(Version 02, Feb 2020)
1. DATA CONTROLLER AND INTERESTED PARTIES
R-Everse SpA (“Company”), whose details are given on the company website at https://www.r-everse.com (“Site”), in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data, as well as to the free circulation of such data and which repeals Directive 95/46/EC (“GDPR”), undertakes to protect the personal data (“Data”) provided by candidates (“Candidates”) (i) through the appropriate registration form on the Site and which is (ii) contained in the CVs that they upload to the Site and manage in order to make use of the personal search and selection service in conjunction with the collaborative recruitment system provided by the Company (“Service”).
2. CONTRACTUAL ARRANGEMENTS
For the purposes of providing the Service, the Company establishes different legal relationships with several subjects (Candidates, Scouts and Clients), with regard to the contractual aspects of the Service. Please refer, therefore, to the relative contractual Terms and Conditions published on the Site.
3. PARTIES AUTHORISED TO PROCESS THE DATA
The Data of Candidates are processed by appropriately trained authorised personnel, among whom scouts (“Scouts”) – with sole regard to Data included in CVs, name and surname – in charge of evaluating and selecting CVs to support the Company in delivering the Service. Scouts are trained in data processing and authorised to perform it.
4. EXTERNAL RESPONSIBLE PARTIES/ iNDEPENDENT DATA CONTROLLERS AND CO-DATA CONTROLLERS/ RECIPIENTS OF THE PROCESSING:
Depending on the specific circumstances, Data may (i) be shared with the corporate group subsidiaries for internal administrative and/or optimisation purposes, to deliver the Service, taking account of the work location (for instance, by transmitting the Data to the German subsidiary, if the work position to be searched is in Germany) in the legitimate interest of the Company or of third parties (Candidates and/or Clients), or (ii) be transmitted upon appointment by the Company (and upon specific agreement) to consultants, bodies, enterprises and companies supplying services entailing Data processing.
(a) suppliers of software, applications (including CRM systems) and hardware as well as related management and support/maintenance services;
(b) suppliers of connectivity and email systems as well as related management and support/maintenance services;
(c) suppliers of external storage systems, including cloud;
(d) legal and tax advisers as well as labour consultants and accountants.
Depending on the particular circumstances or the activities performed, these parties may work as independent data controllers or as co-data controllers, should shared purposes and processing methods be established. .
The Company can provide specific information about the recipients of the Data at the request of the data subject.
The Candidate Data contained in the CVs may also be communicated to the clients of the Company (“Clients”) who purchase the Service, but this, in any case, must only be done with the consent of the candidates.
5. PERSONAL DATA PROCESSED:
The Data of Candidates consists of common data, which does not therefore fall within the definition of sensitive and/or judicial data with regard to the national laws on the protection of data, is not included in the categories of personal data nor of data relating to criminal convictions and offences of the GDPR and does it fall within the definition of data related to health of the latter (collectively defined as “Particular Data”), such as, for example, first names and surname, date of birth, physical address and telephone number (mobile number), email address and, in general, the information contained in the CVs concerning the professional skills necessary for the provision of the Service.
An exception is made for the Particular Data that may be voluntarily inserted into the CVs by the Candidates themselves; the Company does not process any Particular Data for the purposes of providing the Service. In any case, Candidates are advised not to include any Particular Data in CVs (unless due to specific reasons related to the position sought or to other indispensable elements) and also to obscure the Particular Data contained in the payslips which may be requested by the Company during the selection process.
6. PURPOSES OF THE DATA PROCESSING AND LEGAL BASIS OF THE PROCESSING:
The Company carries out Data processing for the purposes and related legal basis outlined below:
(a) registering Candidates on the Site, processing is required to execute pre-contractual measures adopted by the Company on the request of the Candidates when they upload or send in their CVs;
(b) the uploading, management and cancellation of the relative CVs by the Candidates, processing is required for provision of the Service;
(c) the examination and selection, by the authorised personnel of the Company, Scouts and Clients (to a limited extent and, in any case, at an advanced stage in the selection process) of CVs of interest, based on employment offers published on the Site, work openings and/or specific selection requests (it being understood that the Company does not carry out any further processing of the Data contained in the CVs, the updating of which is the exclusive responsibility of the Candidate), processing is required for provision of the Service;
(d) seeking out (for instance via social-network channels) and analysing the Data of potential Candidates for the work positions required by the Clients and by the potential Candidates themselves, in order to assess the Candidates’ skills and suitability for any openings and to contact them to see whether they are interested in the position as well as to launch or continue the selection process, processing rests on the legitimate interest of the Company or third parties (Clients) for the purposes of providing the Service.
7. DATA RETENTION TIME
The Candidates may at any time independently modify their CV and obtain its deletion by sending a request to the Company (firstname.lastname@example.org).
Your consent to the receipt of messages with alerts can be revoked at any time.
The Scouts process the Data of Candidates for the length of time necessary for the provision of the Service, under the conditions and within the limits provided for in the contractual collaboration agreement. Once the search and selection process undertaken by the personnel has ended, therefore, the Scouts are no longer authorised to process the Data of the Candidates and will not be able to access it.
8. TRANSFER OF DATA ABROAD
For internal administrative and/or optimisation purposes of the activities required to provide the Service, the Company may transfer Data to corporate group subsidiaries based in the European Union or in the European Economic Area. Suppliers of IT services located outside the European Union and of whose services the Company avails itself have adopted the Privacy Shield framework. Therefore, any data transferral takes place in compliance with the provisions of articles 44 et seq. of the GDPR. In any case, the Company must make sure it uses suppliers that observe the guarantees envisaged under articles 44 et seq. of the GDPR on transferral of data abroad.
Candidates can contact the Company or external responsible parties in order to exercise the rights provided for by applicable national data protection laws and by the GDPR (Article 15 and following), and, in particular, in order to access their personal data, request rectification and updating or deletion, or in order to request restrictions or portability, using the following procedure: A letter must be sent to the Company at the address indicated above.
10. RIGHT TO OPPOSITION
Along the same procedures described above, Candidates may entirely or partly object to their personal data being processed where the relevant legal basis is constituted by legitimate interests, pursuant to and for the purposes of the provisions of Article 21 of the GDPR.
Any Candidate who believes that the processing of the Data is in violation of the GDPR, may, in accordance with the provisions of Article 77 of the GDPR, lodge a complaint with a supervisory authority for the place in which the Candidate habitually resides or works or with a supervisory authority for the place in which the alleged data breach took place.
12. UPDATES AND REVISIONS
The Company reserves the right to modify and/or update the Informational Notice, taking into account any subsequent additions and/or changes to national legislation and/or to that of the European Union regarding the protection of personal data, or as a consequence of any further purposes of the processing of data. For this reason, the Informational Notice is published with a progressive identification number and specifies the month in which it was published, starting from the May 2018 version bearing the number “00”. The new version of the Informational Notice will replace the previous ones and will be valid, effective and applicable from the date of its publication on the Site.