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Privacy statement

Introduction
Van Lanschot Kempen N.V. (together with its business units and subsidiaries, including Kempen & Co N.V., hereinafter referred to as ‘Van Lanschot Kempen’) is a specialized, independent wealth manager. This is the privacy statement for all candidates who participate in the recruitment and selection procedure of Van Lanschot Kempen. The recruitment and selection procedure starts at the time of applying for a job with Van Lanschot Kempen. The procedure ends at the time of rejection or signing an employment contract with Van Lanschot Kempen. The present privacy statement describes how Van Lanschot Kempen uses and processes personal data collected during the recruitment and selection procedure.

Responsibility for the processing of personal data
Van Lanschot Kempen is responsible for the processing of personal data. The full address details of Van Lanschot Kempen are: Beethovenstraat 300, 1077 WZ Amsterdam, the Netherlands.

Origin of personal data
The majority of the personal data that Van Lanschot Kempen processes are provided by the applicant. In addition, Van Lanschot Kempen can use personal data retrieved from third-party sources. The following are examples of such sources:
  • Employment or recruitment agencies
  • Public sources such as search engines and social media sites that are not private
  • The Incident Warning System for Financial Institutions. The site of NVB (the Dutch Banking Association) provides further details about the warning system and how it works: nvb.nl/IFI.
A screening will take place prior to employment. Within this context, Van Lanschot Kempen will receive personal data from the agency that is responsible for the screening. Read more about the screening below under ‘Pre-employment screening’.

Processing of personal data
Van Lanschot Kempen uses and processes personal data for one or several of the following reasons:

1. Laws and regulations
Van Lanschot Kempen processes personal data in consideration of various laws and regulations. Van Lanschot Kempen has to maintain high ethical standards in its operations and management to control integrity risks and to safeguard the integrity of the organization and the entire financial sector. One aspect of ethical management is the selection of honest, trustworthy employees.

2. Legitimate interest
Van Lanschot Kempen may also use personal data to protect its ‘legitimate interest’ provided that the interest of Van Lanschot Kempen in using personal data overrides the applicant’s right to privacy. Van Lanschot Kempen will balance everyone’s interests in this respect. Examples of legitimate interests that Van Lanschot Kempen has in using personal data in the recruitment and selection procedure include:
  • The recruitment and selection of suitably qualified employees
  • The protection of property and personal data of Van Lanschot Kempen
  • The protection of the security of Van Lanschot Kempen and its staff
Purposes for processing personal data
Van Lanschot Kempen uses personal data for the following purposes:

1. Recruitment and selection of suitably qualified employees. Van Lanschot Kempen uses personal data to assess the suitability of candidates for the role concerned. In the event that the candidate is hired, Van Lanschot Kempen will use the personal data to draft the employment contract.

2. Protection of integrity and security. Van Lanschot Kempen also uses personal data to provide maximum protection for its property, its personal data, and its employees against any form of infringement or damage.

3. HR management. Van Lanschot Kempen uses the personal data of applicants for the purpose of pursuing a responsible, effective, and efficient HR policy. This may include, for instance, research in the field of people analytics. These statistical analyses focus on assessing the impact and effectiveness of the pursued HR strategy. The results of the studies and surveys and the corresponding recommendations can never be traced back to individual persons. One example that comes to mind is the equality and diversity policy pursued by Van Lanschot Kempen.

4. Laws and regulations. Finally, Van Lanschot Kempen uses personal data of employees to be able to comply with applicable laws and regulations. Under the Financial Supervision Act and subordinate legislation, Van Lanschot Kempen has a duty to abide by ethical management principles. One aspect of ethical management is the selection of honest, trustworthy employees.

5. Pre-employment screening. Van Lanschot Kempen attaches great importance to safeguarding the reliability, professionalism, and security of its organization. That is why the final phase of the application procedure consists of a pre-employment screening. This screening may likewise involve the use of personal data collected from public sources.

The pre-employment screening of Van Lanschot Kempen will in any event consist of the following elements:
  • Focum Plus credit check
  • Investigation into irregularities
  • Person identification
  • Personal integrity statement
  • Formal education
  • Depending on the position, verification of the professional experience over the past two to five years
  • Certificate of good conduct (VOG)
The screening consists of an internal and an external part. Van Lanschot Kempen will carry out the internal part and will, within that context, request, examine, and verify information. For the external screening (applicable only to applications for positions with Van Lanschot Kempen in the Netherlands), Van Lanschot Kempen hires a specialized screening agency, Validata (for further details, please go to www.validatagroup.com). We will provide this agency with the following personal data: name, telephone number, email address, and curriculum vitae.

Use for purposes other than for which Van Lanschot Kempen initially obtained the personal data
Van Lanschot Kempen is entitled to use personal data also for purposes other than for which they were originally obtained, provided that the new purpose is in keeping with the purpose for which the personal data were originally obtained.

Van Lanschot Kempen is entitled to share personal data with third parties who can help us select suitable candidates. Examples include recruitment and selection agencies and employment agencies. Van Lanschot Kempen may also share personal data with assessment suppliers, for the purpose of a personality test, for example.

At Van Lanschot Kempen, we are very careful in selecting the partners with whom we work. Van Lanschot Kempen makes clear contractual agreements with these partners on how they should use and process personal data. The responsibility for work done by third parties on the instructions of Van Lanschot Kempen remains with Van Lanschot Kempen.

Protection and storage of personal data 
Van Lanschot Kempen exercises the utmost caution to provide maximum protection of personal data. The method of operation is continuously adapted to a level appropriate to the sensitivity of the personal data.

The basic principle in establishing the criteria for the personal data storage period is that the personal data should never be held for longer than is necessary for the purpose for which they were collected.

Privacy legislation does not set out any specific maximum or minimum retention periods for personal data. Other laws may specify certain minimum retention periods. In that event, it is mandatory to keep the personal data for the specified minimum period of time.

In principle, Van Lanschot Kempen will keep the personal data of rejected applicants for one year starting from the date of rejection. Rejected applicants can send an email message to talent@vanlanschotkempen.com to request deletion of their data. For candidates who are hired, Van Lanschot Kempen will keep their personal data for the same period of time as applies to its employees. Most of the personal data of employees are kept for a period of seven years after termination of employment.

Rights
Applicants can send an email message to the Talent Attraction department of Van Lanschot Kempen at talent@vanlanschotkempen.com to request inspection of the personal data processed in respect of the applicant concerned. In addition, applicants are entitled to ask Van Lanschot Kempen to correct, supplement or delete their personal data.

Personal data protection officer
Van Lanschot Kempen has a designated data protection officer. Within the Van Lanschot Kempen organization, this officer monitors implementation and compliance with the provisions of the privacy legislation. If you have any questions or complaints, please send them to the Privacy Officer at privacyofficer@vanlanschotkempen.com.

Changes to the privacy statement
Over time, changes may occur in the use of personal data due to changing laws and regulations or changes in internal procedures or systems that may directly impact the way personal data are used by Van Lanschot Kempen. If that happens, the privacy statement will be adjusted accordingly and Van Lanschot Kempen will inform candidates on the details. The adjustment will be announced on the website: www.workingatvanlanschotkempen.com.