DATA PROTECTION INFORMATION SHEET FOR CANDIDATES
Regulatory references:
- Italian Law Decree N.196, dated June 30, 2003 modified by Italian Law Decree n. 101 dated August 10, 2018, Personal data protection law (the “Privacy Law”)
- European Regulation n. 679 dated April 27, 2016 relating to the protection of natural persons as regards treatment of personal data, as well as free circulation of personal data (the “Data Protection Regulation”)
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We would like to inform you that, upon receiving your resume, in order to verify the possibility of transforming your candidacy into a labour relationship, AIM Group International S.p.a. collects and processes personal data that relate to you (as a “Data Subject”) as well to to your family-members (in case), which will be subject to data processing in compliance with the currently valid norms regarding personal data processing.
As per article 4 of the Data Protection Regulation, “personal data” means “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
The Data Protection Regulation at article 9 defines the “special categories of personal data”, i.e. those that reveal, for instance, racial or ethnic origin, membership of a political party, religious or philosophical beliefs, trade union membership, data related to sex life or sexual orientation, as well as data which might reveal a general state of health (absence of illnesses, maternity, accidents or so-called mandatory hiring because of disability) and presence or absence of suitability to specific professions.
Processing of personal data (article 4 of the Data Protection Regulation) is defined as the execution of “whatsoever action or set of actions, executed with or without the assistance of automated processes and applied to personal data or sets of personal data, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.
In particular, with reference to the activity of personnel selection, AIM – provided you express your explicit consent – may process special categories of data which might reveal, for instance a general health condition or specific conditions:
a) as they are necessary to determine the possibility of the Data Subject to be hired as a member of so-called protected categories;
b) as they are useful to evaluate the candidacy in relationship with specific jobs, provided that the effective evaluation of eligibility – if any – will be made subsequently, upon hiring, in compliance with the applicable norms.
Provided you give specific consent and always with reference to the activities of personal selection, we might as well acquire and manage, among your personal data, one or more photographic images, to be attached to the information acquired during the selection interview. These images may be used with the scope of better identifying the candidate and of loading them into the candidates management software (if any).
1. Controller, Processor and Data Protection Officer
The Controller of the personal data processing is AIM Group International S.p.a. (hence, the “Controller” or “AIM”), Italian fiscal code 05075630482, Italian VAT number 06486081000, with legal offices in Via Giuseppe Ripamonti n. 129, 20127 Milano, Italy, phone +.39.02.566011, fax +.39.02.56609059 and e-mail [email protected].
The updated list of Processors, where nominated, can be provided upon request by the Users.
The information relating to the Data Protection Officer (as per article 37 of the Data Protection Regulation) nominated by AIM can be retrieved at the following link: https://www.aimgroupinternational.com/company-information.
2. Purposes, ways and duration of processing
The personal data of the Data Subject are processed in the context of the Controller’s ordinary personnel selection activity in order to verify the possibility of transforming your candidacy into a labour relationship.
Your personal data are processed, moreover, with the scope of evaluating your candidacy, of contacting you in order to organize a professional interview and to execute any other activity necessary for the action aimed at defining the labour or cooperation relationship with AIM, complying with the principle of equality between male and female candidates which is prescribed by the prohibition of gender discrimination as per Italian Law Decree n. 198, dated April 11, 2006, (Law on Equal Opportunities for men and women), as modified by Italian Law Decree n. 5, dated January 25, 2010 and by Law n. 183, dated November 4, 2010.
With reference to aforementioned purpose, the processing of the data is performed by parties specifically commissioned, authorized and instructed for data processing as per article 2-quaterdecies of the Privacy Law and article 29 of the Data Protection Regulation, as well as by external entities (such as, head-hunting companies, external consultants for calculation of compensation and social contribution data, etc.), which may assume the qualification of autonomous Data Controllers or be designated in writing to be Data Processors.
The processing may be executed by means of IT, telecom or hardcopy tools in compliance with the norms safeguarding security and confidentiality, with the scope of impeding unauthorized access, theft, publication, modification or non-authorized erasure of the data subject’s data, as well as guaranteeing, among other things, the accuracy, updates and correspondence of the personal data with the declared purposes.
The collected personal data will be stored in electronic and/or paper archives at AIM offices, for the timeframe strictly necessary to manage all activities required by the process of research and selection of personnel and, in any case, for a period not exceeding 36 months from their collection, unless the scopes for which the data of your resume are stored allow for a longer period of time. Once this timeframe has lapsed, your personal data will be erased. AIM reserves the right, in case, to contact you previously to erasure of the data in order to verify your ongoing interest in extending the personal data processing for the sole scopes listed in this information sheet.
Your data will be processed in Italy and, in any case, within the European Union.
3. Mandatory or optional nature of data transfer, consequences of denial and juridical basis for processing
With reference to aforementioned purposes, the transfer of personal data is mandatory, as otherwise the possibility of creating a labour relationship with the Data Subject could not be enacted. Thus, the juridical basis for processing is the assessment of the possibility of creating a labour relationship with the Data Subject and upon request of the latter (as per article 6, paragraph 1, letter b of the Data Protection Regulation).
With reference to special categories of data, as they allow to identify, for instance, a general state of health or specific conditions (such as physical problems, allergies, belonging to so-called protected categories and level of disability), the juridical basis for processing is your explicit consent, as per article 9, comma 1, letter a) of the Data Protection Regulation.
The submission of one or more photographic images to be attached to the information gathered during the interview for personnel selection is optional; lack of submission or denial of consent does not determine the impossibility to participate to the selection procedure: thus, the juridical basis if your Consent (if any), as per article 6, comma 1, letter a) of the Data Protection Regulation.
4. To whom and in which context we may transmit Data Subject’s personal data.
Within the limits of abovementioned purposes, your data may be communicated, in compliance with a duty imposed by law, regulation or EU norms.
In particular, your personal data may by communicated to public security Authorities, Public Entities or private companies for the compliance with legal obligations.
In addition, as AIM belongs to a commercial Group, your personal data may be communicated to the other companies of the Group, in order to verify the possibility of transforming your candidacy into a labour relationship in one of these companies, even if a different entity from the Controller.
Your data will not be transferred outside of the territory of the European Union (UE).
Abovementioned parties, to whom your personal data will or may be communicated (insofar as not being Data Processors in writing), will process the personal data as Data Controllers as defined in the applicable norms, in full autonomy as they are not linked to the processing executed by the Controller. A detailed and constantly updated list of these parties, including their addresses, is always available at the Controller’s legal offices.
Personal data will not be deseminated and will thus not be communicated to the public or to an indefinite number of subjects.
5. Rights of the Data Subject
You may exercise the rights of access to personal data as foreseen by article 15 and following of the Data Protection Regulation, within the limits as described at art. 2-undecies of the Privacy Law and according to the modalities described by the Data Protection Regulation regarding correction and erasure, transferability, limitation of processing and opposition to processing of personal data.
You may exercise your rights by writing to the addresses of the Controller as indicated above.
6. Right to lodge a complaint as per art. 77 of the Data Protection Regulation
In case AIM does not follow up with you within the timeframe defined by the regulation or in case the follow-up to your exercising your rights results to be unsuitable, you may lodge a complaint with the Authority for Protection of Personal Data, at the following addresses: web-site www.gpdp.it or www.garanteprivacy.it, email [email protected], telefax (+39) 06.69677.3785, phone (+39) 06.69677.1.
The Controller
AIM Group International S.p.a.
