Privacy policy for the selection of candidates pursuant to art. 13 of European Regulation no. 679/2016

ver. 1 of 28/02/2019

Comecer S.p.A. commits itself to protecting and respecting your privacy. This Disclosure, according to the provisions of art. 13 of European Regulation no. 679/2016, is aimed at providing you with all useful information on the topic of the personal data which you communicated to us by sending your application for an open position through the website www.comecer.com (“Website”), by accessing the section “Work with us”, and which we will process for the purposes and according to the methods specified below.

We therefore invite you, prior to communicating any personal data, to carefully read this disclosure (hereinafter, “Disclosure”) as it contains important information on the safeguard of personal data and on the security measures adopted by Comecer S.p.A. in order to guarantee its confidentiality in full compliance with the General Data Protection Regulation (GDPR).

For information pertaining to, instead more generally speaking, the processing of personal data collected through the Website provided directly by your or, in any case, generated by the use of the Website, you can consult the Privacy Policy published here: https://www.comecer.com/privacy-policy/.

A table of contents is provided here below to allow you to go directly to the sections of the Disclosure that interest you the most:

TABLE OF CONTENTS

The data controller

Which personal data is processed?

For what purpose do we use personal data that pertains to you?

Are you required to provide us with the personal data that we ask of you?

To whom do we communicate your data?

For how long do we retain your data?

Your rights

Possible changes to the disclosure

The data controller

The Data Controller that processes your data is Comecer S.p.A., with registered office in Castel Bolognese (RA), Via Maestri del Lavoro, 90 (hereinafter, simply “Comecer” or the “Data Controller”).

Which personal data is processed?

The processed data is the data voluntarily provided by you at the time of application or subsequently. This data is usually contained in a Curriculum Vitae (personal detail, education and training, work experience, specific skills and knowledge), as well as additional data that may be provided by you during the selection procedure (“Personal Data”).

In order to prevent any processing of unnecessary data, we invite you to exclude from your Curriculum Vitae or in any subsequent communication sent to the Data Controller any information or data that is not strictly relevant to the selection.

In order to apply for a position at the Comecer company, we kindly ask you to complete the registration procedure in the reserved area of Comecer’s website, by clicking on the following link: https://www.comecer.com/register/.

Through this registration, you have the possibility to attach your C.V. or other documents relevant to your application but also – as described in more detail in Comecer’s Privacy Policy – to freely access the contents (information, commercial material) published by Comecer and to sign up for our newsletter. For additional information with regards to the above, please consult the information provided in letter C) of the section “Which personal data is collected and for which purposes is it processed?” of Comecer’s Privacy Policy.

Through your C.V. or subsequently, the Data Controller may also collect special categories of Personal Data as defined by art. 9 of the GDPR (“Special Data”), such as, for example:

  • data suited to revealing the racial or ethnic origin;
  • political opinions, religious or philosophical beliefs;
  • membership in trade unions;
  • data pertaining to the person’s sexual life or sexual orientation.

Any processing of such data will take place, pursuant to art. 9 of the GDPR, subject to your explicit consent and in compliance with the pro tempore authorisations in force on the subject of personal data protection. To this end, unless it is absolutely necessary, we ask you to refrain from providing this type of information; otherwise, should you decide to provide it, we ask you to grant you specific consent in compliance with the regulations in force on the subject of personal data protection. In fact, we remind you that without such consent on your part to the processing of your Special Data, in case you provide us with this type of data, your application will not be taken into consideration.

Moreover, accidental processing may take place of personal data pertaining to third-party subjects sent to Comecer (e.g., through the sending of documents enclosed with the job application). Given this scenario, you become an independent data controller, undertaking all the associated legal obligations and responsibilities. In this sense, you undertake to hold Comecer harmless from any dispute, claim, request for compensation for damages caused by the processing, and so on, which may be submitted against Comecer by third-party subjects the personal data of which has been processed through your voluntary sending, in violation of applicable rules on personal data protection. In any event, should you provide or treat in any other way the personal data of third-party subjects, you are required to guarantee as of now – assuming any associated responsibility – that said particular processing situation has a suitable legal basis pursuant to art. 6 of the GDPR which legitimises the processing of the information in question.

For what purpose do we use personal data that pertains to you?

The Personal Data provided by you through the sending of your job application or subsequently will be treated for the following purposes:

1) evaluating the congruence of your profile with respect to the open positions at Comecer and, more generally speaking, for managing the employees’ selection procedures;

2) contacting you for the purpose of scheduling the necessary job interviews, using the contact data provided by you.

The processing of your personal data for the aforementioned purposes has as a legal basis art. 6, par. 1, letter b) of the GDPR”, in other words the processing is necessary for execution of pre-contractual measures adopted at the request of the data subject, as well as in art. 111-bis of Italian Legislative Decree 196/2003. The processing of your Personal Data belonging to special categories as per art. 9 of the GDPR for the aforementioned purposes has, instead, as a legal basis art. 6, par. 1, letter a) of the GDPR, in other words you free and informed consent to the processing.

Are you required to provide us with the personal data that we ask of you?

The provision of your Personal data and the relative processing is absolutely optional; however, any refusal to provide the data (or your intention to request that such data be deleted), may make it impossible for Comecer to begin or continue the selection procedure or the evaluation of your job application.

To whom do we communicate your data?

Your Personal Data may be shared with:

  1. subjects within the Company who act in the capacity of data processors authorised by the Data Controller;
  2. external subjects who carry out specific tasks on behalf of the Data Controller which are functional to the aforementioned purposes (e.g., labour consultants, etc.);
  3. third-parties appointed by the Company for the supply of IT or storage services;
  4. public agencies for the fulfilment of regulatory requirements or of specific requests.

The subjects belonging to categories to which the data may be disclosed will use said data in the capacity of “Data Processors” specifically appointed by Comecer pursuant to art. 28 of the GDPR or of independent “Controllers”.

For any additional information about the Data Processors, you may contact the Data Controller directly by sending an e-mail to Comecer’s Privacy Officer: gdpritaly@comecer.com.

Apart from the aforementioned cases, your Personal Data will not be communicated or transferred to third parties.

For how long do we retain your data?

Your Personal Data is retained by Comecer for the time strictly necessary to achieve the purposes for which it is processed or according to the terms indicated by applicable national and European Community laws, standards and regulations.

Your Personal Data will be retained for the aforementioned purposes 1) and 2) for a period of 12 months from the date on which it was provided, and may be used to contact you and for any future job interviews, including in connection with open positions other than the one for which you applied. At the end of said period, your Data will be permanently deleted.

As regards, instead, the retention time of your Personal Data provided/collected for purposes of registering in the reserved area of the Website and processed, with your consent, for the purpose of sending you newsletters and commercial communications, we invite you to consult the section “For how long will your Data be retained?” of Comecer’s Privacy Policy.

In case you are hired by Comecer, the Personal Data pertaining to you will be stored and processed by Comecer based on the privacy policy for employees.

Your rights

You are entitled to ask the Data Controller, at any time, to access your Personal Data, its rectification or deletion or to object to its processing, to request the limitation of the processing in the cases provided for by art. 18 of the GDPR, as well as to obtain the data that pertains to you, in a structured format, commonly used and readable from an automatic device, in the cases provided for by art. 20 of the GDPR.

You are also entitled to revoke your consent to the processing of special data provided by you as per art. 9 of the GDPR at any time, without compromising the lawfulness of the processing based on consent given prior to its revocation, only for the purposes for which the juridical basis is the consent.

You may exercise your rights, or request information from the Data Controller by sending an e-mail to Comecer’s Privacy Officer, at the following address: gdpritaly@comecer.com, or by sending a letter in a sealed envelope to the Company’s registered office located in Castel Bolognese (RA), Via Maestri del Lavoro 90, to the attention of Comecer’s Privacy Officer.

Requests relative the exercise of your rights will be dealt with without undue delay and, in any event, within 30 days from the date on which the request was received.

In any case, you are always entitled to submit a claim to the competent supervisory authority (for Italy it is the “ Garante per la Protezione dei Dati Personali”), pursuant to art. 77 GDPR, should you believe that the processing of your data is contrary to regulations in force.

Changes

Comecer reserves itself the right to change or update this Disclosure, including for the purpose of fulfilling new obligations set by the laws in force or for technical needs.

The Data Controller

Comecer S.p.A.

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