POLICY

 

DISCLOSURE FOR THE DATA SUBJECT Pursuant to arts. 13 and 14 of European Regulation no. 2016/679 ("GDPR")

Dear Sir/Madam,s
as we have received your curriculum vitae (the "Curriculum"), which contains personal data relating to you that our Company will process, we wish to provide you with the necessary information regarding the processing of your personal data pursuant to arts. 13 and 14 of the GDPR.

1. Identity and contact details of the data controller

The data controller is O.M.E. Metallurgica Erbese S.r.l. (tax code and VAT number 00200910131), in the person of the legal representative pro tempore, with registered office in Milan, Corso Venezia, n. 36 (hereinafter the "Company" or the "Data Controller"); tel. +39 031641606 – e-mail: privacy@ome.it.

 

For any comments or questions on this Privacy Policy and to speak with the person authorised to manage requests relating to data processing, you can write to the following e-mail address privacy@ome.it or call the following telephone number: +39 031641606.

 

The list of data processors and of any authorised persons is kept at the headquarters of the Data Controller and made available at the request of the data subject.

2. Type of personal data processed

The data that will be processed will be your personal identification data (first name and surname), contact data (address of residence or domicile; e-mail address; telephone number), as well as data relating to qualifications, work experience and skills and in any case all the data as indicated by you in your Curriculum (the "Common Data").

If indicated by you in the Curriculum, we will also process your personal data belonging to the category of particular data referred to in art. 9 of the GDPR (the "Particular Data"), such as, by way of example and not limited to, data revealing racial and/or ethnic origin, data relating to health status, data relating to private life and/or sexual orientation, political beliefs or trade union membership.

The Common Data and the Particular Data (collectively the "Personal Data") will be processed for the purposes specified below.

 

3. Source of Personal Data

 

If not provided directly by you, the Personal Data have been collected by third parties appointed by us to carry out candidate selection activities such as, for example, employment agencies, offices for targeted employment or providers of work services in general to which you have provided your Personal Data and your CV to allow the selection of your professional profile for the identification of a job. These subjects in turn have sent your Personal Data to the Data Controller in order to allow the evaluation of your application in view of the possible establishment of an employment relationship.

 

4. Purpose of the processing for which the Personal Data are intended

The Personal Data provided will be processed for the following specific purposes:

• to evaluate your application with a view to the possible establishment of an employment relationship between you and the Company;
• to manage all the procedures and phases related to the selection of candidates (e.g. conducting of an interview, comparing the professional profiles and skills of candidates);
• to verify the correctness and truthfulness of the Personal Data provided by you;
• if your application is considered adequate, your Personal Data may be processed for completion of the recruitment procedure or alternatively stored in the company database for future recruitment.

5. Legal basis of the processing

The legal basis that legitimises the processing of your Common Data, pursuant to the provisions of art. 6, paragraph 1, letter b) of the GDPR and art. 111-bis of Italian Legislative Decree 196/2003 is the need to implement a pre-contractual measure on the basis of your application, and, precisely, to carry out evaluations on the possibility of establishing an employment relationship between you and the Company, and, subsequently, in the event of a positive evaluation, to perform the activities preceding your possible hiring. In the event that you also communicate Personal Data, the legal basis for the processing will be your consent pursuant to art. 6, paragraph 1, letter a) of the GDPR. If you do not provide your express consent for the processing of the Personal Data included in the Curriculum received, the Personal Data will not be processed.

6. Personal Data Recipients

Your Personal Data will not be disclosed. Instead, they may be communicated, closely linked to the afore-mentioned purposes, to the following subjects or categories of subjects:

• to employees or collaborators of the Company assigned to carrying out functions that require the processing of your Personal Data or assigned to managing the phases of selection of candidates in view of the possible hiring of employees of the Company;
• to any suppliers of the Company who deal with the management and operation of the IT system and of the portal on which the Company grants candidates the opportunity to submit the Curriculum;
• to investigating companies to verify the truthfulness and correctness of the Personal Data provided by you.

7. Transfer of Personal Data to third countries or to international organisations

Your Personal Data will not be transferred outside the territory of the European Union. Personal Data will be stored on company servers located in the territory of the European Union.

8. Retention period of Personal Data

The Company will retain your Personal Data for the time reasonably necessary to evaluate your application and for completion of the personnel selection process . In any case, your Personal Data will be kept for a maximum period of 12 months from provision in order to contact you in the event that a job position compatible with your professional profile becomes available. After the maximum period of retention of Personal Data as indicated above, we will proceed to delete your Personal Data from any paper-based and/or computer support.

9. Nature of the provision of Personal Data

The provision of Common Data is abstractly optional, however it is in fact essential for the fulfilment of the purposes expressed in this information. Failure to communicate one or more pieces of Common Data may result in the objective impossibility of starting the evaluation of your application or the continuation of such evaluation, and, consequently, of being able to potentially conclude a possible employment contract.

The provision of Particular Data is not required by the Company and is therefore completely optional and the failure to provide such Particular Data will not normally have any influence on the selection of personnel, except in cases where the Particular Data are relevant for the assessment of the suitability or otherwise of the candidate for a particular job.

10. Methods of processing Personal Data

The processing of Personal Data will be carried out using paper-based, computer or electronic tools and supports in compliance with the provisions aimed at guaranteeing security and confidentiality, as well as, among other aspects, the accuracy, updating and relevance of the Personal Data with respect to the purposes declared.

 

The processing of Personal Data carried out by means of the operations indicated in article 4, no.  2, of the GDPR, will consist of the collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication, limitation, deletion or destruction.

11. Rights of the data subject

Your right to request exercising of the rights provided for in Chapter III of the GDPR remains unaffected, and in particular:

• Right of access - Obtain confirmation whether or not Personal Data concerning you is being processed and, in this case, receive information relating, in particular, to: purposes of processing, categories of Personal Data processed and retention period, recipients to whom these may be communicated (article 15, GDPR);
• Right of correction - Obtain, without undue delay, the correction of inaccurate Personal Data concerning you and the integration of incomplete Personal Data (article 16, GDPR);
• Right to deletion - Obtain, without undue delay, the deletion of Personal Data concerning you, in the cases provided for by the GDPR (article 17, GDPR), even if, for example, you do not wish to be taken into account for future work opportunities;
• Right of limitation - Obtain from our Company the limitation of processing, in the cases provided for by the GDPR (article 18, GDPR);
• Right to portability - Receive in a structured format, commonly used and readable by an automatic device, the Personal Data concerning you provided to our Company, as well as obtain a situation whereby the same are transmitted to another data controller without hindrance, in the cases provided for by the GDPR (article 20, GDPR).

You may exercise these rights by simply sending a request to our Company to that effect:

• by e-mail to the following e-mail address: privacy@ome.it.
• by ordinary mail to the following address: Via Milano, 15 – 22036 Erba (CO) or to the additional addresses indicated in the contact details.

It should be noted that any corrections or deletions or limitations of the processing carried out at your request, unless this proves impossible or involves a disproportionate effort, will be communicated by the Company to each of the recipients to whom the Personal Data have been transmitted. The Company will notify you of these recipients if you request it.

 

If you believe that the processing that concerns you breaches the GDPR or Italian Legislative Decree 196/2003, you may lodge an appeal or complaint with the supervisory authority for the protection of personal data in the EU member State in which you habitually reside or work or in that of breach of the GDPR (article 77 of the GDPR). In particular, with reference to Italy, the appeal may be submitted to the Guarantor for the Protection of Personal Data, Piazza Venezia 11 - 00186 Rome; E-mail: garante@gpdp.it.

12. Right of objection and revocation

In accordance with the provisions of Chapter III of the GDPR, we also inform you that, by applying the conditions set out in article 21 of the GDPR, you will also have the right to object to the processing of Personal Data concerning you, unless there are legitimate reasons for the Company to continue processing. You may exercise this right by simply sending a request to that effect to the same addresses indicated above for the exercise of the other rights of the data subject.

 

If you have provided your consent for the processing of Personal Data for the purposes for which it is requested, you will in any case be free to revoke it at any time by sending a communication to this effect without formalities to the e-mail address privacy@ome.it or to the following address Via Milano, 15 – 22036 Erba (CO) or to the further addresses of the contact data.  Upon receipt of such a request, the Personal Data will no longer be processed for the purposes for which consent is requested.

13. Automated processes and profiling

The Company will not perform any profiling activities with your Personal Data nor will it make decisions based on automated processes.

14. Further information

Further information regarding the processing and communication of Personal Data provided directly or otherwise acquired may be requested from the Human Resources Office. This information does not exclude a situation whereby other information is also provided verbally to the data subjects at the time of collection of Personal Data and upon the first contact after the provision of Personal Data.

 

Personal Data are processed lawfully and correctly, adopting appropriate security measures to prevent unauthorised access, disclosure, modification or the unauthorised destruction of Personal Data. Specifically, the Data Controller has implemented suitable measures to protect Personal Data from accidental loss, from unlawful access, use, modification and from unauthorised disclosure.

 

In the unlikely event that the Data Controller deems that the security of the Personal Data collected in its possession or under its control has been or may have been compromised, the Data Controller will inform you of the incident in the manner prescribed by the law in force, using the methods prescribed by it.

 

07/10/2022

O.M.E. Metallurgica Erbese S.r.l.