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Candidate Privacy Notice

Pursuant to applicable data protection legislation
 

In accordance with European legislation on the protection of personal data, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, hereinafter also referred to as the “Data Protection Legislation”, Aprile S.p.A., with registered office at Via di Francia 28, 16149 Genoa, Italy, acting as Data Controller, hereby informs candidates of the purposes and methods of processing the personal data collected, the scope of any disclosure, and the nature of the provision of such data.  
 

Purposes of Processing
 

Your personal information will be processed for the following purposes:
 

1. Recruitment and/or the establishment of a working relationship
 

Your personal data, including, in particular, your name, surname, tax identification number, place and date of birth, address, email address, telephone number, information contained in your CV and, where voluntarily provided by you through your CV or where the position for which you apply is reserved for protected categories under specific legal obligations, data concerning your health, will be processed in order to carry out activities connected with the Data Controller’s recruitment process, including:
 

  • searching for candidates for open positions;

  • collecting applications and CVs;

  • reviewing CVs for an initial screening;

  • organising selection interviews;

  • integrating the most suitable candidate into the Data Controller’s organisation;

  • complying with specific obligations and performing specific tasks arising from laws, regulations or collective bargaining agreements, particularly for the establishment of an employment and/or collaboration relationship and for identifying any benefits applicable to contractual relationships with individuals belonging to protected categories.
     

Your data may also be collected from third parties, including, by way of example:
 

  • IT service providers.
     

The data collected, or otherwise obtained by the Data Controller as a result of the recruitment procedure for available positions within its organisation, excluding health-related data voluntarily provided by you, must be considered necessary. Failure to provide such data will make it impossible for the Data Controller to:
 

  • assess your application as part of the recruitment process;

  • manage the recruitment process in all its stages and fulfil the obligations arising from it.  
     

2. Disclosure to third parties and recipients
 

Your data will not be disclosed to third parties or recipients for their own independent purposes unless:
 

  • you provide your authorisation;

  • disclosure is required in order to comply with legal obligations, including for the protection of your rights;

  • disclosure is made to companies belonging to the same group as the Data Controller for administrative purposes, private entities carrying out temporary employment, employment intermediation, recruitment and selection, training or professional outplacement activities, universities and educational institutions, and IT and information service providers.
     

The personal data processed by the Data Controller for this purpose includes, among other information, your name, surname, tax identification number, place and date of birth, address, email address, telephone number, information contained in your CV, technical data such as your IP address and data generated through the use of online forms available on the Data Controller’s websites, and, where voluntarily provided by you through your CV or where the position is reserved for protected categories under specific legal obligations, data concerning your health.  
 

3. Information security purposes
 

The Data Controller also processes, including through its suppliers, third parties and/or recipients, your personal data, including technical data such as logical access data or traffic data collected or obtained through services made available on the website, including the “Careers” section, to the extent strictly necessary and proportionate to ensure the security and resilience of the network and connected servers against unforeseen events or unlawful or malicious acts that could compromise the availability, authenticity, integrity or confidentiality of stored or transmitted personal data.

For these purposes, the Data Controller has established procedures for managing personal data breaches in compliance with its legal obligations.  
 

Categories of Data
 

Candidates are not required to disclose special categories of personal data as defined under Article 9 of the GDPR, including personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or data concerning health, sex life or sexual orientation.

The only exception concerns health-related data voluntarily provided by you through your CV or where the position for which you apply is reserved for protected categories under specific legal obligations.  
 

Legal Basis
 

The processing carried out by the Data Controller for the purposes described above is necessary for the management of the recruitment process.

The processing is based on the performance of pre-contractual activities and compliance with specific obligations arising from laws, regulations or collective bargaining agreements for the establishment of an employment and/or collaboration relationship.  
 

Methods of Processing
 

Data is processed using paper records or electronic procedures by specifically authorised personnel. Such personnel may access your personal data only to the extent and within the limits necessary to carry out the relevant processing activities.

The Data Controller periodically reviews the tools through which your data is processed and the security measures in place, ensuring they are kept up to date. It also verifies, including through authorised personnel, that personal data which is unnecessary, no longer relevant or no longer required for the stated purposes is not collected, processed, archived or retained.

The Data Controller ensures that data is stored in a manner that guarantees its integrity, authenticity and use solely for the purposes for which it is processed, also taking into account the particular nature of the data.

These checks allow the Data Controller to assess whether special-category data is strictly relevant, proportionate and necessary for the recruitment process and for any relationship subsequently established, including where such data has been provided voluntarily.

The Data Controller ensures that any data found to be excessive or irrelevant will not be used, except where retention of the document containing such data is required by law.  
 

International Data Transfers
 

Data is stored in paper, IT and electronic archives located within the European Economic Area, with appropriate security measures in place.

For the purposes described above, personal data may be transferred to subsidiaries of Aprile S.p.A. located outside the European Economic Area, including:
 

  • Brazil;

  • Chile;

  • Kazakhstan;

  • Mexico;

  • Peru;

  • the United Kingdom;

  • Venezuela;

  • China;

  • the Dominican Republic;

  • the United States.
     

For these countries, standard contractual clauses are used to ensure appropriate safeguards, including with regard to the rights of data subjects in connection with transfers outside the European Union.

For transfers to Argentina, the transfer is based on the European Commission’s adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679.  
 

Retention Period
 

Your personal data will be retained for the time necessary to complete the activities concerning you.

In particular, identification data, information contained in your CV and health-related data, including where voluntarily provided, will be retained for the duration of the recruitment process and for a maximum period of 24 months.
 

This is without prejudice to:
 

  • restrictions on processing and other safeguards applicable to special-category data;

  • the deletion of personal data collected through CVs submitted spontaneously or in the absence of an open position;

  • the Data Controller’s interest in retaining data, including data voluntarily provided by you, for the period necessary to assess your application for possible future employment or collaboration opportunities;

  • the establishment of an employment or collaboration relationship.
     

Where litigation arises, the above periods may be extended for the time necessary to pursue the relevant legal purpose.

Once all purposes justifying retention have ceased, the Data Controller will delete or anonymise your personal data.  
 

Rights of the Data Subject
 

By contacting the Data Controller, you may exercise specific rights, including:
 

  • the right to obtain confirmation as to whether or not your personal data is being processed;

  • the right to access your personal data and receive information including the purposes of processing, categories of data, recipients and retention periods;

  • the right to request rectification of your data or restriction of processing;

  • the right to obtain deletion of your personal data where the applicable conditions are met;

  • the right to lodge a complaint with a supervisory authority.
    ​

To enable you to exercise your rights under the Data Protection Legislation, the Data Controller provides the following contact address: privacy@aprilenet.com
 

Data Controller and Processors
 

The Data Controller is Aprile S.p.A., with registered office at Via di Francia 28, 16149 Genoa, Italy. The updated list of Data Processors is available at the company’s registered office.  
 

Nature of the Provision of Data
 

The provision of personal data is voluntary. However, failure to provide the data will make it impossible to assess whether the requirements for employment and/or collaboration are met and, consequently, to establish any relationship with the Data Controller.  

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