Our company, Lavoropiù SpA (“Data Controller”), performs the function of work administration, temporary employment services, research and selection, recruiting services, outplacement and outplacement support activites, even for third parties, active labour policies training and would like to inform you about your rights as Data Subject and about who, how, why and for what period of time will process your personal data [1].
Which kind of personal data does Lavoropiù process?
Data collection will be carried out directly by the data subjects, also by electronic means, through documents concerning previous professional and training experiences, that data subjects will send o by filling in the forms made available from Lavoropiù S.p.a., through third parties acting as other independent Data Controller (e.g. recruiting websites or platforms) and from other publicly accessible sources.
On the occasion of the aforesaid processing, in addition to contact details (such as name, surname, address), including images, we will be able to know data belonging to special categories, according to the art. 9 and following of the EU Regulation 2016/679 (I.e. relating to his state of health) [2].
Although the collection of personal data is functional to the performance of our activities, we remind you that is not mandatory by law and that you are entitled to not provide them.
In case of refusal, our Company will not be able to collect and store them in our file archive and, then, will not be able to make any selection or evaluation of your application.
Why does Lavoropiù process personal data?
These kind of activities provide for the processing of data relating to the people who come to us looking for a job and who use our services, for the sole purpose of evaluating them as candidates for the positions for which they are proposed and for subsequent staff searches, as participants in training courses and/or involved in active labor policies and/or for the establishment of an employment relationship, with Lavoropiù SpA or, as part of the administration activity, with other companies.
The personal data you provide will be collected and processed exclusively for the aforementioned purposes: in order to the relationship before the establishment of the employment relationship, because processing is necessary in order to take steps at the request of the data subject prior to entering into a contract; [3]; as regards to special categories of personal data processed in the context of the employment relationship, because the processing is necessary for compliance with a legal obligation to which the Data Controller is subject, in the field of labor law and social security and social protection and authorized by European Union and Italian law, with appropriate safeguards for fundamental rights and interests of the data subject [4], personal data collected by independent Data Controllers (e.g. recruiting websites) and from other publicly accessible sources, on the bases of the legitimate interest of the Data Controller [5].
How does Lavoropiù process personal data?
The processing of your data will be based on compliance with the principles of lawfulness, correctness, relevance, proportionality and minimization.
It will be carried out solely for the purposes mentioned above, always with logic strictly related to the scope, in paper form and by magnetic, optical, electronic support, by parties authorized to perform these tasks, appropriately educated and made aware of the constraints imposed by the reference discipline, national and European, with the adoption, after appropriate risk assessment process, of the protection measures - technical, organizational and procedural - in the most appropriate state to ensure the security and confidentiality of the aforementioned data, so how to avoid accidental loss, accidental destruction, illicit or incorrect use, unauthorized access, unlawfulprocessing or not in accordance with the purpose of the collection.
Your personal data will be stored by our Company, unless there is an express request for cancellation of the data subject, compatible with the applicable regulations: in relation to the purpose of establishing a working relationship, also in the field of administration, for 11 (eleven) years from the termination of the aforementioned relationship, for any reason whatsoever, subject to compliance with the conservation obligations established by law and, in any case, in the presence of litigation, for the time necessary to exercise or defend a right in Court; in relation to all other processing purposes, for 48 (forty eight) months since the last interaction between the Data Controller and the data subject, confirming the consent already given (by way of example and not exhaustively: updating the data on the profile available in the database; participation by the data subject in a selection regarding the services provided by Lavoropiù SpA). Your personal data will not be in any form subject to automated decision-making, including profiling.
What are the recipients of personal data processed by Lavoropiù?
The collected data may be communicated to Forma.Temp (Fund for the professional training of temporary workers), to Borsa continua nazionale del lavoro (web-portal of Ministero del Lavoro) to our Clients Companies or to our Suppliers whom provide services (for example, partner companies that organize training courses), with an invitation to treat them in full compliance with the applicable provisions in this area. Your data will also be processed by internal staff as authorized to process for the purposes mentioned above. In any case, they will not be disseminated. In addition, the data relating to the formalities necessary for the management of the employment relationship will be communicated, functionally to the type of employment relationship that will be part of the person concerned, only to those who have title within this list:
• to Lavoropiù SpA staff as authorized for processing;
• to the Companies where you will perform your work, as per the letter of employment;
• to any physician responsible for medical surveillance;
- to any Insurance Companies with which the Data Controller has stipulated policies to protect the risks weighing on the data subject, directly or indirectly, in relation to his work performance
• to all bodies responsible for checks and checks on the regularity of the obligations referred to in the aforementioned purposes.
If the data subject, as part of the employment relationship, is sent to work at user companies established in Third Countries, the data collected may be communicated to the latter, but the transmission of the aforementioned information will take place, however technically possible, keeping the place of conservation within the territory of the European Union.
In this case, the Companies will sign in advance with Lavoropiù SpA a specific contractual clause and SCC, with which they will be obliged to use the best practices in the field of information security and the respect - when compliant with local laws - of the European relevant provisions (i.e. EU Regulation 2016/679).
Data Subject's rights
You are entitled at any time:
1. Right of access – to obtain from Lavoropiù SpA information about: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject confirmation as to whether or not personal data concerning your person are being processed; 2. Right to rectification – to obtain from Lavoropiù SpA the rectification of inaccurate personal data concerning your person; 3. Right to erasure – to obtain from Lavoropiù SpA the erasure of personal data concerning your person where legal grounds exist; 4. Right to restriction of processing – to obtain from Lavoropiù SpA restriction of processing where legal grounds exist; 5. Right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning your person which is based on point (e) or (f) of Article 6(1) GDPR. 6. Data Portability - to receive your personal data, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. Furthermore, you have the right to complain at the competent Data Protection Authority about the processing of your personal data.
How can I contact Lavoropiù?
To exercise your rights, you can contact the Data Controller:
Lavoropiù SpA – Agenzia per il Lavoro-Piazza San Martino 1- 40126 Bologna – Italy. Aut. Min. Prot n.1104-SG granted by the Ministry of Labour on the date of 26/11/04 – professionally registered to the information system of the Employment Agencies (Albo), section I, legally represented by Rudy Giuseppe Parracino, at the address: Piazza San Martino 1 – 40126 Bologna – Italy tel. 051/0988270, [email protected].
and, to obtain further clarifications about the processing, as well as for any reports or complaints, the appointed Data Protection Officer: Donato La Muscatella, lawyer, contact mail: [email protected].
