Recruitment Privacy Policy – Internal Candidate
Volkswagen Financial Services, which jointly designates the entities Volkswagen Bank GmbH – Branch in Portugal and Volkswagen Renting Unipessoal, Lda., respects the privacy of our Site Visitors, Employees, Potential Candidates, Candidates, Customers, Suppliers and Service Providers.
This Privacy Policy describes who we are, for what purposes we may use your data, how we process it, who we share it with, how long we keep it, as well as how you can contact us to exercise your rights.
Who are we?
Your personal data will be processed by the companies Volkswagen Bank GmbH – Branch in Portugal, with the legal person number 980463653, Permanent Representation of Volkswagen Bank GmbH, and Volkswagen Renting Unipessoal, Lda., with the legal person number 507850149, both with registered office at Alfrapark, Edifício G, R/c, Estrada de Alfragide, n.º 67, 2614-519 Amadora, jointly referred to as Volkswagen Financial Services, "VWFS" or "we". The two companies are responsible for the processing of personal data within the meaning of the General Data Protection Regulation ("GDPR") and Law No. 58/2019, of 8 August ("PERSONAL DATA PROTECTION LAW").
For questions related to the processing of your personal data, please contact our Human Resources department at e-mail address vwfsptrecursoshumanos@vwfs.com or our Data Protection Officer at e-mail address dpopt@vwfs.com
Employee Data
With regard to the processing of Employee data, Volkswagen Financial Services and its subcontractors process personal data in strict compliance with the provisions of the General Data Protection Regulation and its implementing laws.
Why do we need Employee data?
Volkswagen Financial Services processes your data for the following purposes: to manage and fulfil the employment contract and/or other contracts and rules governing the relationship with the Employee; talent management and performance appraisal; control compliance with internal policies and procedures; informing internally of the holding of training sessions and keeping a record of the content; management of the execution of employment contracts concluded, namely for the purpose of complying with administrative, judicial, social security and tax obligations, occupational medicine in compliance with the provisions of hygiene, safety and health at work and the conclusion of insurance policies; development of more human relationships with employees, in certain personal situations (birth of children or adoption, marriage of the employee, birthdays of the employee and family members of the respective household, death of family members, etc.); management of complaints and dissemination of information on the activities carried out by Volkswagen Financial Services, based on its legitimate interest in improving and making more effective the services provided.
Will your information be shared with third parties?
Your information may be communicated to third parties, namely Courts, Tax and Customs Authorities and Social Security, under the terms of the law and within the scope of the duty of cooperation.
Volkswagen Financial Services transfers the data to service providers who act as subcontractors exclusively in the name and on behalf of Volkswagen Financial Services under its guidance or support, and who comply with technical and organizational measures equivalent to those to which they are bound.
Personal data may also be accessed by internal and external auditors of Volkswagen Financial Services and the Group in which it operates, ensuring that it is kept confidential and will not be used for purposes unrelated to audits.
Your data will only be processed within the European Economic Area. To the extent strictly necessary and solely for the purposes described above, your data may be transmitted to entities outside the European Economic Area, but Volkswagen Financial Services assures that it will only do so in compliance with the applicable legislation and in order to ensure that the level of protection of your personal data is not compromised.
What are your rights?
At any time, you can ask us to:
· Access to the information we hold about you;
· The rectification of the information, if it is inaccurate or incomplete;
· The erasure or restriction of the processing of your personal data, in certain situations;
· The limitation of processing in certain situations;
· The portability of your data, in certain situations;
· Opposition to the treatment, in certain situations;
· If the processing depends on your consent or agreement and this is carried out by automated means, you have the right to send the personal data previously provided, in a structured, commonly used and computer-readable format.
Your requests will be treated with special care so that it is possible to ensure the effectiveness of your rights. You may be asked to provide proof of your identity in order to ensure that the sharing of personal data is only done with its owner, or person with legitimacy to do so, and for this purpose the request must be submitted in writing to the Human Resources Department through the e-mail vwfsptrecursoshumanos@vwfs.com
Please note that in certain cases (e.g. due to legal requirements) your request may not be immediately fulfilled. In any case, the appropriate response will be provided within a maximum period of one month from the moment the request is made.
You also have the right to lodge a complaint with the National Data Protection Commission (https://www.cnpd.pt/) if you believe that the data processing carried out violates your rights.
Right of access
The data subject has the right to obtain confirmation from Volkswagen Financial Services as to whether or not the data concerning him or her is being processed and, if so, to access his or her personal data and access the information provided for by law.
Right to rectification
The data subject has the right to obtain from Volkswagen Financial Services, without undue delay, the rectification of inaccurate or incomplete data concerning him/her.
Right to erasure ("right to be forgotten")
The data subject has the right to obtain from Volkswagen Financial Services the erasure of his or her data without undue delay, and Volkswagen Financial Services has the obligation to delete the personal data without undue delay where one of the following reasons applies, inter alia, and provided that any statutory data retention period has already elapsed:
a. The personal data are no longer necessary for the purpose for which they were collected or processed;
b. The data subject has withdrawn his/her consent to the processing of data (in cases where the processing is based on consent) and there is no other basis for such processing;
c. The data subject objects to the processing and there are no overriding legitimate interests justifying the processing.
Right to restriction of processing
The data subject has the right to obtain from Volkswagen Financial Services the restriction of processing, if one of the following applies, inter alia:
a. contest the accuracy of the personal data, for a period that allows Volkswagen Financial Services to verify its accuracy;
b. The data processing is lawful and the data subject opposes the erasure of the personal data and requests, in return, the restriction of its use;
c. Volkswagen Financial Services no longer needs the personal data for the purposes of processing, but such data is required by the data subject for the establishment, exercise or defense of legal claims;
d. If you have objected to the processing, until it is established that the legitimate grounds of the controller prevail over those of the data subject.
Right to data portability
If the processing depends on the consent of the data subject and this consent has been given by automated means, the data subject has the right to receive the personal data concerning him or her that he or she has provided to Volkswagen Financial Services in a structured, commonly used and machine-readable format.
Right to object
In cases where the data processing is carried out (i) in the context of the legitimate interests pursued by Volkswagen Financial Services; (ii) for direct marketing purposes or (iii) for profiling, you may also, at any time, object to the processing of your personal data.
Can I revoke my consent at a later date?
If consent is legally required for the processing of personal data, the data subject has the right to withdraw consent at any time, although this right does not compromise the lawfulness of the processing carried out on the basis of the consent previously given or the subsequent processing of the same data based on another legal basis, such as the performance of the contract or the legal obligation to which Volkswagen Financial Services is subject.
If you wish to withdraw your consent, you can contact us at the vwfsptrecursoshumanos@vwfs.com email address.
Use of Employee and Household Data
In social and open events promoted by Volkswagen Financial Services, it may be necessary to collect data from the Employee and his/her family for the purposes of organizing the event or contracting the insurance associated with the activities to be carried out at the event.
On the other hand, at social and open events promoted by Volkswagen Financial Services, the Employee may always object to the collection and/or dissemination of photographic records or filming.
What are the data retention periods?
The personal data provided will be kept for the period necessary for the purpose for which the processing is determined.
The personal data collected throughout the term of the contract will be kept throughout the term of the contract, and for an additional period of 10 (ten) years from the respective termination, or from the end of the retention period determined by law, when it is after the termination.
The data collected will be kept for the indicated periods to the extent that they are appropriate and relevant for the purposes for which they are intended, and their processing will be limited to what is strictly necessary for such purposes.
Do you have any questions?
If you have any questions regarding the processing of your personal data, or wish to exercise any of your rights, please contact us at the following addresses:
• Volkswagen Financial Services
Alfrapark, Edifício G, Estrada de Alfragide, 67, 2614-519
Amadora
Email: vwfsptrecursoshumanos@vwfs.com
• Data Protection Officer
Volkswagen Financial Services has appointed a Damage Protection Officer ("DPO") who:
- Monitors the compliance of the data processing with the applicable standards and policies of Volkswagen Financial Services for the processing, including the awareness and training of the personnel involved in the data processing operations, and carrying out the corresponding audits;
- Informs and advises Volkswagen Financial Services and its employees who process the data regarding their obligations under national and European Union data protection legal provisions;
- It is a point of contact both with the Client or User and with the National Data Protection Commission ("CNPD") to clarify issues related to the processing of their data;
- Cooperates with the CNPD;
- Provides information and advises the controller on its obligations in the field of privacy and data protection.
You can contact the DPO at the following addresses:
Mail: Alfrapark, Edifício G, Estrada de Alfragide, 67, 2614-519 Amadora
Email: dpopt@vwfs.com