we share your personal data?
We will only share your personal data with third parties when you have granted us your consent to do so or there is another legal basis that supports such disclosure of data. Accordingly, the data processing activities carried out by ABANCA described in this Privacy Policy may entail your data being disclosed to the following recipients:
To the Companies of the ABANCA Economic Group and collaborating companies.
To its service providers. The purpose of these disclosures will be the management by these third parties, known as processors, of the provision of certain services on behalf of ABANCA. They will process your personal data on our behalf and for our account, following our instructions at all times. Under no circumstances may they process your personal data for their own purposes. At ABANCA we follow strict criteria for selecting service providers and we enter into the corresponding data processing agreement with each of them, which sets out the conditions of confidentiality, security and data processing in accordance with the regulations in force at any given time.
To the competent bodies of the Public Administrations as determined by the legislation in force at any given time, such as Labour Authorities, the State Public Employment Service, the State Foundation for Training in Employment, the General Treasury of the Social Security or the Spanish Tax Agency, as well as judicial bodies and trade union bodies, in all cases for the exercise of their legitimate powers and for the purpose of complying with the corresponding legal obligations and always within the scope determined by the legislation applicable at any given time.
5. Is any international transfer of your personal data envisaged?
We inform you that no international transfer of data is envisaged in order to achieve the purposes indicated in section 3 (“Why and on what legal basis do we process your personal data?”) of this Privacy Policy.
6. How long do we keep your personal data?
The personal data obtained and/or generated as a result of creating your user profile on ABANCA's employment portal will be kept for the period during which such profile remains active. In this regard, we inform you that you may unsubscribe your user profile at any time by accessing the corresponding section within ABANCA's employment portal itself.
Notwithstanding the provisions of the previous paragraph, we will automatically deactivate your profile on ABANCA's employment portal after two (2) years have elapsed without any use being made of it. For these purposes, it will be understood that you do not use your profile when, during the aforementioned period of two (2) years, you do not update your information or do not submit an application to any selection process.
If, during the period in which your profile remains active, the candidate passes a selection process on ABANCA's employment portal, he/she will become part of the workforce, acquiring the status of “internal candidate”, so that your profile will also remain active throughout the entire period during which you maintain an employment relationship with ABANCA.
If, subsequently and for any reason, your employment relationship with ABANCA ends, you will cease to have the status of “internal candidate”, your initial external candidate profile will be reactivated, and the aforementioned period of two (2) years will begin to be counted again from that moment.
Once the cancellation of your profile on ABANCA's employment portal has been processed, whether at your express request or due to the lapse of the aforementioned period of two (2) years, your data will be deleted.
7. What are your rights?
Data protection regulations grant you a series of rights in relation to the processing of your personal data:
Right of access. You may know what type of data we are processing and the characteristics of the processing we are carrying out.
Right to rectification. You may request the modification of your data when they are inaccurate or incomplete.
Right to portability. You may obtain a copy in an interoperable format of the data being processed.
Right to restriction of processing. You may request the restriction of the processing of your personal data when any of the conditions laid down by law are met:
- When you contest the accuracy of your personal data, during the period in which ABANCA verifies their accuracy;
- When the processing is unlawful but you oppose the deletion of your data;
- When ABANCA does not need to process your data but you need them for the establishment, exercise or defence of legal claims; and
- When you have objected to the processing of your data carried out for the performance of a task carried out in the public interest or for the purposes of a legitimate interest while it is being verified whether the legitimate grounds for the processing override yours.
Right to erasure. You may request the deletion of your data when the processing is no longer necessary.
Right to object. You may request that the sending of commercial communications cease under the terms indicated above.
Right to lodge a complaint with the supervisory authority (in Spain, the Spanish Data Protection Agency: www.aepd.es.
You may exercise your rights by writing to ABANCA's Recruitment Department at the following postal address: Rúa Nueva 30, 5th floor, Postcode 15003, A Coruña. In such communication you must indicate in the Subject line “Data Protection - ABANCA Employment Portal” and specify the specific right you wish to exercise.
We will process your request as quickly as possible and, in any event, within the legal period of one (1) month from receipt of your letter. This period may be extended by a further two (2) months if necessary, taking into account the complexity and number of requests received. In the latter case, you will be informed of the extension within the first month from receipt of the request, stating the reasons for the delay.
8. Amendments to this Privacy Policy
This Privacy Policy will be reviewed and updated to comply with any regulatory changes that may occur from time to time or when ABANCA carries out new processing of your data. For this reason, it is important that you periodically review its content.
The latest update of this document was made in September 2023.