pursuant to Articles 13 and 14 of the EU Regulation No. 679/2016
AG Digital Media S.p.A. Informs you of the following regarding the processing of personal data carried out as part of the current selection process, pursuant to current data protection legislation and, in particular, Articles 13 and 14 of EU Regulation No. 2016/679 (“GDPR”).
Who decides how and why your Data is processed?
The data controller of your personal data is AG Digital Media S.p.A., with a registered office in Corso Italia, 22, 20122, Milan, Italy, tax code and VAT 09568760962, e-mail firstname.lastname@example.org
(hereinafter the "Company" or ''Freeda'' or ''Data Controller’').
Data Protection Officer (DPO)
The Controller has appointed a Data Protection Officer (DPO) who can be contacted by writing to email@example.com
What is the source of your Data?
Your data will be collected directly from you.
In some circumstances your data will be collected from third parties (e.g., job recruitment portals where you have submitted your application, LinkedIn, other recruitment companies, etc.).
What data do we process?
Freeda processes personal data about you, including:
• identification and contact data (e.g., first name, surname, date of birth, social security number, address, telephone contact details, e-mail, residence, domicile
• data relating to previous work experience (e.g., educational qualification, positions held, date of employment, company role, remuneration and any benefits, periodic evaluations, professional qualifications and professional information);
• tax and income data (e.g., previous salary).
The Data collected refer to the information generally contained in the Curriculum Vitae.
In addition, information may also be collected from a reference check (if carried out) such as membership of any institution, academic background, work history and other information relevant to determining your suitability as a candidate.
The Company reserves the right to carry out appropriate checks on the truthfulness of the Data, about qualifications obtained, previous work experience, assumption of professional duties or institutional positions, including by contacting the persons you may have indicated as references, as well as your previous employers.
The Data that will be acquired will not concern personal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information relating to health or sexual life or sexual orientation (hereinafter "Special Categories of Data"), as well as facts not relevant to the assessment of your professional aptitude.
Why do we process your Data and based on what conditions of lawfulness are we entitled to do so?
Your Data will be processed for the following purposes and based on the following conditions of lawfulness:
Purposes related to personnel research and selection requirements in relation to the possible initiation of a work relationship or collaboration with the Company. Such processing is necessary for the execution of pre-contractual measures taken at your request.
- The conferment of your Data is necessary in order to evaluate your candidature and, without it, it will not be possible to proceed with the search and selection process and establish a possible working relationship.
Purposes connected with obligations provided for by laws or regulations to which the Company is subject (e.g., in the field of labour law). Such processing is necessary to fulfil a legal obligation to which the Company is subject.
- The provision of your Data is necessary in order to comply with the legal obligations to which the Company is subject and without it, it will not be possible for the Company to fulfil its legal obligations.
Purposes related to the management of any litigation arising in connection with the relationship. Such processing is necessary for the pursuit of the legitimate interest of the Company in the protection of its rights.
In this case, a new and specific conferment is not required, since the Company shall pursue this further purpose, if necessary, by processing the Data collected for the above purposes, deemed compatible with the present one (also by reason of the context in which the Data have been collected, of the relationship between you and the Company, of the nature of the Data themselves and of the adequate guarantees for their processing, as well as of the link between the other purposes and this further purpose).
How do we process your data and how long do we keep your data?
The processing of your Data will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimisation, accuracy, integrity and confidentiality, in accordance with the GDPR and current national data protection legislation. Your Data will be processed with the support of computerised and paper means and are protected by appropriate security measures to ensure their confidentiality, integrity and availability.
We retain your Data only for as long as necessary to achieve the purposes for which it was collected or for any other legitimate related purposes. Therefore, if Data is processed for two different purposes, we will keep that Data until the purpose with the longer period ends. In any case, we will no longer process Data for that purpose whose retention period has expired. Data that is no longer needed, or for which there is no longer a legal basis for its retention, will be irreversibly anonymized (and thus may be retained) or deleted.
In particular, we will retain your Data for a period not exceeding 2 years after its collection by the Company. Once this retention period has expired, your Data will be deleted.
Who do we share your Data with?
Your Data will be processed by authorised and trained personnel, who will operate in accordance with the principles of fairness, loyalty and transparency and will protect the confidentiality of your Data by means of technical and organisational security measures suitable to guarantee an adequate level of protection.
Furthermore, the Data may also be communicated to external suppliers (e.g., consultants, service companies), appointed as data processors if necessary.
You can request a list of the data processors and further information on the recipients of your Data by writing to firstname.lastname@example.org
Will your data be transferred outside the EU?
The Data Controller stores personal data on servers located within the European Union but may transfer your data outside the EU only if the third country has been deemed adequate by the European Commission (e.g. UK), or, in the absence of an adequacy decision, if Freeda has signed with the non-EU data importer the Standard Contractual Clauses approved by the European Commission, possibly supplemented by additional technical/organisational/legal measures necessary to ensure that the level of protection of personal data is equivalent to that of the European Union.
You may contact the Data Controller at any time by sending an e-mail to email@example.com asking which entities your personal data is being transferred to and to receive a copy of the safeguards adopted for the transfer.
What are your rights in relation to your Data?
You may exercise, in relation to the processing of your Data, the rights provided by the GDPR, (art. 15-21 GDPR) and in particular:
- receive confirmation of the existence of your Personal Data and access to its content (right of access);
- update, amend and/or correct your Data (right of rectification);
- request the deletion of your Data (right to be forgotten);
- request the restriction of the processing of your Data (right to restriction of processing);
- revoke the consent given, in cases where the processing is carried out based on the same, without prejudice to the lawfulness of the processing based on the consent given before revocation;
- in the cases provided for, receive a copy of the data in electronic format concerning you rendered in the context of the contract and request that such data be transmitted to another data controller (right to data portability).
In addition, you have the right to object in whole or in part to the processing of your data (right to object), provided that the requirements of the data protection legislation are met.
Should you exercise any of the aforementioned rights, it will be the responsibility of the Company to verify that you are entitled to exercise them, and you will be acknowledged, as a rule, within one month.
To exercise these rights and obtain further information on the processing of your Data, you may send an e-mail to firstname.lastname@example.org
What other rights can you exercise in relation to your Data?
Should you consider that the processing of Data relating to you is in breach of the applicable data protection legislation, you have the right to lodge a complaint with the Guarantor for the protection of personal data, using the references available on the website www.garanteprivacy.it
Last update: May 2022
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