Promos SRL, as Data Controller, hereby provides the following information, in accordance with General Data Protection Regulation (EU) 2016/679 (GDPR), regarding the use of your personal data for the above purposes, as described hereafter and as they concern you.
The Data Controller, pursuant to articles 4 and 24 of EU Regulation no. 2016/679, is: PROMOS S.R.L., Via San Zeno, 173 – 25124 Brescia (BS), Italy, e-mail: privacy@promosgroup.it , Tel: +39 030 2422862.
The Data Security Manager (RPD and/or DPO), pursuant to art. 37 of the Regulation, can be reached at the following e-mail address: dpo@promosgroup.it
The personal identification data and contacts for the applicant, i.e. first and last name, address, phone number, e-mail address and other data contained in the resumé, which the applicant provides either spontaneously or at the data controller's request, also through job recruitment agencies.
Data relative to specific technical skills, and motivational attitudes might be subject to processing with respect to the professional qualifications sought by the company, also by means of psychological and aptitude tests and interviews. For these purposes, judicial and other sensitive categories of data will not be processed.
To benefit from the protection provided by the law for certain categories of applicants, and to fulfill the specific obligations set forth in EU regulations, laws, and collective labor contracts, however, particular categories of personal data may be processed.
PROMOS prohibits indicating in the resumé data pertaining to particular categories if not pertinent or excessive with respect to the aforementioned purposes. These data, in any case, will not be processed.
The personal data of the applicant are processed exclusively for purposes of selecting and recruiting personnel functional to the possible creation of a working relationship, collaboration or internship.
The juridical basis for processing personal data is the need to apply the precontractual measures required by the applicant and to pursue the legitimate interest of PROMOS in selecting the personnel for its business needs and goals. Applicants must provide their personal data in order to participate in the recruitment procedure.
With respect to any special categories of data (such as health data), if, for example, the applicant belongs to one of the categories protected by law, processing will be limited to those operations essential for the safeguards established by the law and to fulfill the specific obligations of the Data Controller specified in the EU regulations, laws and collected labor contracts. The legal basis for processing the data of these categories derives from the need to fulfill specific obligations and apply the rights of the data controller as well as those of the data subject in matters regarding work and social protection.
If necessary, the data may be used for administrative, accounting and fiscal purposes as well, to fulfill the legal obligations to which the data controller is subject or to exercise the company’s rights in or out of court.
Data are provided optionally and the decision to provide them or not rests with the applicant. Failure or untruthfulness in providing them, however, will make it impossible to process the application and establish a working relationship.
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected, and to manage the process of selection of the applicants.
Specific safety measures are taken to prevent the loss of data or any illicit or improper use of them, as well as any unauthorized access. All data collected are saved and kept secure, limiting access exclusively to authorized personnel.
Resumés and any data relative to evaluation of the applicants are kept for 12 months from the date of their receipt and/or use, for purposes of personnel recruitment. After that time they are deleted.
Authorized employees of PROMOS have access to the personal data of job applicants, to process them under the direct supervision of the company and its managers and sub-managers, also consultants outside the company, who provide specific services to the company and with whom PROMOS has stipulated specific contracts, pursuant to art. 28 GDPR. Among these, service companies and professionals, consulting companies or other parties who may participate in various stages of personnel recruitment.
The complete list of managers and sub-managers assigned to process data can be requested by writing to the e-mail address privacy@promosgroup.it.
All the parties listed above are required to use the information received only for the purposes of processing as indicated above, and to keep the data confidential, intact and inaccessible to unauthorized third parties.
Data subject to processing are not sent outside the European Union. If that should occur, the data controller will take appropriate measures, as required by the GDPR, to protect the personal data of data subjects.
The Data Controller does not use automated decisional processes such as profiling, as described in art. 22, paragraphs 1 and 4, of the European Regulation.
The articles from 15 to 22 of the GDPR grant data subjects specific rights. Art. 15 recognizes the right of data subjects to access their personal data and obtain a copy of it. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.
With the request of access, the data subjects have the right to obtain from PROMOS confirmation or denial of the fact that their data are being processed and to know the purposes and categories of data processed, the third parties to which they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. Data subjects also have the right to know for how long their personal data will be used, in respect of the aforementioned purposes.
With respect to their personal data, data subjects may request correction of incorrect data and completion of incomplete data, as well as deletion (right to oblivion) at the conditions indicated by art. 17 of the GDPR, and may also request limitation of processing and portability of data.
To exercise these rights, applicants can write to the company at the e-mail address privacy@promosgroup.it or at the main office address of the data controller.
Before replying, the data controller may need to identify the person making the request, by asking to provide a copy of the user’s identification. The data controller will provide a written answer without undue delay and, in any case, no later than one month after receipt of the request.
GDPR who believe that their personal data may have been used in violation of the provisions of the Regulation or local legislation on the subject of data protection have the right to file a claim with Guarantor for the Protection of Personal Data, with office in Rome, pursuant to art. 77 of the GDPR, as well as with the courts of law.