INFORMATION ON THE PROCESSING OF PERSONAL DATA – ART. 13 AND 14 OF REGULATION (EU) 2016/679 (“GDPR”)
Gi Group Holding S.r.l. (hereinafter also the “Company“) wishes to provide some information about the purposes, methods and scope of processing of personal data provided by adult candidates through the application through the website of the Company (hereinafter “Site“), websites of any third party companies and social networks, or by e-mail, or during an interview at one of the agencies, or during the conduct of assessment and psycho-aptitude, behavioural, technical or other tests , and/or pre-onboarding activities aimed at your insertion in the Company, including through the platforms of third party companies (e.g. the platforms “Enboarder”, “Eggup” and “Thomas International”).
1. PURPOSE OF PROCESSING AND LEGAL BASIS
1.1. Your data is collected in the following ways:
– through the Site;
– by e-mail;
– at our agencies;
– via third-party websites or social networks;
– through special platforms and websites used for pre-onboarding or testing and assessment (such as, for example, “Enboarder”, “Eggup” and “Thomas International”).
1.2. Your data are processed both in case of application in response to a specific advertisement and in case of voluntary application for the purpose of direct employment with the Company.
In case of application in response to a specific advertisement, your data may also be processed for future research and selection of personnel in line with your profile, if you do not object to such processing by sending a written notice to globaltalent@gigroup.com. If you do not object to such processing, your data will be processed exclusively in the context of the specific selection for which you have applied.
1.3. Your data may be processed in connection with assessment and psycho-aptitude, behavioural, technical or other tests and for the subsequent receipt, by e-mail, of assessment results and suggestions for personal development.
1.4. If you continue the selection process, your data will be processed during the pre-onboarding activity aimed at your insertion in the Company.
1.5. The legal basis applicable to the processing of your personal data for the purposes referred to in 1.2 and 1.4 is the performance of pre-contractual measures taken at your request pursuant to Article 6(1)(b) of the GDPR.
1.6. The legal basis applicable to the processing of your personal data for the purposes referred to in 1.3 is your consent pursuant to Article 6(1)(a) of the GDPR.
1.7. Your data may also be processed for the purpose of establishing, exercising or defending a legal claim against us.
1.8. The legal basis applicable to the processing of your personal data for the purpose referred to in 1.7 is our legitimate interest pursuant to Article 6(1)(f) of the GDPR.
2. CATEGORIES OF DATA PROCESSED, SOURCE OF DATA AND PROCESSING OF SPECIAL CATEGORIES OF DATA
2.1. The Company will, by way of example but not limited to, collect data that you have entered in your CV and/or provided during your interview at one of its agencies or central offices.
2.2. The Company shall collect the aforementioned data from you and/or from websites managed by third parties or social networks through which the Company publishes advertisements on its own behalf or through which it can consult candidate profiles.
2.3. The Company may also collect your data (e.g., name, surname, e-mail address) when you access the platforms used for the purposes described in 1.3 and 1.4 (i.e., assessment, pre-onboarding).
2.4. Please do not indicate in your curriculum vitae special categories of data (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data uniquely identifying a natural person, data concerning health or sex life or sexual orientation of the person). If special categories of personal data concerning you are processed for the purposes described in 1.8, the applicable legal basis is the establishment, exercise or defence of legal claims under Article 9(2)(f) of the GDPR.
3. DATA RETENTION
3.1. In the case of data processing for the purposes of search and selection referred to in paragraph 1.2 in connection with a voluntary application, the data are entered into the company database and stored for 30 months after their entry.
3.2. In the case of data processing for the purposes of research and selection referred to in paragraph 1.2 in response to a specific advertisement, if you object to the storage of your data for future selections, the data is stored for the duration of the selection and, if the selection is unsuccessful, until it is closed.
3.3. In the case of data processing for the purposes of assessment and psycho-aptitude, behavioural, technical or other tests referred to in paragraph 1.3, the data are entered into the platforms used and stored for 30 months after they are entered.
3.4. In the case of data processing for the purposes of pre-boarding activities referred to in paragraph 1.4, the data are entered into the platforms used and stored until the end of that phase and no later than the end of the trial period.
3.5. In the event of data processing for the purposes of ascertaining, exercising or defending a right in a court of law as referred to in paragraph 1.7, the data shall be included in a historical archive and kept for the entire duration of the litigation, until the time limit for appeals has expired.
3.6. After the above-mentioned retention periods have expired, the data are destroyed or made anonymous.
4. NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL
4.1. The provision of the data marked with an asterisk in the data collection form on the website is necessary to allow the Company to pursue the research and selection purposes referred to in point 1.2 above; therefore, refusal to provide the requested data will prevent the Company from carrying out its research and selection activities and will not allow your application to be taken into consideration.
4.2. The provision of data for the purposes referred to in point 1.3 above (assessment) is optional. Refusal to provide data or failure to give consent will have no consequence on your application and will not prevent the Company from carrying out its search and selection activities.
4.3. The provision of data for the purposes referred to in point 1.4 above (pre-onboarding) is necessary to allow the Company to complete the pre-contractual activities of employment in the Company; therefore, any refusal to provide the requested data will prevent the Company from carrying out the pre-contractual activities and will result in the interruption of the selection process.
5. DATA PROCESSING METHODS
5.1. Data processing is based on the principles of correctness, lawfulness and transparency and data minimization (privacy by design); may be carried out both manually and through automated methods, including through the use of platforms and websites of third party companies, capable of storing, processing and transmitting the data, and will be carried out using technical and organisational measures that are appropriate, insofar as reasonably necessary and in accordance with the state of the art, to guarantee, among other things, the security confidentiality, integrity, availability and resilience of the systems and services, avoiding the risk of loss, destruction, unauthorised access or disclosure or, in any case, unlawful use, as well as through reasonable measures to delete or rectify in a timely manner data that are inaccurate in relation to the purposes for which they are processed.
6. RECIPIENTS OF DATA
6.1. Your data may only be processed by employees of the company departments authorised to process them, as they are responsible for pursuing the above-mentioned purposes. These employees have received adequate operating instructions in this regard.
6.2. Your personal data may be communicated by the Company, for the pursuit of the purposes set out in point 1 above, to the following entities:
– Public bodies in the framework of the implementation of active labour policy or measures.
– Group companies in Italy or abroad.
6.3. Your personal data may also be processed by persons, expressly appointed as data processors, who provide the Company:
– management and maintenance services of the Site;
– archiving services;
– communication mailing services;
– pre-boarding services;
– assessment and testing services of various kinds.
6.4 An up-to-date list of data recipients is available at our registered office or by sending an e-mail to it.privacy@gigroupholding.com.
6.5 Personal data provided by candidates will not be disseminated.
7. RIGHTS OF THE DATA SUBJECT
7.1. As a data subject, you are entitled to the rights set out in Articles 15 to 22 of the GDPR, where applicable.
7.2. In particular, data subjects may ask the Data Controller for access to their data, their deletion, the rectification of inaccurate data, the integration of incomplete data, as well as the restriction of processing in the cases provided for by Article 18 of the GDPR1.
7.3. Data subjects have the right to object at any time, in whole or in part, to the processing of data necessary for the legitimate interests of the Data Controller.
7.4. In addition, if the conditions for exercising the right to portability set out in Article 20 of the GDPR2 are met, data subjects have the right to receive the data provided to the Data Controller in a structured, commonly used and machine-readable format and, if technically feasible, to transmit it to another data controller without hindrance.
7.5. These rights may be exercised by writing by post to the address below or by e-mail to the following e-mail address: it.privacy@gigroupholding.com. It is understood that, where the request is made by electronic means, the information will be provided in a commonly used electronic format.
7.6. Data subjects have the right to lodge a complaint with the competent supervisory authority (in particular in the Member State where they usually reside or work or in the State where the alleged infringement has occurred).
8. WITHDRAWAL OF CONSENT
8.1. You have the right to withdraw your consent at any time by sending an e-mail to it.privacy@gigroupholding.com.
8.2. Withdrawal of consent shall not affect the lawfulness of processing based on consent given before withdrawal.
9. CONTACT DETAILS OF THE DATA CONTROLLER
9.1 The data controller is Gi Group Holding S.r.l., with registered office in Milan, Piazza IV Novembre 5, in the person of its Legal Representative.
10. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (so-called DPO)
10.1 The Data Protection Officer [DPO] can be contacted at the following address Piazza IV Novembre n. 5, 20124 Milano, for the attention of the Data Protection Officer, e-mail dpo@gigroup.com
1 That is, if:
a) the data subject contests the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of such personal data;
b) the processing is unlawful and the data subject objects to the deletion of the personal data and requests instead that their use be restricted;
c) although the data controller no longer needs them for processing purposes, the personal data are required by the data subject for the establishment, exercise or defence of legal claims;
d) the data subject has objected to the processing in accordance with Article 21(1), pending verification as to whether the legitimate reasons of the controller prevail over those of the data subject.
2 That is, whether the processing is based on consent within the meaning of Article 6.1(a) or Article 9.2(a) or on contract within the meaning of Article 6.1(b) of the GDPR and is carried out by automated means.
