INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA AND ACQUISITION OF CONSENT
(pursuant to Articles 13 and 7 of EU Regulation 2016/679)
This information notice is provided by SMART EVOLUTION TRADING S.P.A. as Data Controller, in order to describe how the personal data you provide as a candidate are managed, both through your curriculum vitae (CV) and during interactions (e.g. interviews, telephone and email communications, spontaneous applications) with the personnel in charge of recruitment.
The processing of your personal data will be carried out according to the principles of lawfulness, fairness and transparency, protecting your privacy and your rights in compliance with Regulation (EU) 2016/679 (hereinafter "GDPR").
1. Data Controller
The Controller of the processing of your personal data is: SMART EVOLUTION TRADING S.P.A. — Registered office: Via don Eugenio Bruno 1-3, 10029 Villastellone (TO), Italy — VAT no.: 10286490015.
2. Purposes and Legal Basis of Processing
Your personal data will be processed for the following purposes and on the basis of the following lawfulness conditions:
A) Recruitment and Selection Purposes for the Current Position. The processing of your common personal data (personal details, contact details, educational background, professional experience, etc.), contained in your CV and collected during the selection process, is necessary to follow up on your application. Activities include the evaluation of your professional profile against company needs, the organisation and management of interviews and communications relating to the selection process. For this purpose the processing does not require your consent, as it is necessary for the performance of pre-contractual measures taken at your request (Art. 6(1)(b) GDPR).
B) Processing of Special Categories of Data (formerly "sensitive data"). Should you voluntarily provide, in your CV or during the interview, data qualifying as special categories pursuant to Art. 9 GDPR (e.g. health-related data, membership of protected categories under Italian Law 68/99, racial or ethnic origin, political opinions, trade union membership), such data will be processed exclusively if relevant and indispensable for the assessment of your suitability or for the establishment of the employment relationship. The legal basis for such processing is your explicit consent (Art. 9(2)(a) GDPR). Failure to provide consent for the processing of such data may not allow a complete assessment of specific requirements (e.g. hiring incentives).
C) Data Retention for Future Job Opportunities. Subject to your specific and optional consent, your personal data and CV may be retained to be considered for any future job positions, other than the one you applied for, that may open at our Company and that are deemed compatible with your professional profile. The legal basis is your consent (Art. 6(1)(a) GDPR).
3. Categories of Personal Data Processed
Common personal data: first name, surname, date and place of birth, address, contact details (telephone, email), photograph (if included in the CV), data relating to educational background and professional experience, skills and any other information you provided in your CV and during the interview.
Special categories of data: only if voluntarily provided by you and subject to your explicit consent, as specified in point 2.B. The Controller will refrain from proactively collecting data not relevant to the professional assessment.
4. Nature of the Provision of Data
The provision of common personal data for the purpose referred to in point 2.A is necessary to allow the evaluation of your application: without such data it will be impossible to proceed with the selection process. The provision of any special categories of data (point 2.B) and consent to the retention of data for future selections (point 2.C) are optional; any refusal will not affect your participation in the current selection process.
5. Processing Methods and Security Measures
The processing will be carried out using manual, IT and electronic tools, with logic strictly related to the purposes indicated and in such a way as to guarantee security and confidentiality, preventing risks of destruction, loss, modification, unauthorised disclosure or unlawful access. No fully automated decision-making processes, including profiling, that produce legal effects on you are used.
6. Data Retention Period
For purpose 2.A, data will be retained for the entire duration of the selection process and, in the event of non-hiring, will be deleted at the end of it, subject to your consent for the subsequent purpose.
For purpose 2.C, subject to your consent, data will be retained for a maximum period of 24 months from the date of provision; upon expiry they will be deleted or anonymised, subject to a new expression of consent on your part.
7. Data Recipients
Your personal data will not be disseminated. They may be communicated to authorised internal personnel (Human Resources Department, line managers) and to external companies or professionals who carry out outsourcing activities on behalf of the Controller as Data Processors pursuant to Art. 28 GDPR (e.g. recruitment consultancy companies, IT and management providers).
8. Data Transfers Abroad
Data is processed within the European Union. Should it become necessary to use entities located outside the EU, the transfer will be regulated in accordance with Chapter V of the GDPR.
9. Rights of the Data Subject
At any time you may exercise the rights set out in Articles 15 et seq. of the GDPR: access (Art. 15), rectification (Art. 16), erasure / right to be forgotten (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21), withdrawal of consent (Art. 7(3)) for processing based on consent. Withdrawal does not affect the lawfulness of processing based on consent prior to withdrawal.
To exercise such rights you may send a written communication to the Controller's address.
You also have the right to lodge a complaint with the competent Supervisory Authority (for Italy, the Garante per la Protezione dei Dati Personali, www.gpdp.it), should you consider that the processing of your data is contrary to the legislation in force.
