Personal data processing principles

Artificial intelligence solutions may be used in candidate selection and CV evaluation, providing significant support in information processing, increasing work efficiency and improving the quality of the selection process. These solutions are used, for example, to convert audio recordings of interviews into text, to create summaries and to classify candidates’ CVs according to the criteria specified in the job vacancy advertisement and relevant to the particular position. The final decision on whether or not to advance a candidate to the next selection round and on hiring a candidate is made by the responsible employee of Latvenergo AS.

Your personal data may be obtained from you or, for example, from another person who provides information about you, from publicly available information (for example, publicly available recruitment databases, registers of certified persons, the social media platform LinkedIn, publications on websites and/or at conferences), from recruitment service providers, and from state security authorities.

If the recruitment process relates to the position categories specified in Cabinet Regulation No. 20 of 7 January 2020 “Procedure for the nomination of members of the management board and supervisory board in capital companies in which the capital shares are owned by the State or a derived public person”, we may also receive personal data about you from the sources specified in the regulation, for example, from recruitment consultants.

Your personal data will be processed by authorised employees of the Controller within the scope specified in their job duties, in compliance with the requirements of personal data protection and other laws and regulations, as well as the personal data processing requirements set out in the Controller’s internal regulations.

Personal data may be transferred to:

• the Controller’s outsourced service providers (processors), who may be authorised to carry out certain data processing activities on behalf of and under the supervision of the Controller, for example, recruitment service providers, developers and maintenance service providers of information system solutions, service providers ensuring the exchange of information, and security and protection service providers;
• recruitment consultants;
• under certain circumstances, law enforcement authorities, including state security authorities, or supervisory authorities (for example, the State Labour Inspectorate), courts, as well as the Controller’s processors – providers of legal services;
• when organising a job interview using online communication solutions, in certain cases your personal data may be transferred to the provider of the respective service;
• if the recruitment process relates to the position categories specified in Cabinet Regulation No. 20 of 7 January 2020 “Procedure for the nomination of members of the management board and supervisory board in capital companies in which the capital shares are owned by the State or a derived public person”, personal data will also be received by the recipients provided for in the regulation. Information on the results of the selection process will be made public in accordance with the procedure and to the extent specified in laws and regulations.

It is not intended to transfer personal data to recipients outside the European Union, the European Economic Area, or to countries and organisations in respect of which the European Commission has not adopted a decision on an adequate level of protection, except where, for example, an interview takes place using online communication solutions, in which case your personal data may be processed in third countries to provide the respective service.

Information obtained when a candidate applies for a vacancy, as well as publicly available information about the candidate if the approached candidate expresses interest in participating in the selection, and information obtained within the selection process will be stored, in full or in part, for no longer than six months from the end of the particular selection process. If an employment contract is concluded with you, the information may be retained for the entire duration of the contractual relationship, whereas information on the vetting carried out and the information provided by the state security authority will be retained for no longer than 2 years after the vetting.

References on your previous professional activity obtained within the selection process may be retained until you withdraw your consent; if the references have been obtained on the basis of the legitimate interests of Latvenergo AS, they will be retained for no longer than six months from the end of the particular selection process.

If the recruitment process relates to the position categories specified in Cabinet Regulation No. 20 of 7 January 2020 “Procedure for the nomination of members of the management board and supervisory board in capital companies in which the capital shares are owned by the State or a derived public person”, candidates’ applications are stored for six months from the appointment of the selected candidate to the position, whereas information obtained within the selection process (for example, information obtained in the professional knowledge assessment, evaluations by commission members and the recruitment consultant, minutes of nomination commission meetings) may be retained for the entire duration of the contractual relationship of the candidate selected in the process.

If you have chosen to be included in the list of potential candidates for future recruitment, the information will be stored until you withdraw your consent, but for no longer than two years from the end of the particular selection process.

If a complaint is received about the selection process concerned, all information obtained in the selection process may be retained until the complaint has been examined and fully resolved (for example, until the relevant court judgment enters into force).

Right of access. You have the right to access your personal data and to receive information from Latvenergo AS about the processing of your personal data. Using the Controller’s contact details, you may request information on the processing of your personal data if the information provided in these Principles does not seem sufficiently comprehensive to you.

Right to rectification. If you notice inaccuracies in your personal data, you have the right to request that Latvenergo AS rectify the inaccurate personal data by sending an appropriate request to the contact details specified by Latvenergo AS.

Right to erasure. You have the right to request that Latvenergo AS erase your personal data if:

• the personal data are no longer necessary in relation to the purposes specified in the Principles for which they were processed;
• you withdraw your consent on which the processing of personal data was based;
• the personal data have been processed unlawfully;
• you have objected to the processing and the legitimate grounds of Latvenergo AS do not override your legitimate grounds;
• the personal data must be erased in accordance with the requirements of laws and regulations.

In certain cases we will not be able to comply with your request to erase personal data. This applies to cases where, under laws and regulations, Latvenergo AS is obliged to process your personal data. Likewise, data erasure is not possible if the processing of personal data is necessary, for example, to establish, exercise or defend legal claims. That is, in the cases mentioned, the right to request erasure of your personal data is restricted.

Right to restriction of processing. You have the right to request that Latvenergo AS restrict the processing of your personal data if:

• you believe that the data are being processed unlawfully or are inaccurate;
• you believe that the processing is unlawful, but you do not wish to have the personal data erased;
• you have objected to the processing and pending verification of whether the legitimate grounds of Latvenergo AS override your legitimate grounds;
• Latvenergo AS no longer needs your data for a specific purpose, but you need them to establish, exercise or defend your legal claims.

Right to object to processing. You have the right to object at any time to the processing of your personal data that is based on the legitimate interests specified in the Principles. Latvenergo AS has the right to continue processing your personal data if Latvenergo AS demonstrates compelling legitimate grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

Right to withdraw consent. Where you have given consent to the processing of certain personal data, you have the right to withdraw it at any time; however, such withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To withdraw consent, you may use the contact details specified in the Principles.

Right to data portability. You have the right to receive the personal data that you have submitted to Latvenergo AS in a structured, commonly used and machine-readable format (processed electronically or in information systems), and you have the right to request that these data be transmitted to another controller (service provider) if the data are processed on the basis of a contractual relationship or consent. The right to data portability applies only to data that you, as a data subject, have submitted to Latvenergo AS.

Right to lodge a complaint. You have the right to lodge a complaint with Latvenergo AS, as well as with the Data State Inspectorate (Elijas iela 17, Riga, pasts@dvi.gov.lv), if you believe that Latvenergo AS has violated your rights or has not sufficiently protected your personal data. However, before contacting the Data State Inspectorate, we encourage you to approach Latvenergo AS or the data protection officer in order to find a solution.

To exercise all of the above rights, you may use the contact details of Latvenergo AS specified in these Principles, indicating the following personal data in your request: first name, surname, personal identity number, postal address (if you wish to receive the reply by registered mail) or e-mail address (if you wish to receive the reply by e-mail).

We encourage you to submit your request in one of the following ways:

• send a free-form application electronically to info@latvenergo.lv or fpda@latvenergo.lv, signing the application with a secure electronic signature;
• send your signed free-form application by post to: Latvenergo AS, Pulkveža Brieža iela 12, Riga, LV-1230;
• submit your signed free-form application in person at the Controller’s address.

Latvenergo AS has the right to make changes to these Principles and to inform of them by publishing the current version of the Principles on its website.