Information for candidates
1. Who we are
This privacy statement has been provided to you in accordance with Article 13 of Regulation (EU) 2016/679 on the protection of personal data (the “Regulation” or “GDPR”) and amendments and additions thereto, and with other applicable laws as in force from time to time, including Article 13 of Legislative Decree 196 of 30/06/2003 (“Personal Data Protection Code”) by Arpa Consulting S.r.l. (“ARPA” or the “Company”) in its capacity as controller of your personal data.
Arpa Consulting S.r.l., a limited liability company registered in Turin, Italy (registered address at Corso Re Umberto 65, Turin), is a recruitment agency authorised to practice by the Ministry of Labour and Welfare under Article 4(1)(d) of Legislative Decree 276 of 2003 (authorisation No. 9697 of 5 April 2007) and registered in the electronic roll of job search providers held by Employment Agencies.
For the purposes of this privacy statement, “Candidate” means any person screened by Arpa Consulting S.r.l. through its job search and recruitment programmes.
2. Categories of personal data processed
Your personal data will be processed by ARPA within the scope of our dealings with you. The categories of personal data that will be processed include:
- a) your identification data and contact details, including but not limited to: your first and last names, tax ID, nationality, date and place of birth, places of address, phone numbers including your mobile phone number, e-mail addresses, etc.;
- b) family details, including but not limited to: your marital status, dependants, place of residence, etc.;
- c) resume details, such as education and career experience, including but not limited to: your educational qualifications, past and present employers, positions held and relative duties and responsibilities, employment grades, career promotions, performance and achievements, hobbies and personal interests, volunteer work, etc.;
- d) data concerning your pay and remuneration, including but not limited to: your gross annual salary, bonuses, stock options, insurance benefits, fringe benefits, etc.;
- e) photographs and audio-visual recordings of you;
- f) your sensitive data, as necessary and permitted by law, including but not limited to: your health data, judicial data, residency permit, etc.
ARPA does not need to know, and therefore will not accept, information of a confidential nature concerning third parties or information governed by any confidentiality agreements you may have entered into.
Your personal data may be collected through disclosures made by you to ARPA through various channels, such as by electronic mail, telephone or Skype, the registration of data on our website, direct interviews with Company personnel, etc.
ARPA may also acquire your personal data held by Internet portals, where the latter have requested and obtained your consent to the disclosure of the data to third parties authorised to receive them.
In addition, your personal data may be provided to the Company directly by its clients or by third parties that have requested and obtained your consent to do so.
3. Legal grounds and purposes for which your personal data will be processed
ARPA is a recruitment services provider specialised in human resources development and management consultancy. In particular, it is engaged by clients to perform job searches and recruitment for executive, board, management and professional positions.
With your express consent, your personal data will be processed by the Company to assess your potential candidacy in job search and recruitment activities and, in particular:
- to represent your personal and professional profile;
- to propose your professional skills and expertise to client companies, bodies and organisations looking to hire staff, under specific job search engagements;
- to comply with legal obligations binding on the Company;
- to establish, exercise or defend legal claims in court or whenever legal action is taken.
The Company is committed to protecting the privacy of its candidates, as strictly related to its activities, and does all it can to guarantee that your personal data is processed with respect for your rights, fundamental freedoms and dignity as a person, in particular as concerns the protection of your personal identity, in accordance with the provisions of the Regulation.
4. Disclosure and transfer of your personal data
Personal data collected by ARPA will only be disclosed for the purposes stated above. Your personal data will not be transferred to third parties, other than those identified in this privacy statement.
In the course of our activities, and exclusively for the same purposes stated in this privacy statement, your personal data may be transferred to the following categories of recipients:
- a) ARPA personnel;
- b) consultants engaged by ARPA;
- c) clients of ARPA; d) third party companies that assist ARPA in job search activities.
ARPA may transfer your personal data to countries located outside the European Union (EU)/European Economic Area (EEA), known as “third countries”. Such transfers to third countries may include all the processing activities identified in section 3 hereof. This privacy statement also applies in the event that your personal data is transferred to third countries where data protection levels are different to the European Union. Specifically, international transfers of personal data may occur in the following situations:
- a) third parties outside the EU/EEA: you will be informed and, where required, your consent will be requested before your personal data is transferred to third countries. Any transfers of personal data to countries for which the European Commission has not expressed an adequacy decision will only be made under agreements that include the standard contractual clauses envisaged by the European Commission or other appropriate safeguards in accordance with laws in force.
You may request further information on international transfers of personal data and obtain a copy of the adequate protections adopted by exercising your privacy rights, as reported in section 8 hereof.
6. Protection of your personal data
ARPA will process your personal data both manually, with printed media, and electronically. Your personal data will be held in an archive owned exclusively by us and accessible exclusively by our personnel or by processors duly authorised and monitored. The Company has implemented adequate technical and organisational measures to provide suitable levels of security and confidentiality for personal data.
Those measures take into consideration:
- a) the state of the art of technology;
- b) the costs of its implementation;
- c) the nature of the data;
- d) the risks of processing.The purpose of those measures is to protect personal data from accidental or unlawful destruction or alteration, accidental loss, unauthorised disclosure or access and from any other form of unlawful processing.
Moreover, when managing your personal data, ARPA:
- a) only collects and processes data that is suitable, relevant and not excessive for the purposes stated above;
- b) ensures that they are accurate and remain reasonably up to date on the basis of your notifications.
7. Retention periods for your personal data
Without prejudice to your right to object to the processing of your personal data and/or obtain their erasure, ARPA will keep your personal data only for the time necessary to fulfil the purposes for which they were collected or to comply with contractual, legal or regulatory requirements.
The retention period is therefore the time for which they will be used plus the time required until contractual obligations and legal requirements lapse, unless legal planning or statutory timeframes require a longer retention period. When that period expires, your personal data will be removed from all active system and/or rendered anonymous.
8. Your legal rights
The following rights attach to the personal data processed by ARPA:
➢ Right to rectification: You have the right to obtain from ARPA the rectification of all personal data concerning you or provided by you. ARPA will make every reasonable effort to ensure that the personal data in its possession is precise, complete, up to date and relevant on the basis of the most recent information provided by you;
➢ Right to restriction: You have the right to obtain the restriction of the processing of your personal data where:
- a) you contest the accuracy of your personal data during the period in which ARPA is required to check its accuracy;
- b) processing is unlawful or you request a restriction of processing or the erasure of your personal data;
- c) it is no longer necessary for ARPA to keep your personal data but you require the data for the establishment, exercise or defence of legal claims; or
- d) you have objected to processing while ARPA is verifying whether its legitimate grounds override your legitimate grounds;
➢ Right of access: You have the right to obtain from ARPA information on personal data held that concerns you, including therein information on the categories of personal data possessed or controlled by ARPA, the purposes for which they are used, the source from which they originated (if not directly provided by you), and any recipients to which they have been disclosed;
➢ Right to data portability: At your request, ARPA will transfer the personal data provided by you in electronic form to another controller, if technically possible, providing that the data will be processed with your consent or is necessary for the performance of a contract;
➢ Right to erasure: You have the right to obtain from ARPA the erasure of your personal data where:
- a) the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- b) you have the right to object to any further processing of your personal data and you have exercised that right;
- c) your personal data has been processed unlawfully;
unless the processing of your data is necessary for compliance with legal or statutory obligations or for the establishment, exercise or defence of legal claims;
➢ Right to object: You have the right to object at any time to the processing of your personal data, where data processing is not based on your consent but on the legitimate interests of ARPA or third parties. In that case, ARPA will cease to process your personal data, unless it can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims. If you choose to object to processing, please specify whether you intend to have your personal data erased or its processing restricted;