Privacy declaration on the processing of personal data of Aegon job applicants

This privacy statement applies to the processing of personal data of applicants who apply for a position at Aegon via the careers.aegon.com website or via another direct or indirect application procedure. If you enter employment with us, from that moment on the relevant Privacy Statements and Privacy Policy for Aegon employees will apply.

Personal data is data that identifies you, either directly or indirectly. We process a lot of your personal data during your application procedure, such as your name, address, date of birth, phone number (both business and private), CV, and links to your public profile on LinkedIn. Other data we process includes sensitive personal data or criminal data, for example when we ask you for a Certificate of Good Conduct (VOG in Dutch).

Appendix 1 contains a list of the personal data that Aegon can process about you in connection with your application.

The term 'processing' (processing of personal data) is frequently mentioned in this privacy statement. 'Processing' refers to all the operations we can carry out involving your personal data, such as collection, storage, retrieval, sharing, analysis, and erasure. This includes processing using computers as well as processing of data in physical documents stored in filing cabinets.

You provide most of the personal data to Aegon yourself when you submit your CV and cover letter, but Aegon can also receive data about you via an external recruitment agency or other agency, the references you have specified, or your public LinkedIn profile.

Aegon will only process the data in your application for the following purposes and on the basis of the following principles: 

Recruitment and selection process
Aegon processes your personal data to determine whether you are the right candidate for the position for which you are applying and to contact you. This could be to invite you for an interview at the office or to send you a letter, for example.

Before inviting anyone for a first interview, we ask all applicants to do an online agility test. This test predicts how agile you are, and how quickly you can master things.

We process your data to conclude a possible employment contract or other contract with you, and then execute it.

Pre-employment screening and integrity monitoring of the financial sector and employees 
It is very important that employees working in the financial sector are reliable and honest, so Aegon is legally obliged to perform a screening prior to employment. This is called a pre-employment screening,  and its purpose is to assess whether you are honest and reliable. You can only work with us if your screening result is positive.

What is checked?
This screening checks, among other things, your identity, and verifies the information on your CV. Diplomas are checked for authenticity, and we can also call the references you specified. In addition, you will have to provide a Certificate of Good Conduct (VOG) and possibly an extract from the Credit Registration Office (Bureau Kredietregistratie). Depending on the screening level (level 1, 2 or 3), we will also check whether you appear in our internal incident register, in external warning registers, or on sanctions lists. Some of the external warning registers that we consult are: the EVR, EVA, SFH, CBV and the Banks Disciplinary Law Register (Tuchtrechtregister Banken).

The pre-employment screening is performed by the screening team of HR Services Aegon Netherlands in collaboration with the Security Affairs department and external organisation Validata.

We process your data because we are legally obliged to do so and on the grounds of the legitimate interest of our company, the sector, customers and employees.

Talent profiles and job alerts
With your consent, we offer you the possibility to submit your personal data to enable Aegon to create and retain job talent profiles for your potential future job opportunities. Aegon uses this information to inform you via e-mail of job opportunities that match your profile and that may be of interest, as well as share information about Aegon as an employer.

The personal data processed by Aegon in order to create a job candidate profile comes directly or indirectly from you, via various channels including:

• Completing online talent community web forms and providing attachments,
• Interactions with the online chat bot, and
• Data imports from LinkedIn or other recruitment platforms, either by you or an Aegon recruiter (with your consent)

Reports and analyses
We use data from job applications for management reports and analysis. We monitor the percentage of applicants who proceed to the next round or are accepted for example. These reports are not made at an individual level, so the results of an analysis cannot be traced back to you as an individual. We process data for this purpose on the grounds of our legitimate interest.

When Aegon uses legitimate interest as grounds to process personal data, it carefully balances and records all interests (of Aegon, employees, and third parties). This includes i) the expectations of the applicants, ii) to what extent the proposed processing is regarded as intrusive and whether there are other ways to achieve the purpose, and iii) to what extent the processing can be objected to, or whether opt-out can be invoked before Aegon starts processing personal data.

We retain the data from your job application and screening for a maximum of 4 weeks after completion of the application period if you do not enter employment. If you give your consent, this period can be extended to 1 year after completion of the procedure. If you have given consent for us to retain your data for the longer period, and you want to withdraw this consent, send a request to people@aegon.nl. We will then immediately erase your data from our systems.

If you enter employment with us, the data will become part of your personnel file, and the Privacy Policy for Employees will apply.

We are absolutely committed to protecting and securing your personal data. Aegon has implemented functional, technical, physical and organisational safeguards to protect the personal data in our possession and reduce the risk of: 

• Unauthorised access and modification; 
• Improper disclosure; and 
• To minimise accidental or unlawful destruction or loss. 

We use various measures to do so, including information security, staff training, and secure servers. Personal data is only accessible to employees insofar as it is necessary for these employees to do their jobs. Employees who have access to personal data have a duty of confidentiality in line with Aegon's Code of Conduct. If a data breach results in a high risk of a breach of your rights and freedoms, we will contact you in accordance with our data breach notification procedures. 

Only a select group has access to your personal data; those who are directly involved in the application process for the vacancy for which you are applying. This includes members of the management team of the department you are applying to, potential new line managers, people working in HR, third parties who help us find you, and Validata who supports us in carrying out Pre-Employment Screening. These people may work both inside and outside the European Union.

If you apply for an international position, your personal data will also be accessible to our Global HR department involved in the vacancy for which you are applying. Our Global HR department is partly located in the United States, so your personal data may end up in countries inside or outside the European Union. The European Commission has determined that some countries have an 'adequate' level of personal data protection. For other countries such as the USA, we use the standard contractual clauses approved by the European Commission. We also take additional security and other measures if necessary.

Applicant and employee data is stored in our Workday personnel system. This system is used by all Aegon entities, both inside and outside the European Union. Workday's servers are located in the United States of America. Aegon has made clear agreements with Workday about how Workday may process personal data. We have ensured that we comply with the applicable rules for transferring your personal data to and from the European Union. These agreements meet all statutory conditions.

You have a number of rights concerning the processing of your personal data, such as the right of access and the right of erasure. 

1. Right of access
   You have the right to know what happens to your personal data held by Aegon. 
    
2. Right to rectification
   You have the right to have your personal data rectified or supplemented if it is incomplete or incorrect; 
    
3. The right to be forgotten
   You have the right to have your personal data erased as soon as there is no business necessity, legal requirement or legitimate interest for us to retain or process it.  
    
4. The right to object and restriction of processing
   In a limited number of circumstances, you have the right to object to the processing of your personal data or to limit the processing of it (temporary suspension of the processing) unless we are obliged to process your personal data due to a legal obligation or contractual necessity.   
    
5. Right to data portability
   You have the right to ask us to transfer the personal data you have provided to us to another party in electronic form.In such circumstances, we can decide to provide you with a copy of your personal data so that you can submit it to a third party yourself, to ensure that your personal data does not end up in the wrong hands. 
    
6. Right not to be subject to a decision based solely on automated processing.
   Automated decisions are decisions about you made by computers, not by humans. If employees are subject to automated processing, an Aegon employee will always assess each individual case, and always check whether the automated decision does not lead to an unreasonable outcome in the individual case. Aegon will therefore never make a fully automated decision about you.

To exercise any of the rights mentioned above, contact us at people@aegon.nl. Your request will be answered within one month. We may ask for additional information in order to fulfil your request to exercise your rights; for example, verification of your identity or clarification of your request.

If another party makes a request on your behalf, we must be able to confirm that this party has the appropriate authority to make such a request.

If you submit a request, we also take into account Aegon's other obligations and the rights of other data subjects. This means there is a chance that your request will be partially granted or, in exceptional circumstances, rejected. If your request is rejected, we will let you know why.

If you want to exercise your rights concerning the processing of your personal data by third-party processors, co-controllers or one of the parties we work with, please contact us at people@aegon.nl

This privacy statement was last updated on June 15, 2022. The latest version can be found at https://careers.aegon.com/nl/aegon-careers/ons-privacybeleid/

If you have a complaint about the way in which your personal data has been or will be processed, contact us at people@aegon.nl. All complaints are handled in line with internal procedures and policies. 

If you are unable to resolve your complaint with Aegon, you can submit your complaint to the Dutch Data Protection Authority. This is the independent authority in the Netherlands set up to monitor compliance with the General Data Protection Regulation.  

Website:  https://www.autoriteitpersoonsgegevens.nl/  

Phone: +31 (0)70 888 8500 

Types of personal data that may be processed in connection with your job application:

Personal data  

• Contact details (business and personal) 
• Gender
• Date of birth 
• Photo
• Information about education, experience, qualifications and references (as listed on a CV) 
• Other personal data available on LinkedIn and other recruiting sites
• Other personal data provided to Aegon included in an applicant’s CV, application form (digital or physical), online chat bot or provided by a recruitment agency

Sensitive personal data  

• Passport number, place of issue, date of issue, validity and nationality, and/or a copy of an identity document 
• Signature employee 
• Citizen Service Number (BSN) 
• Gender 
• Data about marital status, spouse
• Data about outside business activities, or other relationships that could potentially create a conflict of interest 
• Data on absence due to illness, reintegration processes and percentage of incapacity for work (health and disability data)  
• Screening information, including criminal data and associated declarations, credit data and personal statements, as well as Certificates of Good Conduct (VOG) and ancillary positions
• Information about work-related memberships, works council, staff association 

The above list is not exhaustive.