Privacy notice

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Date of latest revision: 23/11/2023

Banque Internationale à Luxembourg S.A., 69, Route d’Esch L-1470 Luxembourg is a European financial institution and, as such, processes personal data in accordance with the data protection obligations set out in the EU General Data Protection Regulation 2016/679 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. To comply with GDPR, BIL has implemented data protection principles through its Data Protection Policy, in addition to local privacy laws and regulations.

Purpose and scope of this Privacy Notice

BIL, acting as a Data Controller when collecting your personal data in the context of the selection and hiring process, must provide you with information on the processing of your personal data.

This Privacy Notice outlines in a transparent way how BIL processes your personal data, i.e. collects, handles, stores and protects it during the selection and hiring process.

This Privacy Notice only applies to personal data of job or internship applicants (‘candidates’), processed by BIL in its name and on behalf of its Luxembourg-based entities.

What is personal data?

Personal data means any information relating to you and that enable to identify you either directly or indirectly.

What personal data does BIL collect from you as a candidate?

BIL aims to collect and process only the personal data that is strictly necessary for the relevant purpose.

In the course of the selection and hiring process, BIL processes personal data collected directly from you or from another source. The following categories of personal data are processed, depending on the stage of the selection and hiring process.

Categories of personal data collected directly from you:
  • Personal identification data such as first and last name, date and place of birth, gender, nationality, civil status, parental status, address, phone number, email address, ID document or passport…
  • Any relevant additional skills and information that may be of relevance such as driving licence, secondary activities, hobbies...
  • Employment administration: education and professional background (CV, academic titles, schools and universities, qualifications, languages, previous employment, length of previous employment contracts, former titles, sector), criminal check record, work permit (if applicable)…
  • Financial data: salary information, pay slips…
  • Relatives’ and contacts’ data: identification data of relatives (legal partner, children...), professional references…
  • Personal messages and comments sent by candidates of their own accord such as feedback on the hiring process…
Categories of personal data collected from other sources
  • Professional experience such as previous employment, length of previous employment contracts…
    Please note that, with your consent, BIL may check your work history, which primarily involves contacting the professional references you provide for this purpose during the recruitment process.
  • Information on individual risk profile such as presence in risk intelligence databases, …
    Please note that BIL uses a screening platform called ‘Worldcheck’ in order to assess the risks associated with your profile (Politically Exposed Persons, integrity…) and protect itself from financial crime, regulatory and reputation risks.Personal data may also be created as a result of your use of our selection management system (login details, etc…).
When and how does BIL collect your personal data?

BIL collects personal data from you during the selection and hiring process.

These personal data may be either provided directly by you (via our website, during interviews…) to BIL or derived from activities carried out by BIL in the course of the selection and hiring process.

Are you obliged to provide BIL with your personal data?

Should you fail to provide the requested information, BIL may not be able to process your application and take the selection and hiring process any further.

On which basis and why does BIL collect and process your personal data?

Processing refers to every activity that can be carried out in connection with personal data, as collecting, recording, storing, adjusting, organising, using, disclosing, transferring or deleting it in accordance with applicable laws.

BIL collects and processes your personal data to execute different processes depending on the needs in the course of the selection and hiring process.

BIL aims to collect and process only the personal data that is strictly necessary for the following purposes:

to assess your suitability for a position within BIL or one of its subsidiaries, and potentially to make you a job/internship offer.

With your consent, BIL may check your work history, which primarily involves contacting professional references you have provided for this purpose.

to comply with its legal obligations:

  • obligations under Luxembourg laws and regulations such as equality and diversity;
  • legal duties as future employer, mainly with the Administration de l’Emploi (when making an offer…);
  • legal obligations to address requests and communications from competent authorities and courts.
  • other business purposes:
    • the assessment of the specific risks associated to your prior activities when relevant;
    • the need to be able to deal with complaints or legal disputes involving you or service providers used for our selection and hiring process;
    • collection of feedback, conduct of surveys and data analytics studies (to review satisfaction, ESG reporting…).

BIL does not process your personal data for profiling or automated decision making in the context of the selection process.

BIL is required by the GDPR to have a legitimate ground to process the information we hold about you. By submitting your application, you hereby agree to BIL processing the personal data you have provided. You may retract this consent at any time by withdrawing from the selection and hiring process, in accordance with the terms and conditions set out below. Please note that this will not impact the lawfulness of any processing performed based on your consent prior to the withdrawal of your application.

How long does BIL store your personal data?

BIL only stores your personal data for the length of time required to process applications and hiring. Your application will therefore be anonymized after 24 months of inactivity (inactivity being defined as not accessing your profile on our career site), unless you request otherwise. An email will be sent to you 30 days prior to the anonymization of your data, asking whether or not you would like your data to be retained for 24 additional months. In case you do not answer, your data will be anonymized.

With whom does BIL share your personal data and how?

Your personal data is shared within BIL and its Luxembourg-based entities to the employees authorized to process your personal data only to the extent that is needed for the purpose defined, meaning to perform the selection and hiring process. Our employees are subject to confidentiality obligations and may not disclose your personal data, unlawfully or unnecessarily.

BIL also shares your personal data with external third parties depending on the needs and services provided in the context of the selection and hiring process. These external third parties include:

HR service providers with which BIL has entered into service agreements for the management of applications and recruitment;

Luxembourg Administration de l’Emploi to the extent required.

Our HR service providers are based in the EU but may be required to disclose your personal data to parties or clouds located outside the European Economic Area (EEA) (in particular the United States), whose laws may not provide the same level of data protection as that ensured within EEA. In such cases, BIL ensures that there are safeguards in place to protect your personal data, such as standard contractual clauses in agreements with service providers or personal data protection adequacy decisions adopted by the European Commission.

More specifically, for the application management platform through which your application is submitted and processed, BIL enlists the services of Cornerstone OnDemand Europe Ltd., registered at 4 Coleman Street, London, United Kingdom, EC2R 5AR.

Which security measures did BIL implement to protect your personal data?

BIL takes appropriate technical and organizational measures (policies and procedures, IT security, etc) to ensure the confidentiality and integrity of your personal data and the way it’s processed.

When your personal data is shared with third parties, BIL puts in place appropriate measures to make sure that those third parties keep your personal information secure.

What are your rights and how does BIL respect them?

BIL makes sure that the rights related to the protection of your personal data are fully respected and that you may exercise them.

Hence you have a right to:

  • request access to your personal data and get an overview of the personal data that BIL processes and/or a copy of this data;
  • ask BIL to rectify your personal data in case it is incorrect;
  • ask BIL to restrict the use of your personal data, within the limits provided by applicable laws and the GDPR;
  • object to the processing of your personal data within the limits provided by applicable laws and the GDPR;
  • request data portability, i.e. the transfer of your personal data either directly to you or to another company.
  • request the deletion of your personal data, under the conditions and within the limits provided by applicable laws and the GDPR.
Who can you contact for personal data protection related questions and how can you exercise your rights?

Should you have any question on the way BIL processes your personal data or wish to exercise any of the rights listed above, please submit a written and signed request, including your identity, to BIL’s Data Protection Officer by email at DPO@bil.com or by post: Banque Internationale à Luxembourg, 69 route d’Esch, L-2953 Luxembourg. BIL will answer your request within one month of the receipt of your request. This can be extended by a further two months if your request is complex.

Should you consider that the DPO has not been able to assist you with your concerns, you may lodge a complaint with the Commission Nationale pour la Protection des Données (https://cnpd.public.lu/en.html) by postmail to the following address : 15, boulevard du Jazz, L-4370 Belvaux.

Changes to this Privacy Notice

This Privacy Notice may be amended to remain compliant with any changes in law and/or to reflect changes in the way BIL processes personal data. The revision date at the top of this page will be amended accordingly and we encourage you to regularly review our Privacy Notice available on our website to stay informed.

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