Principles for the processing of personal data of employees of Latvenergo AS contractors

Pursuant to Articles 13 and 14 of Regulation (EU) 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) (elsewhere in the text referred to as the Regulation), Latvenergo AS hereby informs you about the processing of personal data of employees of contractors (elsewhere in the text referred to as the Principles).

Controller: Public Limited Company Latvenergo, registration number: 40003032949, registered office: Pulkveža Brieža iela 12, Riga, LV-1230 (hereinafter – Latvenergo AS), info@latvenergo.lv.

Contact details of the Data Protection Officer: Pulkveža Brieža iela 12, Riga, LV-1230, fpda@latvenergo.lv.

Purpose of processing of personal data Categories of personal data Legal basis for the processing of personal data

Provision of commercial activity:

  • For ensuring the safety and continuity of energy supply operations by registering and managing the rights of contractor’s employees to work at Latvenergo AS energy installations and areas with certain electrical safety groups and special rights and training, by ensuring organisational processes, including documentation and site access management, and compliance with and the monitoring of safety requirements, conducting Latvenergo AS occupational safety briefings, reporting, as well as investigating and accounting processes of unsafe working conditions or environmental hazards.
  • Ensuring the electronic recording, accounting and storage of recorded data regarding the working time of persons employed on-site as part of the construction process of energy supply facilities to meet the requirements of regulatory enactments, including the provision of data on the unified electronic working time accounting system
  • For the management of the accounts, accounting and financial records, and the protection of financial interests 
  • Organisation of competitive dialogue and procurements, including procurements with suppliers qualified by qualification systems, as well as the organisation of E-procurements
  • Maintenance of the Supplier List and Qualification Systems



  • Identification information
  • Contact details
  • Represented company
  • Position
  • Nationality
  • Username
  • Contract information
  • Information contained in communication materials (for instance, in correspondence)
  • Information on compliance with the requirements for the safety and continuity of electricity supply operations (for instance, information on electrical safety group and/or special rights, certificate number and expiry date, information on briefings)
  • Audio recordings (such as telephone recordings)
  • Video recordings
  • Photos
  • Authentication information
  • Access information
  • Information on time spent by a person on-site and other related information
  • Information obtained as part of the investigation
  • Information related to participation in competitive dialogue, information related to procurement and E-procurement, including data on professional eligibility, experience and education;
  • Information included in the offer;
  • Report contents
  • Signature

If you have expressed a wish to provide your personal data in order, for example, to report unsafe working conditions or environmental hazards and/or to receive information about the situation, we will process your personal data on the basis of your consent.

In the cases specified by regulatory enactments, we will process personal data in order to fulfil the legal obligations specified by Latvenergo AS, as well as process the data in order to exercise, for example, the following legitimate interests of Latvenergo AS:

  • to detect and prevent security risks at the energy supply facilities;
  • to prevent potential financial and organisational risks;
  • to maintain a list of suppliers and select and maintain a list of qualified suppliers;
  • to organise and ensure procurement procedures, including price surveys and related activities below the public procurement contract price threshold, as well as to ensure the procurement process in the electronic procurement system of Latvenergo AS.

Protection of security and other legal interests:

  • Provision of safety of the information systems of Latvenergo AS (including the maintenance of audit trails) and prevention and investigation of IT security incidents (for instance, in the case of unauthorised external access to the information systems, websites or apps of Latvenergo AS), as well as any kind of malicious activity against the information systems of Latvenergo AS, any websites or apps (such as DDoS attacks)
  • Provision of physical security in the premises of Latvenergo AS, on the territory of sites or at the sites, including the performance of video surveillance and implementation of access control (for example, issuing of passes) and prevention and investigation of physical security incidents, protection of individuals and property, and the protection of legal interests
  • Identifying risks of fraud and corruption and ensuring transparency
  • Obtaining and summarising information for situation assessment, event investigation and obtaining evidence 
  • Transfer of personal data of personnel carrying out work on critical infrastructure sites to national security authorities to assess compliance with national security interests
  • Identification information
  • Contact details
  • Service provision address
  • Contract information
  • Information on opinion
  • Information contained in communication materials (for instance, in correspondence) 
  • Information about the meeting or conversation (time, date, place, topic, the most important aspects of the content of conversation)
  • Information about the use of information systems
  • Information obtained within customer due diligence for the purpose of compliance with regulatory enactments
  • Audio recordings (such as telephone recordings)
  • Video recordings
  • Photos
  • Authentication information
  • Access information
  • Vehicle information
  • Represented company 
  • Information on time spent by a person on-site and other related information
  • Information related to participation in procurements
  • Litigation information
  • Information obtained as part of the investigation
  • Nationality 
  • Information provided in the replies by the national security authorities (presence/absence of information that would prevent access)
  • Report contents

We will process personal data on the basis of your consent if you wish to disclose your identity as a whistleblower to others or if your report submitted on the alleged violation is not considered a whistleblower’s report but you want your personal data to be processed with the purpose of contacting you about the content of the report.

In the cases specified by regulatory enactments, we will process personal data in order to fulfil the legal obligations specified by Latvenergo AS, as well as process the data in order to exercise, for example, the following legitimate interests of Latvenergo AS:

  • to protect personal rights through the services of authorised and competent authorities;
  • to prevent and detect security risks (for example, by performing video surveillance at the sites and adjacent territories, providing a pass regime and controlling the access of visitors, by creating audit records);
  • to detect and investigate incidents, and to obtain evidence (for instance, to keep personal data for a certain period of time in the event of a potential dispute);
  • to introduce an organisational system to ensure that any person can submit a report on possible misconduct or dishonesty of an employee, with Latvenergo AS helping to monitor compliance with regulatory enactments and a set of ethical standards when performing the employee’s daily duties and representing the employer;
  • to ensure openness and fairness in cooperation with third parties, as well as to identify and reduce possible cases of fraud and corruption;
  • during the investigation and remediation of personal data breaches, to ascertain all specific circumstances in order to assess the impact of a personal data protection incident on the rights and freedoms of the data subject;
  • to prevent and detect security risks by transferring personal data of personnel to national security authorities for the assessment of compliance with national security interests.

Provision of Latvenergo AS services, service development and quality assurance:

  • For the consideration of applications, requests, claims, and proposals
  • For the counselling of individuals
  • For proving service provision (including communication) and the provision of quality control
  • For the registration and authentication of individuals on mobile apps, information systems and websites
  • For the provision of the functionality of websites, portals, mobile apps, and other information systems

  • Audio recordings (such as telephone recordings)
  • Authentication information
  • Identification information
  • Contract information
  • Information about the use of information systems
  • Information on opinion
  • Information contained in communication materials (for instance, in correspondence)
  • Contact details
  • Access information
  • Service provision address
  • Video recordings
  • Information on the language of communication
  • Represented company

In the cases specified by regulatory enactments, we will process personal data in order to fulfil the legal obligations specified by Latvenergo AS, as well as process the data in order to exercise , for example, the following legitimate interests of Latvenergo AS:

  • to protect the interests of the individual and Latvenergo AS, to have good knowledge of the quality of the provided services, and to provide evidence for communication;
  • to ensure the provision of services and/or communication with the actual recipient of the service and/or the communication;
  • to respond to requests for information and to ensure communication;
  • to ensure business continuity and performance during the process of the correction of errors and the delivery of new solutions, and to verify that the developed information system solution and/or add-on is working as intended.

Compliance with the requirements of laws and regulations or exercise of the rights of Latvenergo AS in accordance with the laws and regulations:

  • Provision of information to state and local government control and pre-trial investigation authorities as well as other state and local government authorities within the limits of their competence, such as the Police, the State Audit Office or archives;
  • Compliance with the requirement of the prevention of money laundering and terrorism and proliferation financing and national and international sanctions.
Any of the personal data listed above

In the cases specified in regulatory enactments, we will process personal data in order to fulfil the legal obligations specified by Latvenergo AS and perform the duty performed by Latvenergo AS in the public interest.

Within the framework of the purpose, we will process personal data, in order to exercise, for example, the following legitimate interests of Latvenergo AS:

  • to protect personal rights through the services of authorised and competent authorities;
  • to protect their rights by using information available from third parties regarding persons sanctioned under the laws and regulations in other countries and by analysing publicly available information;
  • to protect their rights by using information available from third parties in accordance with regulatory enactments and by fulfilling the obligations specified in the Law on the Prevention of Money Laundering and Terrorist and Proliferation Financing.

Personal data may be obtained from you, your employer, a public authority or information systems held by them, or another person who provides information about you, including national security authorities.

Your personal data will be processed by the authorised staff of Latvenergo AS, in accordance with the scope specified in their job duties, observing the requirements specified in personal data protection and other regulatory enactments, as well as the requirements for the processing of personal data specified in the internal regulatory enactments of Latvenergo AS.

Your personal data may be handed over to:

  • providers of outsourced services (processors) to Latvenergo AS, who are authorised to carry out certain personal data processing activities on the commission and under the supervision of Latvenergo AS, for instance, security and safety service providers, information system solution developers and maintenance service providers, and service providers who provide the transfer of information;
  • your employer;
  • providers of the postal and delivery service (if applicable);
  • Latvenergo Group company, if the respective case concerns the property or human resources of Latvenergo Group company;
  • audit and audit service providers;
  • state institutions, which must provide the information specified in the regulatory enactments;
  • under certain circumstances, to law enforcement authorities, including state security authorities, the courts, as well as to the processors of Latvenergo AS – legal service providers.

The transfer of personal data to other recipients outside the European Union or the European Economic Area or to countries and organisations for which the European Commission has not adopted a decision on an adequate level of protection shall not be provided for within the framework of personal data processing, unless the recipient is your employer.


Your personal data are processed to the extent that is reasonably necessary depending on the specific purpose of data processing under the provisions of the applicable laws and regulations.

Latvenergo AS will store your personal data:

  • for as long as it is necessary in order to achieve the purposes for the processing of personal data specified in Section 1 of the Principles, including in order to fulfil the obligations determined by regulatory enactments, for instance:
    • we will keep the information reflected in the contract concluded between Latvenergo AS and your employer for the entire validity period of the contract and for 10 years after the termination of the contract and the fulfilment of obligations. Latvenergo AS, if it considers that the information reflecting the fulfilment of the obligations under the contract is not relevant, reserves the right to erase the information earlier;
    • we will keep the information contained in the briefing logs for at least 5 years after the last entry;
    • when fulfilling the obligation specified in the Law on the Prevention of Money Laundering and Terrorist and Proliferation Financing, we will store the information obtained during the inspection for 5 years after the termination of the transaction;
    • we will store information on issued invoices and information related to payments for at least 5 years, in compliance with the provisions of the Law On Accounting”;
    • we will store audio records for no longer than 3 years;
    • we will store video surveillance recordings for no longer than 30 days if the video surveillance is carried out at Latvenergo AS facilities and adjacent areas, or for 40 days if the video surveillance is carried out at an electric vehicle charging service provision site of Latvenergo AS;
    • in accordance with Section 46 of the Law on the Procurements of Public Service Providers, all original documents of the competitive dialogue and procurement procedure, as well as original applications and bids shall be stored in the Electronic procurement system (LEIS) of Latvenergo AS for no less than three years after the decision regarding the procurement procedure has been made and for no longer than ten years, as provided for by Part Five, Section 40 of the Public Procurement Law;
    • personal data that have been included on the Supplier List and the Qualification System shall be processed for as long as the data subject is included on the Supplier List and/or the Qualification System, but for no longer than 10 years, with the maximum period being adjusted to the period specified in Part Five, Section 40 of the Public Procurement Law;
  • if the processing is based on your consent, until the moment the consent is withdrawn, for instance, if you have reported unsafe working conditions or an environmental hazard and would like to receive information on the resolution of the situation;
  • if a complaint is received or the legitimate interest of Latvenergo AS is violated, for instance, a dispute regarding the amount or quality of works performed exists, the relevant information may be retained until the resolution of the dispute is complete, or if the dispute is being resolved in court, until the date when the final court decree enters into force.

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

Right to rectification. If you notice inaccuracies in personal data, you have the right to request that Latvenergo AS corrects inaccurate personal data.

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

  • personal data are no longer necessary in connection with the purposes specified in the Principles for which they were processed;
  • personal data is processed unlawfully;
  • you have objected to the processing, and the legitimate reasons of Latvenergo AS are not more important than your legitimate reasons;
  • personal data must be deleted in accordance with the requirements of regulatory enactments.

Please note that the right to erasure does not apply in cases where, in accordance with the laws and regulations, Latvenergo AS is obliged to process personal data or the processing is necessary for archiving, public interest or statistical purposes, as well as for the purposes of filing, implementing or defending a legal claim.

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

  • you believe that the data is being processed illegally or is inaccurate (the restriction will be effective while the non-contentious appeal process is in progress);
  • you believe that the processing is illegal, but you do not wish to delete these personal data;
  • you have objected to processing, and as long as it is not verified that the legitimate reasons of Latvenergo AS are more important than your legitimate reasons;
  • Latvenergo AS no longer requires your personal data to achieve a certain purpose, but you need it to protect your legal interests and rights.

Right to object to processing. You have the right to object to the processing of your personal data at any time based on the legitimate interests set out in the Principles. Latvenergo AS has the right to continue processing your personal data if Latvenergo AS indicates compelling legitimate reasons for processing that are more important than your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

The right to withdraw consent. Where you have given your consent to the processing of certain personal data, you have the right to withdraw it at any time, however, such withdrawal of consent shall not affect the lawfulness of the processing based on the consent prior to withdrawal. You can withdraw your consent by using the contact details indicated in the Principles.

Right to portability. You have the right to receive your personal data that you have submitted to Latvenergo AS in an orderly, transferable and electronically scanned format, and you have the right to request that these data are sent to another Controller if these personal data are processed based on consent pursuant to Article 6, Paragraph 1, Sub-paragraph a) of the Regulation. Please note that you can only claim portability rights in relation to the personal data you have provided 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 failed to sufficiently protect your personal data. However, before contacting the Data State Inspectorate, you are invited to contact Latvenergo AS or the Data Protection Officer to find a solution.

For the realisation of all the above-mentioned rights, you may use the contact information of Latvenergo AS specified in these Principles, indicating the following personal data in the request: name, surname, personal identification number, postal address (if you wish to receive a reply by registered mail) or e-mail address (if you wish to receive the answer to an email address).

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

  • send a free-form application electronically to the e-mail info@latvenergo.lv or fpda@latvenergo.lv, by 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.

Latvenergo AS has the right to make amendments to these Principles and to inform you about such changes by publishing the current version of the Principles on its website and/or by sending the information to the responsible person of your company.

Document updated on 15.04.2025.