Recruitment

Privacy Policy in accordance with Article 13 of Regulation (EU) 2016/679 (“GDPR”) on Personal Data Processing

1. Data Controller
We hereby inform you that, pursuant to Art. 13 of the GDPR, Sofidel S.p.A., as data controller (Data Controller or Company), which can be contacted at the address [email protected], shall process your personal data, which you provide by filling out the online form and/or by spontaneously submitting your curriculum vitae, or later as part of any staff recruitment and selection process, in order to establish a working relationship with the Company.

2. The Data Protection Officer
We hereby inform you that the Company has appointed a person in charge of data protection (“DPO”), who is available for any information regarding the processing of your personal data and can be contacted at the address [email protected]

3. Types of data processed
The data processed by the Data Controller may include:
1) Common data, such as personal details (e.g. name, surname, date of birth, address, image, sex, marital status, tax code, etc.), contact details (e.g. landline and/or mobile telephone number, e-mail address, etc.), work and professional details.

2) Where appropriate, data belonging to the ‘special categories’ referred to in Article 9(1) of the GDPR, i.e. data revealing racial or ethnic origin, religious beliefs, political opinions, membership of political parties, membership of trade unions, associations or organisations of a religious or philosophical nature, biometric or genetic data, and health status (for example, belonging to what are known as protected categories).

The personal data indicated above will be jointly defined below, for brevity, as “personal data”.

4. Purpose, lawful basis and optional nature of the processing
Without the need for your specific consent, your personal data will be processed for the following purposes:

a) To assess the suitability of your profile for open positions and, in general, to manage staff selection procedures and to contact you in order to schedule any interviews that may be necessary (“Purpose of managing your application”) pursuant to Articles 6(1)(b) and (f) of the GDPR and 111-bis of Italian Legislative Decree 196/2003 (“Privacy Code”), i.e. in execution of pre-contractual measures adopted at your request and on the basis of the Data Controller’s legitimate interest.

b) To fulfil any legal obligations to which the Data Controller is subject pursuant to Articles 6(1)(c) and 9(2)(b) of the GDPR (“Compliance Purpose”).

c) To defend against any legal claims on the basis of Articles 6(1)(f) and 9(2)(f) of the GDPR (“Purpose of defence in court”).

We would like to inform you that any processing of data belonging to the special categories referred to in Article 9(1) of the GDPR for these purposes may only take place, pursuant to Article 9(2)(a) of the GDPR, with your explicit and specific consent and in accordance with the pro tempore authorisations in force regarding the protection of personal data. If not strictly necessary, therefore, we ask you not to provide this type of information. If you decide to provide such information, you will be asked to give your consent in accordance with the applicable personal data protection legislation. In the absence of your consent to the processing of any special data provided by you, such data will not be considered for the purposes of your application. In any case, the Company’s compliance with Art. 8 of Law 300/1970 (known as the “Workers’ Statute”) remains unaffected, as it undertakes not to conduct any investigation, including through third parties, into the political, religious or trade union opinions of the worker, as well as any other fact that is not relevant for the purpose of assessing the candidate’s professional aptitude.

The consent given by you may be withdrawn at any time, without prejudice to the lawfulness of any processing conducted prior to such withdrawal.

The provision of your personal data for the purposes indicated above is optional, but in its absence, it may be impossible for the Data Controller to assess your profile or schedule interviews.

It is also possible that you voluntarily provide the Company – within the framework of the above procedure – with data relating to third parties. We would like to inform you that, in relation to such cases, you are the independent data controller with all the obligations and responsibilities under the law. On this point you shall hold the Data Controller harmless in the broadest possible sense against any dispute, claim or compensation for damages resulting from such processing, etc. that may be received by the Data Controller from third parties whose personal data has been processed through your spontaneous communication in breach of the applicable rules on personal data protection. Should you provide or otherwise process the personal data of third parties, you warrant as of now – accepting all related liability – that this particular case of processing is based on an appropriate lawful basis legitimising the processing of the information in question.

5. Recipients and transferral of personal data
Your personal data may be shared with:

– Natural persons authorised by the Data Controller pursuant to Art. 29 of the GDPR in the performance of their duties (e.g. employees and system administrators, etc.).

– Other service providers (such as, for example, the IT operator of the “Work with Us” portal, consultants, etc.), who typically act as data processors pursuant to Art. 28 of the GDPR (the complete and updated list of data processors can be obtained from the Data Controller at the contact details given above).

– Subjects, entities or authorities, independent data controllers, to whom it is compulsory to communicate your personal data pursuant to the provisions of law or orders by the authorities.

We also hereby inform you that your personal data will be accessible to other companies in the Sofidel Group for administrative and accounting purposes in accordance with Art. 6(1)(f) and Recitals 47 and 48 of the GDPR.

With regard to the transfer of data to Third Countries, the Data Controller informs you that the processing will take place according to one of the methods permitted by current law, such as the consent of the data subject, the adoption of Standard Clauses approved by the European Commission, the selection of parties participating in international programmes for the free movement of data (e.g. EU-USA Privacy Shield) or operating in countries the European Commission considers secure. Further information may be obtained, on request, from the Data Controller and/or the DPO using the above contact details.

6. Retention of personal data
Your personal data will be kept for no longer than is necessary for the purposes for which it was collected, in accordance with the principle of minimisation referred to in Article 5(1)(c) of the GDPR. As far as the curriculum vitae sent is concerned, the personal data contained therein will be kept for a maximum of 1 (one) year. The Data Controller may contact you shortly before the indicated expiry date to request an extension of this retention period. Personal data processed for the purposes referred to in Section b) will be kept until the time set out in the specific applicable obligation or rule of law.

Further information may be obtained from the Data Controller and/or the DPO at the above contact details.

7. Data processing methods
In relation to the aforementioned purposes, the processing of personal data is performed by means of manual, computer and electronic tools with logic strictly related to the purposes and in such a way as to ensure the security and confidentiality of the data, in addition to compliance with specific obligations under the law.

8. Your privacy rights
You have the right at any time to request from the Data Controller access to your personal data, its rectification or deletion, and to object to its processing. You have the right to restrict its processing in the cases laid out in Art. 18 of the GDPR, to withdraw the consent you have given pursuant to Art. 7 of the GDPR at any time, to receive the personal data concerning you in a structured, commonly used and machine-readable format in the cases laid out in Art. 20 of the GDPR, as well as to lodge a complaint with the competent supervisory authority pursuant to Art. 77 of the GDPR (Personal Data Protection Authority), should you believe that the processing of your data contravenes the regulations in force.

You can object to the processing of your data under Art. 21 of the GDPR in which you give evidence of the reasons for your objection: the Data Controller reserves the right to evaluate your request, which will not be accepted if there are legitimate grounds for the processing which override your interests, rights and freedoms.

Requests should be sent in writing to the Data Controller or to the DPO at the following email addresses: [email protected] or [email protected].

Having read and understood this Privacy Policy.