Privacy policy for candidates pursuant to articles 13 and 14 of Regulation (EU) 2016/679
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Reference legislation:
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Yarix S.r.l. (hereinafter “the Company”), an “S.r.l.” limited liability company subject to the control of Var Group S.p.A. pursuant to article 2359 of the Italian Civil Code, with registered office at Vicolo Boccacavalla 12, 31044 Montebelluna (TV), Italy; VAT no. IT03614930265, hereby informs you that your personal data will be processed pursuant to applicable legislation on the processing of personal data.
Specifically, the Company acts as Data Controller with regard to the processing of personal data, defined as “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”.
Data Processor should be taken to mean “the natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.”
Processing of personal data means “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”
In concrete terms, processing of your personal data may be carried out by parties duly authorised by the Company to perform such operations on personal data.
This policy is provided to you for the purposes of information as a “data subject”, meaning the physical person to whom the personal data refer.
1 | Personal data subject to processing
The personal data are provided directly by you to the Company, or collected by the Company via Var Group S.p.A., the parent company pursuant to article 2359 of the Italian Civil Code, or else by SeSa S.p.A., holding company of the SeSa S.p.A. group of companies to which the Company belongs and to which it has entrusted HR management.
The personal data subject to processing may include, in particular, personal identifying data, telephone numbers and email addresses, information on education, training and prior career experience, information on specific skills and expertise, photos of you and any further information provided in your curriculum vitae.
Sensitive information, that is data falling under the classification of “special categories of personal data” pursuant to article 9 of the EU regulation may also be subject to processing. This category includes personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data aimed at uniquely identifying a natural person, data concerning the health or sex life or sexual orientation of the person.
2 | Purposes of the data processing and legal basis of the processing of personal data
Your personal data will be processed in order to evaluate your application, carry out a hiring interview and perform any other activity required to complete the selection process aimed at potential hiring or establishing an employment relationship with the Company, in compliance with equal-opportunities legislation (Italian Legislative Decree no. 198 of 11 April, 2006, as amended by Italian Legislative Decree no. 5 of 25 January 2010 and Italian Law no. 183 of 4 November, 2010).
In this case, the Company will process your personal data for the purposes of implementing the precontractual measures adopted upon your request for the purposes of establishing an employment relationship with the Company; as such, your consent is not required.
Please note that the Company does not make requests for personal data which falls under the “special categories of personal data” specified in article 9 of the EU regulation; as such, any such information provided in your curriculum vitae will be considered as being voluntarily provided and any processing will occur on the basis of your implicit consent.
Consent to the processing of personal data may be withdrawn at any time; withdrawal of consent does not affect the lawfulness of any processing performed prior to such revocation.
3 | Methods and duration of processing of personal data
Your personal data will be processed by the relevant departments of the Company interested in your professional profile, as well as by employees of the Company who need to process such data in consideration of the roles performed. Please note that company personnel have received prior authorisation and training on processing of personal data.
Your personal information may be processed by Var Group S.p.A., the parent company pursuant to article 2359 of the Italian Civil Code, and by SeSa S.p.A., holding company of the SeSa S.p.A. group of companies to which the Company belongs and to which it has entrusted HR management.
With reference to further parties authorised to process your personal data, see point 5 of this policy.
Processing may be performed through the use of computerised, telematic or hardcopy media and tools, pursuant to provisions designed to guarantee security and confidentiality of the data, as well as ensuring that the data are accurate, up to date and relevant to the declared purposes.
All processing is performed through the adoption of technical and organisational measures able to guarantee an appropriate level of security for the risks pursuant to the principles of article 5 of the EU regulation and the methods outlined in article 32 of the same, as well as the provisions laid out by the Italian Data Protection Authority.
In this regard, we also confirm the adoption of appropriate security measures to prevent unauthorised access, theft, disclosure, alteration or destruction of your personal data.
The personal data collected will be held in electronic and/or hardcopy archives at the Company’s registered offices and operating sites, or at the registered offices and operating sites of Var Group S.p.A., the parent company pursuant to article 2359 of the Italian Civil Code, or else at the registered offices and operating sites of SeSa S.p.A.
Your personal data will be stored only for the period of time necessary to manage all activities required for the employee search and selection process, and in any case for no longer than 36 months from the time they were collected; after this time, your personal data will be deleted from our systems. The Company reserves the right, where required, to contact you before deletion in order to determine whether you still wish processing of your personal data to be performed for the sole purposes identified in this policy.
4 | Nature of providing your personal data
Providing your personal data is optional; nevertheless, refusal to provide this data would prevent us from carrying out the activities required to complete the selection process required to hire you or establish an employment relationship with you; as a consequence, providing your personal data is “mandatory” for the purposes of complying with your specific request.
5 | Recipients of personal data
Within the limits of the purposes specified in this policy, your personal data may be disclosed in order to fulfil a legal, regulatory or EC obligation.
In particular, your personal data may be disclosed to public security authorities, public bodies or private companies in order to fulfil legal obligations.
Your personal data may be processed by Var Group S.p.A., the parent company pursuant to article 2359 of the Italian Civil Code, if it has shown interest in your professional profile.
Your personal data may also be processed by SeSa S.p.A., holding company of the SeSa S.p.A. group of companies to which Yarix S.r.l. company belongs and to which it has entrusted HR management; to this end, SeSa S.p.A. is operating as a Data Processor specifically nominated by the Company.
If you have registered and created a professional profile on the dedicated recruiting platform on the SeSa S.p.A. or Var Group S.p.A. website, your personal data may also be processed by the provider of this platform. This provider has been specifically nominated by the Company to perform these processing operations on personal data performed within the scope of technical operations on the platform itself.
Personal data will not be transferred outside the European Union (EU) or European Economic Area (EEA).
Personal data will not be published or disseminated, i.e. divulged to the public or an unlimited number of parties.
6 | Rights pursuant to articles 15, 16, 17, 18, 20 and 21 of Regulation (EU) 2016/679
You can exercise your rights to access your personal data provided for by article 15 of the EU regulation and the rights provided for pursuant to articles 16, 17, 18, 20 and 21 of the same regulation regarding rectification, erasure, restriction of the processing, portability (where applicable), and the right to object to the processing of your personal data.
You may exercise your rights by writing to the following address: privacy@yarix.com
Should the Company not provide a response within the timeframe laid out in the regulation, or if you do not consider the response adequate, you can lodge a complaint with the Italian Data Protection Authority.
Contact details:
Garante per la Protezione dei Dati Personali (Italian Data Protection Authority)
Fax: (+39) 06 69677 3785
Telephone: (+39) 06 696771
Email: garante@gpdp.it
7 | Data Protection Officer
SeSa S.p.A., holding company of the SeSa S.p.A. group of companies to which Yarix S.r.l. belongs in consideration of the control of Var Group S.p.A. pursuant to article 2359 of the Italian Civil Code, has nominated a Data Protection Officer for the group companies.
The Data Protection Officer supervises compliance with regulations governing processing of personal data, and provides consultancy where required. Moreover, they cooperate with the Italian Data Protection Authority where required.
The Data Protection Officer and relative contact details are specified below:
Privatamente S.r.l.
Email: dpo@sesa.it