Job Candidates Privacy Policy

Contents

  1. General provisions
  2. Recipients and scope
  3. Nature, type and source of the personal data processed
  4. Purpose of processing, legal basis and storage time
  5. Persons authorised and responsible for processing
  6. Method and location of processing, including abroad
  7. Candidates’ rights

  1. General provisions

    1. Introduction.Officine Mazzocco Pagnoni S.r.l. (the "Company") undertakes to protect personal data in compliance with (i) (EU) Regulation 2016/679 ("GDPR") concerning the protection of natural persons with regard to the processing of personal data, and the free movement of said data and which abrogates Directive 95/46/EC , and (ii) the applicable Italian national legislation regarding the protection of personal data ("National Data Protection Laws").
    2. Purpose of this Privacy Policy. This Privacy Policy indicates how the Company processes the data and information provided by candidates when sending their curriculum vitae and any subsequent assessment interviews, for the purpose of possible recruitment or collaboration with the Company ("Candidates").
    3. Role of the Company. The Company processes the personal data of Candidates in its role as data controller. The Company’s identification data and references are displayed on the corporate letterhead and are in any case available on the company website.
    4. Updates and revisions. The Company reserves the right to modify and/or update this Privacy Policy, also taking into account eventual and subsequent additions and/or amendments to National Data Protection Laws and/or the GDPR and/or the European Union regulations regarding personal data protection. For this reason, this Privacy Policy is marked with a serial number and the month of publication, starting from the May 2018 version, which bears the number "00". Any new versions of the Privacy Policy will replace the previous ones and will be valid, effective and applied from the date of communication to the Candidates.
    5. Applicable regulations. The Company carries out processing in compliance with (i) the regulations established by National Data Protection Laws; (ii) the European Union regulations established by the GDPR, which are directly applicable; (iii) the provisions of the Guarantor for the protection of personal data ("Guarantor").

  2. Recipients and scope

    1. Privacy Policy recipients. This Privacy Policy is addressed to Candidates, who provide their personal data to the Company, using the following methods:
  1. by delivering their CVs and letters of recommendation ("Documents") in paper-based format directly to the Company personnel authorised to receive or send such Documents, by paper-based mail, to the address of the Company's registered office;
  2. by uploading Documents to the “Work with us” section of the Company website, [●] (“Site”) as a spontaneous application or in response to a company job vacancy advertisement;
  3. by spontaneously sending Documents to the Company's digital contacts published on the Website;
  4. by delivering or sending to third parties (e.g. companies/agencies/recruitment and head hunting platforms, employment agencies, etc.) which the Company may use for personnel recruitment activities.
    1. Scope. This Privacy Policy applies to the processing performed by the Company for the purpose of carrying out the activities connected to the assessment and selection of Candidates.

  1. Nature, type and source of the personal data processed

    1. Personal data processed. The Company processes the data of Candidates that can be defined as general - that is to say, data that does not fall into the special categories of personal data referred to in Article 9 of the GDPR ("Special Data") - with the exception of some Special Data, that may be requested from or provided by the Candidate, which the Company is required to know owing to the employment relationship that may be established, such as, in particular, eventual minority group membership or the outcome of medical examinations prior to recruitment. With specific reference to the Special Data subject to processing by the Company, it should be noted that, for the purposes of this Privacy Policy, this category shall refer only to (i) data that is strictly necessary due to its relevance to the method of carrying out the work activity specified in the recruitment procedure and/or (ii) data which constitutes an essential and decisive requirement for the purposes of carrying out the work activity in question. Candidates are therefore advised not to send Special Data if they are not strictly pertinent to the abovementioned hypothese
    2. Source of the personal data processed. Personal data, including Special Data, is contained in the Candidates’ Documents - sent to the Company in the manner set out in section 2.1 above – or in any case provided by the latter to the Company at subsequent assessment interviews aimed at verifying the skills and conditions required for eventual recruitment or the start of a working relationship with the Company.

  2. Purpose of processing, legal basis and storage time

    1. Purpose, legal basis and storage time. The Company processes personal data including the Candidates' Personal Data for the purposes set out in the following table ("Table"), which further indicates the relative legal basis and, with particular reference to consent, the requirement (or not) of express consent for the purposes of processing as well as the storage time:

 

Purpose

Legal basis

Consent

Storage time

A

To collect and analyse the personal data contained in the Candidates’ Documents transmitted/delivered directly to the Company in order to verify their skills and suitability, with a view to scheduling an interview. This processing is required to carry out pre-contractual procedures (the verification of the data contained in the Documents) adopted at the request of the Candidates, via the transmission/delivery of the Documents themselves. not required

This processing is required to carry out pre-contractual procedures (the verification of the data contained in the Documents) adopted at the request of the Candidates, via the transmission/delivery of the Documents themselves.

Not required

The Documents are stored for the period of time needed to carry out the assessments and in any case for a period not exceeding one year from their receipt; at the end of this period they are deleted, unless (i) they are required for an ongoing recruitment operation or (ii) the recruitment process results in the Candidate beginning to work/collaborate with the Company, in which case their personal data will be stored in the relative personal file, in line with the times indicated in the Privacy Policy for employees.

B

To collect and analyse the personal data contained in Candidate’s Documents made available by them to third parties (e.g. companies/recruiting agencies) that the Company may use in order to verify their skills and suitability, with a view to scheduling an interview.

This processing is based on the legitimate interest of the Company in carrying out the activities aimed at recruiting personnel to fill vacancies.

Not required

The Documents are stored for the period of time needed to carry out the assessments and in any case for a period not exceeding one year from their acquisition; at the end of this period they are deleted, unless (i) they are required for an ongoing recruitment operation or (ii) the recruitment process results in the Candidate beginning to work/collaborate with the Company, in which case their personal data will be stored in the relative personal file, in line with the times indicated in the Privacy Policy for employees..

C

To collect and assess personal data (including any Special Data within the limits stipulated in article 3.1.) provided by Candidates also in the context of assessment conversations, conducted to interview/assess the Candidates and insert them in the company recruiting process for eventual employment or collaboration.

This processing is required to carry out pre-contractual procedures (the verification of personal data provided by the Candidates during interviews and selection) adopted at the request of the Candidates; with specific reference to any Special Data provided by the Candidates, this processing is required to fulfil the obligations and exercise the rights pursuant to article 9.2 letter b) of the GDPR and, in particular, to fulfil the obligations of the specific sector discipline, and comply with art. 111-bis of Legislative Decree no. 196/2003 and the general authorisation of the Guarantor for the Protection of Personal Data contained in ruling no. 146/2019.

Not required

The personal data provided by Candidates, also in the context of their assessment interviews, are kept together with the Documents sent or delivered to the Company for the same storage time specified above in relation to the purpose in subsection A).

 

    1. Optional/mandatory provision of data. Following the transmission of Candidates' Documents, the Candidate can decide whether to provide personal data at subsequent assessment interviews with authorised Company personnel. In any case, any refusal by the Candidates to provide, in whole or in part, personal data including Special Data, that is necessary and essential for verifying the skills and indispensable conditions regarding the job position/collaboration in question, will not allow the Company to carry out the necessary and instrumental activities required to establish an employment/collaboration relationship with the Company.

  2. Persons authorised and responsible for processing

    1. The controller and persons authorised for processing. The Company is the data controller of the Candidates' personal data used for the processing activities listed in the Table. The Company’s directors, partners, managers, employees and collaborators (regardless of their specific contractual title) can process Candidates’ data, if they are authorised to process them and as long as they act in accordance with National Data Protection Laws and article 29 of the GDPR.
    2. Persons responsible for processing The Company can designate third parties as external data processors, such as professionals and service provider companies (e.g. Site hosting servers, recruiting platforms, etc.) to carry out processing on behalf of the Company for certain purposes. Candidates can request a complete list of persons responsible for processing personal data covered by this Privacy Policy by contacting the Company and sending (i) a communication by post or e-mail to the Personnel Department of the Company at the following address: privacy@omppumps.com or (ii) any written communication, including via e-mail, to the contact addresses indicated on the Company website or letterhead. According to the GDPR, the Company is not required to designate a data protection officer.
    3. Limits. The authorised persons, as well as any designated data processors, are suitably trained and equipped with specific powers that allow them to access the personal data of the Candidates, including their Special Data, according to the duties covered or the specific skills and duties and/or commitments undertaken (including contractual commitments, where, for example, the relationship exists with an external manager, pursuant to article 28.3 of the GDPR) and in compliance with this Privacy Policy.

  3. Method and location of processing

    1. Method of processing. The personal data covered by this Privacy Policy is mainly processed automatically, using IT systems or in some cases manually, in any case with logic systems strictly connected to the purposes for which the data was collected and in a way that guarantees their security, in compliance with the provisions of the GDPR and National Data Protection Laws.
    2. Location of automated processing. The personal data covered by this Privacy Policy is processed, partly at the Company's headquarters, where it is stored on the Company's servers, and partly on the servers of external data processors that the Company uses to manage its recruitment activities.
    3. Location of paper-based processing. If the personal data of the Candidates is stored in a paper-based format, the relative Documents (including CVs) in which this data is contained, is stored at the Company’s registered office – or by external processors and service providers that have been nominated and instructed in processing – and stored in special archives that are locked and accessible only to duly authorised office staff.
    4. Disclosure and communication. Candidates’ processed personal data is not subject to disclosure. Candidates' personal data can be communicated to external managers and/or service providers identified and nominated in compliance with art. 28 of the GDPR.

  4. Candidate’s rights

    1. Rights. Candidates can contact the data controller to exercise the rights established by the National Data Protection Laws and by the GDPR (articles 15 and following), and, in particular, their right to access their personal data, request it to be rectified, updated, deleted or limited, and to requesting its portability, in the following ways: by sending a communication (i) via e-mail to the address: privacy@omppumps.com or (ii) by other means to the contact addresses indicated on the Company's Website or letterhead or the e-mail address of the Company's Human Resources Department: job@omppumps.com.
    2. Right to object. In the same manner provided for in the previous article, Candidates can also object, in whole or in part, to the processing of their personal data, where the relative legal basis is constituted by the legitimate interest of the Company, pursuant to and for the effects of the provisions stipulated in Article 21 of the GDPR.
    3. Complaints. Notwithstanding the above, in compliance with the provisions of art. 77 of the GDPR, any Candidate who considers that the processing of their personal data is in breach of the GDPR, can lodge a complaint with the Guarantor (where - in accordance with the provisions of art. 77 of the GDPR - this supervisory authority is based in the State in which the Candidate habitually resides or works) or to a supervisory authority where the alleged violation has occurred.
    4. Withdrawal of consent. If the Candidate’s consent is required for certain processing activities, the latter can withdraw this at any time - unless it involves mandatory obligations established by the legislation in force at the time of the withdrawal request - by contacting the Company in writing at the addresses indicated on the Company's Website or letterhead or at the above addresses of the Company's Personnel Office, which will carry out all the activities required including those resulting from the withdrawal as long as they do not affect the legality of processing activities based on the consent given before it was withdrawn.

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