Privacy notice about the processing of personal data pursuant to articles 13-14 of the General Data Protection Regulation (EU) 2016/679 (hereinafter also referred to as “GDPR”).
Dear Sir/Madam, in compliance with current legislations and regulations, we hereby inform you about the processing of your personal data that will be carried out by our company, as “data controller”, in order to evaluate your application and manage the eventual selection phase.
1. Purpose of this document.
The purpose of this document is to provide applicants, with the following information regarding the processing of your personal data:
- what does “processing of personal data” mean;
- who is the “data controller”;
- which kind of data are processed;
- which are the purposes and methods of processing;
- if the treatment involves automated decision-making processes (such as profiling);
- which are the legal basis of processing;
- who the data may be communicated or disseminated to by Primeur and the scope of such data dissemination;
- which is the timing of the data retention;
- which is the nature (compulsory or optional) of the processing;
- which are the rights of the applicant, in its quality of data subject.
2. Processing of personal data – definitions.
Pursuant to art. 4 of the GDPR, the term “processing” 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.
Personal Data means any information relating to an identified or identifiable natural person (the “data subject”); 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.
3. Controller and Processors.
Data controller of your personal data is Primeur Italy S.r.l., VAT number: 07615530966, with registered office in Via Uberto Visconti di Modrone, 11, Milano (MI) – ITALY.
The e-mail address for contacting Primeur about the protection of personal data is: privacy[at]primeur.com
Pursuant to art. 4 of the GDPR:
- “controller” is the person which determines the purposes and means of the processing of personal data;
- controller may appoint third parties as “data processors” (i.e. subjects processing personal data on behalf of the controller), as specified below.
4. Personal data processed.
Within the relationship with Primeur, inter alia, the following personal data will be treated: name and surname, place and date of birth, social security number, residence / domicile address, e-mail address, telephone numbers, working hours, family members’ data, curriculum, previous work experience, specializations, qualifications, contractual and salary data, productivity bonus, details of banking relationships, deductions, reimbursement of expenses.
Primeur may also process special categories of personal data, as per art. 9 of the GDPR (such as the suitability to certain tasks).
5. Purposes of processing.
The processing of your personal data may be carried out by Primeur for the purpose of evaluation and selection, possibly also in relation to other job offers consistent with your professional profile.
6. Methods of processing
Your data will be processed by Primeur mainly with digital procedures and may be accessed by our authorized personnel and / or third parties who perform, on our behalf, as data processors, some technical and organizational activities, such as administrative, accounting, tax or IT advisors.
The processing of your data will satisfy the principles of proportionality, fairness, lawfulness, transparency and protection of both your privacy and rights and will not involve automated decision-making processes, including profiling.
7. Basis of the processing.
Pursuant to art. 6 of the GDPR, processing is to be considered lawful only if and to the extent that at least one of the following legal basis applies: consent, performance of a contract, fulfilment of a legal obligation, pursuit of a legitimate interest of the data controller, protection of the vital interests of the data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Your personal data will be processed by Primeur on the basis of the consent you have given for selection purposes.
8. Recipients of the data collected.
Your personal data may be accessed by other subsidiaries of Primeur Group, to the extent strictly necessary and based on any existing intercompany agreement set for the functioning of the departments involved, with reference to the selection process.
In accordance with GDPR, Primeur appoints its suppliers as data processors, if they process personal data collected by Primeur, with the aim of guarantee an adequate protection of the rights connected to them.
Personal data collected may be transferred outside the European Union to be processed by third parties providing services to Primeur. In such case, Primeur would ensure that this transfer takes place in compliance with current legislation and that an adequate level of protection of personal data is guaranteed, on the grounds of the mechanisms envisaged for this purpose by the GDPR (such as adequacy decision adopted by the EU Commission, standard contractual clauses adopted by the EU Commission or by the competent supervisory authority, or Binding Corporate Rules).
Personal data collected by Primeur may be reported to competent authorities, if and when required by law.
9. Processing time – data retention.
Your personal data collected by Primeur will be stored for the time strictly necessary to satisfy the aforementioned purposes, in compliance with current regulations.
10. Compulsory or voluntary nature of submitting data.
The provision of your personal data is necessary and mandatory for the management of your application.
11. Rights of the data subject.
Under GDPR you are entitled to:
- receive from the controller, at any time, information about the existence of your personal data, the origin of the same, the purposes and methods of processing and, if existing, to obtain access to personal data and information referred to in Article 15 of the GDPR;
- request the updating, rectification, integration, deletion, limitation of data processing if one of the conditions provided for in Article 18 of the GDPR occurs, the anonymisation or block of personal data processed in violation of law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed;
- oppose, in whole or in part, for legitimate reasons, to the processing of data, even if appropriate to the purpose of collection;
- oppose, if any, to the processing of data based on automated decision-making process, whereas it includes profiling (not applicable to the current recruitment process);
- whether the processing is based on consent, revoke the consent at any time, without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;
- receive its personal data, previously provided meaningfully and actively, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments;
- file a complaint to the relevant Authority for the protection of personal data.
Whether a request is sent to Primeur asking the erase of data or limitation or opposition to the processing, Primeur may keep some personal data within the limits of the current legislation and for the intended purposes (e.g. to exercise its contractual rights or its right to defence).
In order to exercise the above rights and for any other question concerning the processing of your personal data, you may ask Primeur, via the contact details below, providing the information necessary to fulfil your request:
- by e-mail, at the address: privacy[at]primeur.com
- by mail at the following address: Primeur Italy Srl , Via Imperia 21/A 20142 Milano, Italy
12. Security of data provided.
The security and confidentiality of data processed by Primeur is assured pursuant to art. 32 of the GDPR, by means of the procedures and of the technical and organizational measures taken by Primeur.
Primeur Italy S.r.l.