1. Introduction
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ING Groep N.V. (along with its affiliates and
subsidiaries, referred to as “ING”) is a global organisation
domiciled in Europe, South and North America, Asia and Australia
(see also
www.ing.com). ING is committed to protecting the
privacy of external and internal applicants. When an applicant
visits the ING career website or uses the internal job vacancies
site, ING collects information (personal data) about the applicant
(e.g. via web forms). ING uses the applicant’s personal data in a
fair and lawful manner; this means that ING will collect and
process personal data in accordance with applicable privacy laws.
Protecting the privacy and personal data of applicants is of the
utmost importance to ING and is a significant aspect of the way ING
creates, organises and implements its recruiting activities. This
privacy statement is intended to inform applicants with regard to
ING’s processing of recruitment data and is applicable to ING
recruitment and selection activities. This recruitment privacy
statement may be modified from time to time to comply with
applicable laws or to reflect updated business practices. Please
check this page regularly for any changes since there is no prior
notice for updates.
2. Purposes
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Personal information (applicant data) submitted
by an applicant to ING will only be used by ING to support a
responsible, effective and efficient recruitment and selection
process. ING will collect and process applicant data from
unsolicited applications and from ING current open positions. ING
will process applicant data for recruitment purposes only. ING
recruitment purposes are: matching applicant data with ING current
open positions, communicating ING recruitment and selection
procedures, contacting applicants to schedule interviews/tests and
sending information to applicants about other relevant vacancies.
Processing includes; obtaining, recording, holding, organizing,
transferring, adapting, amending, recovering, consulting, using,
limiting, disclosing by transmission, disseminating or otherwise
making available, aligning, blocking, destroying and erasing
recruitment data.
3. Applicant Data
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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.
Examples of applicant data include, but are not limited to:
applicant contact details (name, gender, address, language, etc.),
applicant education (academic, courses, etc) work history (previous
employers, references, etc.)
ING does not collect or process any 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. If, owing to certain
circumstances, ING does collect sensitive applicant data, the
applicant’s explicit prior written consent will be asked. Please
note that by providing ING with unsolicited sensitive applicant
data, the applicant consents to ING’s processing of this sensitive
applicant data for recruitment purposes.
The applicant data that ING collects and
processes will be adequate, relevant and not excessive relative to
the specified purposes for which the applicant data are collected
and processed. Applicant data will be as accurate as possible and,
as necessary in accordance with applicable laws, kept up to date by
applicants and ING.
4. Disclosure
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ING may disclose certain applicant data to a
supplier or contractor organisation supplying services which
require the use and/or creation of applicant data for the purposes
described in this privacy statement and in accordance with
applicable laws. In these limited instances, selected third parties
may access applicant data. Prior to disclosing any information to
any third party, ING will ensure that all third party recipients
are bound to strict standards of security. In the event of a merger
and/or acquisition, ING may disclose an applicant’s information to
the third party involved in such merger and/or acquisition but only
to authorised personnel involved in the recruitment process.
ING does not sell or trade applicant data to
any third party. ING may be obliged to disclose certain applicant
data to third parties, such as government authorities, in
accordance with applicable laws. It may also be necessary for ING
to disclose applicant data so as to protect the legal rights of
ING, again in accordance with applicable laws.
5. Transfer
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ING’s recruitment & selection career and
job vacancies site (
www.ing.jobs and
www.jobvacancies.intranet ) offers applicants the
opportunity to apply on-line (both unsolicited applications and ING
current open positions). Applicants can indicate their preferences
for a specific country during the on-line application process. If
an applicant chooses to apply outside his or her country of origin,
the application data will be transferred to the country where the
vacancy exists. The transfer of the application data is for
recruitment & selection purposes only. Applicants consent to
transfer of their application data and to ING worldwide recruiters
contacting them to start recruitment activities by accepting this
ING recruitment privacy statement.
To operate as a global business and to promote
an applicant’s career within ING, it is necessary to process and
transfer applicant data within ING's worldwide operations.
Applicant data will be entered in an international database that is
available for ING recruiters from the various countries where ING
operates. The use of this database will involve transferring
applicant data outside the country of origin of the applicant.
Applicants consent to transfer of their application data (for
processing by worldwide ING recruiters) to the various countries
where ING operates by accepting this ING recruitment privacy
statement.
ING will ensure adequate security measures for
the transfer and processing of applicant data to the ING locations
in the various countries where ING operates.
6. Retention
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ING will retain applicant data during the
recruitment and selection process. ING will only retain applicant
data after the recruitment and selection process if there is a
legal obligation to do so (e.g. equal opportunity requirements in
local employment laws). ING may also retain applicant data if there
is a ‘business need’ to keep the applicant data, e.g. keeping an
applicant’s resume on file if a suitable vacancy arises. Without
prejudice to local legislation, applicant data will be kept for a
maximum of 2 years (i.e. the end of the calendar year following
your application). This implies that retention periods in local
legislation always need to be taken into account and complied with.
After the retention period the applicant data will be completely
deleted from ING’s system.
7. Security
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ING uses a number of technical, physical and
organizational security measures to assure the integrity,
confidentiality and availability of applicant data. ING has
implemented security technologies to protect the stored applicant
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 applicant data is limited to ING processors
who are involved in ING recruitment activities. ING processors who
have access to applicant data are obliged to respect the privacy of
applicants visiting ING’s website and the confidentiality of their
applicant data. ING ensures adequate security to protect manual and
electronic processing of applicant data and prevent its misuse, all
in accordance with applicable local legal requirements. ING also
ensures (contractually) that third parties and affiliates
processing applicant data on ING’s behalf, will observe similarly
adequate security measures again in accordance with applicable
local legal requirements.
An applicant has an important role to play in
assisting ING in keeping applicant data secure. An applicant should
at all times keep his or her password confidential and use the
correct procedure to log in and out of the ING recruitment
website.
8. Applicant’s rights
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An applicant has the right to access his or her
applicant data that ING holds. ING facilitates access to applicant
data through an on-line self-service system accessible via
www.ing.jobs or via the ING intranet. An
applicant has the right to request ING to correct his or her
applicant data. Correction also implies supplementing, deletion,
blocking or ensuring in another way that applicant data will no
longer be used. ING only has an obligation to correct applicant
data when the data is factually inaccurate, incomplete or
irrelevant to the purpose for which ING processes the data
(correction of applicant data is also facilitated via
self-service).
If an applicant is unable to use the
self-service system he or she can contact ING (see §9) to exercise his or her access and
correction rights. ING may also collect and process applicant data
(e.g. test data) that is not accessible via self-service. By
contacting ING (see § 9) the applicant can
exercise his or her access and correction rights. ING will process
the applicant’s requests and rectify errors in a timely manner.
9. Contact Information
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Please send any questions, comments or issues
about this privacy statement or ING’s applicant data collection and
processing activities to:
ING Data privacy
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.
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