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Data Protection Notice

General Data Management Guidelines of the Magyar Nemzeti Bank

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The Magyar Nemzeti Bank (hereinafter: MNB) manages personal data collected or recorded during its activities based on the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC and on Act CXII of 2011 on information self-determination and freedom of information, as follows.

Purpose and Scope of the Guidelines

The purpose of this Guideline is to record the data protection and data management principles and data protection and data management policy of the MNB that as a data controller it recognizes as binding.

The MNB as a data controller informs all affected parties of the general information on personal data management by publishing these Guidelines.

Unless otherwise noted data management connected to administrative procedures and the tasks defined in the Act on the MNB is out of scope for these Guidelines.

Data controller:

Magyar Nemzeti Bank

Registered Office: 1054 Budapest, Szabadság tér 9.

 

Data Protection Officer of the MNB Dr Tivadar János Marton (phone: 06 1 428 2600, email: martont@mnb.hu).

Scope of managed data:

Designation of Data Management

Scope of Data Managed

Data managed for visits to the MNB website

Information provided during the use of the website

Data managed with regard to the operation of the Career Portal

Data provided as a part of the registration and data extracted from the CVs submitted

Customer Service operation

Data to identify natural persons, phone numbers, email addresses and other information provided by clients

Operation of the Bank Security Service

Security camera recordings, badge data

 

Legal basis of data management:

Designation of Data Management

Legal Basis of Data Management

Data managed for visits to the MNB website

Your consent

Data managed with regard to the operation of the Career Portal

Your consent

Customer Service operation

Legal basis in line with the legal basis of each individual case depending on authority rating

Operation of the Bank Security Service

Performed in line with legal obligation, in capacity as a public authority, Act CLIX 1997 on Armed Security, Nature Conservation and Field Watch

 

Purpose of data management:

Designation of Data Management

Purpose of Data Management

Data managed for visits to the MNB website

Operation of website, use of content with a registration obligation

Data managed with regard to the operation of the Career Portal

Application for positions advertised by the MNB, use for finding the appropriate candidate for future vacant or newly created positions

Customer Service operation

Support MNB processes, information, access to files, call centre, answer client requests

Operation of the Bank Security Service

Fulfil bank security requirements

 

Time of data management:

Designation of Data Management

Time of Data Management

Data managed for visits to the MNB website

For the technical data collected at the time of website visit: the time defined for the goal; for registration data is managed until permission is revoked but not longer than 2 years

Data managed with regard to the operation of the Career Portal

Maximum 1 year following registration

Customer Service operation

Retention time as per legislation, retention as per goal, 5 years for recorded telephone conversations

Operation of the Bank Security Service

30 days for CCTV cameras placed within the building, 3 days for external CCTV cameras partly monitoring public space. 24 days for entry data and records taken of guests, otherwise 30 days.

 

Whose data are being managed, scope of affected parties:

Designation of Data Management

Affected Parties of Data Management

Data managed for visits to the MNB website

Natural persons who visit the MNB’s website and perform a registration

Data managed with regard to the operation of the Career Portal

Natural persons who register at the MNB’s website and upload a CV

Customer Service operation

Natural person clients of the MNB

Operation of the Bank Security Service

Natural persons monitored outside and inside of the building

 

Data transfer:

The MNB transfers data to recipients specified in legislation as a part of administrative procedures or performing its other tasks. Every affected party is entitled to request information on data transfers in line with the provisions of the section “Rights related to data processing”.

Data security measures:

Personal data maintained in an electronic format are stored on the servers of the MNB, external data processors are used on an ad hoc basis. In all data management outsourcing cases the MNB ensures that the contracted service provider meets the requirements for data management. The MNB takes appropriate measures to protect personal data (among others) from unauthorized access and modification.

Rights related to data processing:

Right of information and right to access:

You may request written information from the MNB about the following, using the contact point listed as “Data Controller”:

                    what personal data of yours the MNB manages,

                    on what legal basis does the MNB manage your personal data,

                    for what reason does the MNB manage your personal data,

                    from which source the MNB acquired your personal data,

                    for what period does the MNB manage your personal data,

                    if the MNB still manages your personal data,

                    to whom, when, for what reason and to which personal data did the MNB grant access to or to whom did the MNB transfer your personal data.

Furthermore, you are entitled to a copy of your personal data stored at the MNB.

The MNB will fulfil your request in a maximum of 30 days in a reply letter sent to the contact details provided in your request. If you send your request to the MNB through an electronic channel, the MNB will also reply using electronic means if possible. Please indicate if you would like to receive the reply through a different channel.

Right to rectification:

You may request the MNB in writing using the contact point listed as “Data Controller” to modify or rectify your personal data (for example your name, email address if it changed). If you send your request to the MNB through an electronic channel the MNB will also reply using electronic means if possible. Please indicate if you would like to receive the reply through a different channel.

The MNB will fulfil the request in a maximum of 30 days without undue delay, and send a notification in a reply letter sent to the contact details provided in the request.

Right to erasure (“right to be forgotten”):

You may request the MNB in writing to delete your personal data, using the contact point listed as “Data Controller”.

The MNB will reject the request for erasure if it is required by legislation to store your personal data. If such requirements are not valid for your personal data, the MNB will fulfil the request in a maximum of 30 days without undue delay, and send a notification in a reply letter sent to the contact details provided in the request. If you send your request to the MNB through an electronic channel the MNB will also reply using electronic means if possible. Please indicate if you would like to receive the reply through a different channel.

Right to restrict the processing of personal data:

You may request the MNB in writing to restrict the processing of your personal data, using the contact point listed as “Data Controller”. If the processing of personal data is restricted, such personal data shall, with the exception of storage, only be processed by the MNB with the data subject's consent or for the establishment of legal claims or for reasons of important public interest.

A request to restrict the processing of data may be submitted if:

                    you think that your data are not correct or

                    you think that the MNB’s processing of your data was not legal but you do not wish to have your data erased or

                    you request the processing to establish or defend legal claims but the MNB does not need these data any more.

 

The MNB will fulfil the request in a maximum of 30 days without undue delay, and send a notification in a reply letter sent to the contact details provided in the request. If you send your request to MNB through an electronic channel the MNB will also reply using electronic means if possible. Please indicate if you would like to receive the reply through a different channel.

Right to withdraw consent:

You may notify the MNB in writing, during the period of processing, that you wish to withdraw your consent to the processing of your personal data, using the contact point listed as “Data Controller”. If consent is withdrawn the MNB’s processing of your personal data prior to withdrawal is deemed to be legal.

The MNB will delete the personal data upon receiving the withdrawal without undue delay, and send a notification in a reply letter sent to the contact details provided in the notification. If you send your request to the MNB through an electronic channel the MNB will also reply using electronic means if possible. Please indicate in your notification if you would like to receive the reply through a different channel.

Legal remedy:

If, in the affected person’s judgement, data management does not comply with the legal requirements, they have the option to initiate the proceedings of the MNB’s data protection officer, or they can bring the matter before court.

In addition, an investigation may be initiated by filing a report to the National Authority for Data Protection and Freedom of Information on the grounds that there was an infringement in practising the rights related to personal data management or there is imminent danger thereof.

Contact information to National Authority for Data Protection and Freedom of Information:

National Authority for Data Protection and Freedom of Information

Seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Postal address: 1530 Budapest, Pf. 5.

Telephone: 06-1-391-1400

Telefax: 06-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

 

Detailed information other than the general guidelines:

Data processing details for the website www.mnb.hu:

During your website visit the responsible data processor of your data is the MNB.

With your visit to the Internet site of the MNB you also submit your personal data to us.

Your personal data (data relating to you) may enter into our processing in the following ways: on the one hand technical data referring to your computer, browser software, Internet address, and the pages visited are automatically generated in our IT systems as a part of keeping the Internet connection alive; on the other hand you may give us your name, contact details or other information if you wish to contact us during the website use session.

The majority of information available on our website does not require you to log on or provide your credentials for access. However, there are certain functions that may require you to provide certain personal information (name, email address).

If you provide any of your personal data to the MNB, by that you give your consent to the MNB to keep on record and process these data, for the purpose and duration specified by the type of the transaction.

The MNB shall never divulge the data disclosed to it during the use of its website to any third party under any circumstances, with the exception of the cases defined by law.

The MNB does not use the services of external entities (data processing agents) for the operation of the website, including the handling of the data of visitors, with the exception of the Career Portal.

The MNB shall treat data of a personal nature provided by you through the Internet with the same level of security protection as the protection of data provided by other means.

Data processing details for the Career Portal:

The MNB will process personal data you submitted during registration and data that are available in the CV and documents you uploaded that may identify you as a natural person and that are related to your education, qualifications, professional experience, skills, and competences. The MNB will use these personal data for the application for positions advertised by the MNB, for finding the appropriate candidate for future vacant or newly created positions, to select the best candidate and to keep contacts with you. Any information submitted by you beyond those requested for the actual application are based on your free consent.

If the data uploaded by you contains special personal data, the MNB will contact you to discuss the appropriate processing of these.

Your data may be accessed by the employees of the MNB to perform their duties. For example, the employees of the HR Directorate will have access to your personal data while performing their tasks related to the management of the selection process. Furthermore, your personal data will be disclosed to manager and associates being involved in the selection process.

The MNB involves a third party, Nexum Magyarország Kft. (6726 Szeged, Temesvári krt. 15.) in the data processing. Nexum Magyarország Kft. provides IT support for the operation of the MNB systems, as a data processor groups incoming data to a format that supports HR processes and ensures that these data are accessible for the persons involved in the selection process.

If you request the MNB to delete your data as a part of establishing your legal claims, as a result any selection process you may be involved in is terminated and you cannot be selected for the affected position.

Data processing details for the MNB Customer Service:

The MNB operates a Customer Service. Customer Service, primarily the call centre does process personal data – the caller is notified and the system records the number of the caller and the conversation for quality assurance purposes. You are entitled to request a copy of the recording at the Customer Service. The systems stores call recordings for 5 years. After this period a permanent deletion is performed.

In the case of other requests, complaints and requests for access to files, personal data in the affected files are handled in line with the rules that apply for the processes the files were submitted for.

When you establish your data processing related claim the Customer Service is the point of contact.

Data processing details for the information collected by using security cameras:

In line with Act CLIX 1997 on Armed Security, Nature Conservation and Field Watch the MNB Bank Security Directorate operates a non-stop CCTV system within the building to protect premises, to prevent incidents, mitigate their consequences and facilitate investigation, to detect infringements, to catch any offenders and to prevent illegal activities. The system records events within the building. As per legislation recordings are retained as follows: 30 days for CCTV cameras placed within the building, 3 days for external CCTV cameras partly monitoring public space.

By entering premises you agree that in line with legislation the MNB Bank Security Directorate records, stores, processes and in the cases listed in the legislation discloses to third parties your recorded facial data that enable your identification.

 

Besides your data processing rights listed above you may request the MNB Customer Service to provide you written information about such recordings, and the MNB will fulfil the request in a maximum of 30 days without undue delay. You may request the MNB to block (that is retain) such recording for a period longer than 30 days if you presume that this is necessary to establish your claims.

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