(Version 01, February 2019)
1. Owner and interested parties
R-Everse S.r.l. (“Company”), whose data is displayed on company websites at the following URLs https://www.r-everse.com and https://reallyzation.com/ (“Site(s)”), in accordance with (EU) Regulation 2016/679 pertaining to the protection of processing individuals’ personal data, the free movement of such data and which rescinds Directive 95/46 /CE (“GDPR”), as well as the Italian national legislation on personal data protection (“National Data Protection Law”), is committed to protecting personal data (“Data”) provided by individuals wishing to work with the Company by carrying out personnel selection and recruitment work (“Service”) and becoming scouts (“Scouts”) for the Company (i.e. recruiters sifting through candidates’ (“Candidates”) CVs).
Those wishing to become Scouts enter their Data onto a special registration form present on the Site and upload their CVs so that the Company can examine them and decide whether they meet the set requirements and have the necessary skills to fill the role of Scout. Conferral takes place by drawing up a special cooperation agreement with the Company.
2. Reference to contractual discipline Please refer to the relative mandate for the contractual terms between the Company and the Scout.
3. Parties authorised to process the data The Data of those wishing to be Scouts and that of the Scouts themselves is processed by Company staff members who are authorised to conduct the processing and properly trained to do so.
4. External managers / independent owners and co-owners – Processing recipients Upon appointment by the Company (and upon specific agreement), consultants, bodies, enterprises and companies supply services whose provision entails processing Candidates’ Data. Specifically, this relates to:
(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 on the 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 owners or as co-owners, should shared purposes and processing methods be established.
The Company can provide specific information about the recipients at the request of the interested party.
In addition to the aforementioned external managers, the Candidates and the Company’s clients (“Clients”) must be understood to be included amongst the various recipients to whom the Scouts’ Data is disclosed.
5. Processed personal data The Data of those wishing to be Scouts and that of the Scouts themselves 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 nor 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 qualifications and professional skills required by the Company to examine and assess the professional profiles of those wishing to become Scouts.
Unless any Particular Data is voluntarily inserted into the CVs by those wishing to be Scouts themselves, the Company does not process any of their Particular Data.
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) gathering and assessing the CVs of those wishing to be Scouts with a view to bestowing a mandate upon them processing is required to execute pre-contractual measures adopted by the Company on the request of the Scouts,
(b) establishing and engaging in contractual relations with the Scouts processing is required to execute pre-contractual measures and contractual obligations as well as to fulfil legal obligations.
7. Data retention time The Data of those wishing to be Scouts is kept throughout the contractual relationship and for 11 years after relations with the Scout have come to an end. Should the appraisal and assessment procedure of the CVs of those wishing to be Scouts have a negative outcome, the Data will be deleted immediately, unless the profile of the individual wishing to become a Scout is considered to be of potential interest for any future mandates.
8. Transferring data abroad 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.
9. Rights The Scouts 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 object 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.
11. Complaints Any Scout who believes that Data processing is in violation of the GDPR may file a complaint in accordance with the provisions of Article 77 of the GDPR with a supervisory authority where the Scout normally lives or works, or to a supervisory authority where the alleged data breach occurred.
12. Updates and revisions
The Company reserves the right to modify and/or update this Notice, including any subsequent additions and/or amendments to national and/or European Union regulations regarding personal data protection or due to possible further purposes of data processing. For this reason, this Notice is published with a progressive identification number and the month of publication, starting with the May 2018 version which displays the number “00”. Subsequent versions of the Notice will replace previous ones and will be valid, effective and applied from the date they are published on the Website.