1. Controller
This data protection statement provides information regarding the purpose of the processing carried out by the Treasury and Capital Markets Departments of the European Investment Bank hereafter, hereafter the “EIB” or “we” in the course of the recording of FI front office phone calls.
2. Purpose of the processing
This data protection statement provides information regarding the purpose of the processing carried out by the EIB in the course of the recording of FI front office phone calls. The EIB performs tasks in the exercise of the authority vested to it in accordance with the Provisions of the Treaties and its Statute.
The EIB processes your personal data as reasonably necessary so that it can conduct and manage the recording of FI front office phone calls, in a reasonable and proper manner, in accordance with applicable laws and regulations. Personal data are processed in accordance with Regulation (EC) 2018/1725 of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies and agencies and on the free movement of such data and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (hereafter, the EU DPR).
Specifically, EIB processes the personal data for the below purpose(s) as described in the record,
- To avoid any risk of misunderstandings between the Bank and counterparties relating to transactions and live pricings agreed over the phone;
- To enable retrieval and playback of a phone call in the context of a legal, regulatory or disciplinary-related investigation or inquiry.
3. Legal Basis of the processing
The legal basis for the processing of personal data in the course of the recording of FI front office phone calls is:
- Directive 2014/65/EU on markets in financial instruments (MiFiD II);
- Regulation EU/2014/596 on market abuse.
- The Public Interest
- The FI Front Office Manual;
4. Categories of data subjects
The following categories of individuals (data subjects) are/may be concerned by the processing under 2: designated EIB staff, specifically FI Front Officers working in the Treasury and Capital Markets Departments.
5. What personal data do we process?
EIB processes the following categories of personal data:
- any personal information which may be exchanged during an incoming or outgoing phone call carried out by a FI Front Officer, including but not limited to:
- Full name;
- Professional information including contact details;
- Demographic information.
6. Where do we obtain your personal data?
We may obtain your personal data directly from you.
7. To whom is your data disclosed?
The data is stored within EIB servers in EIB data centers and not disclosed outside the EIB Group.
Data may be processed, upon receipt of a call recording playback request, by FI-Compliance team and relevant GCS teams. In the event of a playback recording request in the course of an investigation or inquiry, HR DG and Data Protection Officer may also be involved.
8. International Transfers
Your data are not transferred to entities established outside the EU or the European Economic Area.
9. How long do we keep your personal data?
We keep your data for 7 years from their collection.
10. What are your rights and how can you exercise them?
Your rights are set out in sections 3 to 5 of the EU DPR.
- You have the right to obtain from the controller confirmation as to whether or not your personal data are being processed, and, if so, to access your personal data by contacting the Controller or through the EIB DPO (right of access);
- You have the right to request the controller to rectify any inaccurate data and/or have incomplete personal data completed (right for rectification);
- You have the right to request the controller to erase your personal data as per Article 19 of the EU DPR (right to be forgotten);
- You have the right to request the controller to restrict the processing of your personal data in the following cases (right to restriction of processing):
- (i) if you contest the accuracy of your data;
- (ii) if the processing of the data is unlawful and you oppose to their erasure;
- (iii) if the controller no longer needs the personal data referred to for the purposes of the processing but you require them for the establishment, exercise or defence of legal claims; or
- (iv) if you have objected to the processing of your data and EIB seeks to establish whether the controller has legitimate grounds overriding yours right to restriction.
- You have the right to object to the processing of personal data, on grounds relating to your particular situation, unless EIB demonstrates compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims;
- You have the right to receive your personal data from the EIB in a structured, commonly used and machine-readable format to allow you to transmit your data to another controller without hindrance from the EIB (right to data portability);
- When the legal basis of the processing is the consent, data subject has the right to withdraw his/her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
- You have the right to lodge a complaint with the European Data Protection Supervisor (www.edps.europa.eu) at any time (right to lodge a complaint).
11. Contact us
If you have any questions about our processing of your personal data, or wish to exercise any of the rights described above, please contact us: FI-Tre-Secretariat@eib.org or the EIB's Data Protection Officer, Mr. Pelopidas Donos, by email at p.donos@eib.org or at the following address:
Mr. Pelopidas Donos
European Investment Bank
98-100 Boulevard Konrad Adenauer
L-2950 Luxembourg (Grand Duchy of Luxembourg)