INFORMATION ON THE PROCESSING OF PERSONAL DATA WITHIN CALL CENTER ACTIVITIES
This document aims at describing the way in whichAsset Portfolio Servicing România S.R.L. ( ‘APS România’) uses personal data within call center activities. This information notice is issued in accordance with Regulation (EU) no. 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (General Data Protection Regulation), pursuant to which you have the right to be informed of the data we process about you and your rights relating to such data.
1. WHO WE ARE
Our contact details are:
Asset Portfolio Servicing România S.R.L. (hereinafter ‘APS România’)
Calea Floreasca 246C, Sky Tower Building, etajele 11, 12 și 584.70 mp din etajul 32, Sector 1, Bucharest.
The contact details of the Data Protection Officer
2. WHAT KIND OF PERSONAL DATA WE PROCESS
Within the call center activity, APS România processes the personal data resulting from the recording of telephone calls, namely the voice, as well as other personal data provided during conversations.
3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
The purposes of processing and recording telephone calls are:
Ø To prove the interactions between you and APS România, with respect to claim recovery, in order to fulfill the legal obligation provided for by Article 49 of Emergency Ordinance no. 52/2016 on credit agreements offered to consumers for immovable property, and amending and supplementing Government Emergency Ordinance no. 50/2010 on credit agreements for consumers.
Ø To find, exercise or defend APS rights in court/competent authorities/investigation and control bodies;
Ø Proper evaluation and training of APS call center agents;
Ø To improve the quality of the services and conversations with you;
Ø For a better understanding of your requests;
Ø To access and check the recordings in the case of a subsequent complaint and/or claim from you;
4. LEGAL GROUNDS ON WHICH WE PROCESS YOUR PERSONAL DATA
The grounds on which we process your personal data are:
a) Consent: You consented to the audio recording of the telephone conversation; Article 6(1)(a);
b) Compliance with legal obligations: processing is necessary to comply with APS România’s obligations arising from laws or other legislative acts; Article 6(1)(c); Article 6(3) ;
c) Legitimate interest: processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child Art.6(1) lit. (f) ;
5. HOW WE COLLECT YOUR PERSONAL DATA
Recording of phone calls
Ø Calls received from you by the Soft&Filed Collection Department and the Enforcement Department within APS România. The welcome message will mention that the call is recorded and the continuation of the call is your consent for recording the conversation.
Ø Calls made by the Soft&Filed Collection Department and the Enforcement Department within APS România to you. When establishing the telephone connection and prior to your identification, you will be informed of the recording of the call and you will be asked for consent thereto.
The recording will be stopped if you end the phone call or you do not want to continue the call with recording, having the possibility to communicate with APS România also by other means of communication mentioned in the preamble.
6. HOW LONG WE STORE YOUR PERSONAL DATA
As part of the call center activity, we will keep the records containing your personal data throughout the term of the contract and 5 years after its termination or after the completion of the enforcement proceedings.
7. WHO CAN ACCESS THE RECORDED CONVERSATIONS
The recorded conversations can be accessed by the persons authorised to evaluate and verify the calls and/or by the competent authorities.
8. WHERE THE CONVERSATION RECORDINGS ARE STORED
The conversation recordings are stored on servers located in Romania and/or the European Union.
9. REQUESTING FOR COPIES OF THE RECORDED CONVERSATIONS
Requests for copies of the recordings must be made in writing and sent by mail or email to the addresses mentioned in the preamble.
We should mention that the consent of all parties involved in the conversation is needed before the recording is issued. Otherwise, the conversation will be transcribed.
10. RIGHTS YOU CAN EXERCISE IN ACCORDANCE WITH GDPR
Ø 1. Right to information
Ø 2. Right of access
Ø 3. Right to withdraw the consent
Ø 4. Right to data rectification
Ø 5. Right to lodge a complaint with a the National Supervisory Authority for Personal Data Processing
The contact details of the Romanian Supervisory Authority for Personal Data Processing are:
B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, cod poștal 010336, Bucharest, Romania
This Information Note shall be supplemented by the Information Note on the processing and protection of personal data available on the website of APS Romania at: https://ro.aps-holding.com/personal-data-processing.