INFORMATION ON THE PROCESSING
OF PERSONAL DATA
WHO WE ARE AND WHY WE PROCESS YOUR PERSONAL DATA
The information below seeks to give a clear and transparent outline of which personal data we collect and process during the staff selection process, in accordance with the General Data Processing Regulation 2016/679 (hereinafter GDPR or Regulation), applicable from 25 May 2018 in every member state of the European Union.
Specifically, data subjects in this case are natural persons who send their CV either spontaneously or to apply for vacant positions.
Italpepe 2 S.r.l., with registered offices at Via Ardeatina, 2479 – 0034 Rome (Rm), in the person of its president Alfonso Vitaletti (hereinafter also “ITALPEPE”) is the Controller of your personal data (hereinafter also “the Controller” or “we”).
Within the ITALPEPE organisation, the HR department manages human resources and has an obligation to provide information regarding the processing of the personal data of employees, contract workers, admin workers and interns.
For any questions regarding the processing of personal data, you can email us at firstname.lastname@example.org.
PURPOSES AND LEGAL BASIS FOR DATA PROCESSING
Personal data provided, whether contact details or information regarding education, skills and previous professional experience, is processed for purposes associated with the selection and eventual recruitment of ITALPEPE staff, planning of activities and internal checks, by electronic means or otherwise, and the corresponding consultation and comparison.
CVs sent spontaneously, when considered of no interest, will be destroyed and not stored; where considered of interest, the candidate will be contacted with a request to store the CV digitally/in hard copy, and they will also be provided with this document.
The legal basis for this processing may include the necessity of pre-contractual measures, but also the execution of necessary controls and checks based on the premise of legitimate interest of the Data Controller.
Processing of a candidate’s data may be geared to “particular categories of personal data”, i.e. personal details that reveal ethnicity, political opinions, religious or philosophical beliefs or trade union affiliation, as well as genetic and biometric data which can unequivocally identify a natural person; also details of the individual’s health, sex life and sexual orientation.
The premise for the potential processing of such “particular” data, where included in the CV, is that such information is provided directly by the data subject and its processing may be necessary to fulfil obligations and exercise specific rights of the Data Controller and the data subject regarding employment rights, social security and protection.
METHODS OF COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA
The processing of personal data will be carried out in line with the principles of honesty, lawfulness and transparency, and to protect the right to confidentiality, and will be carried out using manual, paper and automated instruments for the time period strictly necessary to fulfil the purposes for which it was collected.
CVs retained for further selection processes are stored in digital format in dedicated secure folders with no expiry date, unless the individuals concerned ask us to erase them, or send us an updated CV.
Selection processes involve the use of instruments (e.g. written notes, calculations, digital documents) to evaluate candidates; these will be destroyed immediately or, if storage is needed, protected by encryption.
Specific security measures are in place to prevent data loss, unlawful or incorrect use and unauthorised access.
In the selection process, personal data will be stored for the entire period of the process, and while obligations or fulfilment remain in connection with it, or in compliance with legal or regulatory obligations or for the purpose of defence of self or third parties (e.g. requests for access to documents).
Personal data will be processed in accordance with the law and the obligations of confidentiality required from authorised ITALPEPE staff and any external personnel who carry out processing as Data Supervisors on behalf of ITALPEPE, such as email system managers.
Regulation (EU) 2016/679 (articles 15 to 23) guarantees specific rights to data subjects. In particular, regarding the processing of your personal data, you have the right to request the following from ITALPEPE: access to your data, rectification, erasure and portability; restriction on processing or objection to processing.
Right to access: you can ask ITALPEPE to confirm whether or not your personal data is being processed, and if so, obtain access to your data;
Right to rectification: you can ask ITALPEPE to rectify incorrect personal data relating to you;
Right to erasure/to ‘be forgotten’: you can, under certain circumstances, obtain from ITALPEPE the erasure of personal data relating to you;
Right to portability: under certain circumstances, you can receive from ITALPEPE your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit the data to another controller without hindrance from ITALPEPE;
Right to restriction of processing: under certain circumstances, you can obtain a restriction on processing by ITALPEPE;
Right to object to processing: you can object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you; ITALPEPE will no longer process the data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
You may also make a complaint to the relevant supervisory authority, which in Italy is the Data Protection Authority.
You may request to exercise these rights at any time from ITALPEPE, by emailing email@example.com.