No.

Why do we collect information about You?

What information do we collect about You?

Why do we have the right to collect the information You provided?

How long do we use or store information about You?

3.1.

We carry out a verification of the reliability of candidates seeking to perform their duties

Name, surname, position applied for, date of submission and/or revocation of consent for security clearance, signature, personal data referred to in Article 16 of the Law on Prevention of Corruption of the Republic of Lithuania and/or Article 17 of the Law on the Protection of Objects of Importance to Ensuring National Security of the Republic of Lithuania (the scope of the personal data shall depend on the information provided by the relevant authorities to the Company).

For this purpose, special categories of personal data may also be processed if they have been provided to us by the authorities carrying out the screening of the candidate (the State Security Department of the Republic of Lithuania, Special Investigation Service of the Republic of Lithuania, the Ministry of the Interior of the Republic of Lithuania).

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

We have Your consent (Article 6(1) clause a of the GDPR)

a.     When the selection process provides information leading to a decision not to appoint a person to a position, the personal data will be kept for 3 months after the end of the selection process.

b.     When a candidate’s verification provides information that leads to an employment decision, the candidate’s personal data (obtained prior to the conclusion of the employment contract) is stored for the duration of the employment contract and for 1 year after the termination of the employment relationship.

3.2.

We organize and conduct public procurement

Name, surname, personal code or date of birth, address, telephone number, position, other personal data may be required depending on the object of the contract and the qualification requirements (criminal record check, tax obligations related to the object of the contract, qualification requirements as specified in the contract documents), name, surname, personal code or date of birth, address, telephone number, position, bank account number, copy of the certificate of sole proprietorship, copy of the business certificate.   The successful supplier may be asked for: curriculum vitae, copies of diplomas, certificates obtained, the number of contracts completed, criminal record, payment records with the State Tax Inspectorate, SoDra etc.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

a.     During the period of validity of the contract and 5 years after the expiry of the contract.

b.     When the contract was not concluded, 5 years after the end of the procurement.

3.3.

We draw up and execute contracts with You, and comply with related tax obligations

Name, surname, personal code or date of birth, telephone number, e-mail address, bank account number, signature, basis of representation (power of attorney, statutes, etc.), number of the power of attorney, term, duties, billing information, settlement period, other information relevant to the conclusion and performance of the contract, depending on the nature of the contract.

We conclude a contract with You and fulfil our contractual obligations (Article 6(1) clause b of GDPR)

During the period of validity of the contract and 5 years after the expiry of the contract.

3.4.

We carry out internal and external communications to publicize the Company’s activities

In the case of media representatives, name, surname, position, telephone number and e-mail address.

In the case of instructors, other invitees, name, surname and position.

We have a legitimate interest in processing Your personal data (to publicise the Company’s activities by informing You about ongoing news) (Article 6(1) clause f of GDPR) 

a.     Media representatives (e.g. journalists in charge) – protected for as long as they are actually working for the media outlet or the department.

b.     5 years after the end of the contract.

3.5.

We administer the internal reporting channel (Trust line) and carry out internal investigations on the basis of the information received

In case the information is not provided anonymously, the data collected will be the data provided by the person himself or herself – name, surname, telephone number, personal code, e-mail address, the circumstances of the notification, the date of the notification, the decision to inform about the actions taken and the decisions taken.

We have a legitimate interest in the processing of Your personal data (to prevent fraud, corruption, other criminal acts, violations of law, other violations –  to prevent acts being committed, to take measures to prevent acts being committed in the future, etc.)(Article 6(1) clause f of GDPR).

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

If an infringement has been found after examination of the information received – 5 years after the end of the investigation.

If the examination of the information received did not lead to the finding of an infringement – 3 years after the end of the investigation carried out.

3.6.

We deal with complaints, suggestions or requests submitted by You

Name, surname, e-mail address, telephone number, signature, date of application, application number (registration number) and the information contained therein, the outcome of the proceedings, if the person making the application, complaint or proposal has been communicated with by e-mail, the personal data recorded in that communication.

We have a legitimate interest in processing your personal data (to deal with your applications, requests or complaints) (Article 6(1) clause f of GDPR)

1 year  from the date of receipt of the application, complaint or offer.

3.7.

We carry out security clearance checks on the Company’s contractors and sub-contractors who, by virtue of their assigned functions, are granted unescorted access to national security facilities and assets under the Company’s control.

Name, surname, personal identification number/date of birth, position, date of signature, signature of contractors’/subcontractors’ employees;

Personal data referred to in Article 17 of the Law on Protection of Objects Important for National Security of the Republic of Lithuania (the scope depends on the information provided to the Company by the relevant authorities).

For this purpose, special categories of personal data may also be processed if they have been provided to us by the authorities carrying out the background check (the State Security Department of the Republic of Lithuania, the Special Investigation Service of the Republic of Lithuania, the Ministry of Interior of the Republic of Lithuania).

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

We have Your consent (Article 6(1) clause a of the GDPR)

a.     In the case of the provision of final services/works, the Personal Data is retained for 1 month after the end of the contract;

b.     In the case of continuing services/works, the data shall be kept for 10 years after the end of the contract.

c.     Where a contractor’s or sub-contractor’s employee has been vetted and, on the basis of the information obtained, is denied access to facilities and assets of national security significance under the Company’s control, personal data shall be retained for a period of 3 months following the completion of vetting

3.8.

We aim to ensure the protection of the Company’s facilities and the people who visit them

In the case of access control, name, surname, date and time of entry and exit, details of movement within the facility;

In the case of video surveillance, video data of persons within the surveillance area of CCTV cameras;

For visitors on excursions to the Company’s facilities – name, surname, signature, place of work.

We have a legitimate interest in processing your personal data (security of property and persons) (Article 6(1) clause f of GDPR)

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

a. The retention period for image data and visitor (tour participant) data is 30 days.

b. access control records are kept for 6 months

3.9.

We implement economic or financial sanctions, embargoes or other restrictive measures imposed or administered by the EU or other relevant institutions.

Managing risks associated with business partners

Name, surname, date of birth, nationality, place of residence, address of registration, country of residence, percentage of shares held, information on links with politically exposed persons, information on investigations carried out in relation to corruption, competition, anti-money laundering, terrorist financing, occupational health and safety violations, information on business partners, clients.

Personal data of shareholders of the partner of activity, beneficiaries (name, surname, date of birth, nationality, place of residence)

Name, surname, position, e-mail address of the representative of the business partner.

Other information provided in the questionnaire by the business partner, his representative.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of the GDPR)

We have a legitimate interest (to ensure the compliance of our business partners with the requirements of the Group’s Supplier Code of Conduct and the management of potential financial and reputational risks) (Article 6(1) clause f of the GDPR) 

5 years after the end of the contractual relationship.