• Purpose of this Policy
  • Data processing manager
  • Processing of personal data
  • Rights to data privacy
  • Requests or concerns
  • Updates to this Policy

1. Purpose of this Information

This Notice describes the personal data we collect and process, the purposes of the Processing and your rights in relation to it.

If you have any questions about the applicable standards, or have any comments or complaints about this Policy, please contact us as set out in section 5 below.

2. Data Controller

The person responsible for processing personal data will be:

3. Processing of personal data

3.1. Types of personal data we may collect

“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable person means a person who can be identified, directly or indirectly, in particular by means of an identifier such as a name, an identification number, residence data, an online identifier or by reason of one or more specific factors relating to identity. physical, physiological, genetic, mental, economic, cultural or social nature of that natural person.

The types of Personal Data processed include, but are not limited to: identification data and contact details (such as name, address, telephone number, personal email address, date of birth), photograph, marital status, education, qualifications, details relating to professional life, details relating to personal life, financial information, proof of employment eligibility, and any other information communicated on a voluntary basis.

Personal Data may be collected by different means, including:

  • Completed contact or application forms on our website;
  • CV and references;
  • personal contacts (e.g. phone calls, emails and interviews); And
  • reports and/or evaluations and estimates on the interview.

In most cases, we collect Personal Data directly from the interested party, but sometimes we may obtain it indirectly from:

  • public sources (e.g. LinkedIn or freely accessible social media);
  • And third parties (e.g. recruitment agencies, temporary agencies, evaluation partners, …).

3.2. Sensitive personal data

We do not collect or process any sensitive personal data such as information relating to racial or ethnic origin, political or philosophical opinions, religious beliefs, physical or mental health or condition, life, sexual preferences or orientation, trade union membership or affiliation, biometric data, genetic information, the commission or alleged commission of a criminal offense, and any other related legal action or past conviction of the individual. In the event that, due to specific circumstances, we need to collect such data, we will ask for the express prior written consent of the interested party.

Please note that by providing us with unsolicited sensitive personal data, you consent to the processing of that data for recruitment purposes.

3.3. Purpose and legitimacy of the processing

We process Personal Data for recruitment purposes, to register and process applications for a position within our company and/or other Aliaxis companies. We will process all Personal Data necessary for the purpose of evaluating applications for each position.

In the event that we decide to make an employment offer to the interested party, we may also use their Personal Data to draw up an employment offer/contract.

Accordingly, the processing of Personal Data is based on Aliaxis' legitimate interests (e.g. to evaluate the data subject before making him or her an offer of employment).

3.4. Disclosure of Personal Data

We ensure that we allow access to Personal Data only to our employees who need such access to carry out their duties and responsibilities, as well as to third parties who have a legitimate purpose to access it. If we disclose Personal Data to another Aliaxis Group entity or to a third party, we will take all necessary steps to ensure an adequate level of protection for such data.

In particular, Personal Data may be communicated to the following categories of recipients:

  • Other Aliaxis companies: we may disclose Personal Data to other entities within the Aliaxis Group to carry out recruitment activities (e.g. if employees of other Aliaxis companies are involved in the recruitment process);
  • Third Party Service Providers: We may also make certain Personal Data available to third parties who provide services to us, such as rating agencies. We may also disclose Personal Data to external collaborators, lawyers and consultants on a need-to-know basis.
  • To the three third parties: we may also communicate Personal Data to other third parties for other legitimate reasons, including:
  • where we are legally required to do so (for example, to comply with valid legal processes such as search or subpoena warrants, or court orders, etc…);
  • this communication is required in order to provide you with services and/or information;
  • with the prior consent of the interested party.

3.5. International transfers of Personal Data

As our Group operates globally, we may need to transfer Personal Data to other Aliaxis companies or third party service providers located in countries other than those in which the Personal Data was initially collected.

For example, we may need to transfer Personal Data to other countries for assessment purposes or for other services related to the recruitment process. In this case, we will implement appropriate PO 28 – PR3: Privacy Policy for Recruitment 4 of 5 safeguards to ensure an adequate level of protection for any Personal Data transferred.

If the transfer concerns Personal Data of European residents in countries outside the European Union (EU) and the European Economic Area (EEA), we will take the necessary measures to ensure an adequate level of data protection under the law EU, such as entering into standard EU contractual clauses with the party who will receive the data.

3.6. Protection of Personal Data

We are committed to ensuring the protection of Personal Data. In order to avoid unauthorized access or disclosure or any other unlawful form of Processing of Personal Data, we have put in place appropriate physical, technical and procedural measures to protect the Personal Data in our possession.

Access to Personal Data is limited to authorized Aliaxis employees for the sole purpose of fulfilling their professional responsibilities. We have also implemented appropriate technical measures, including but not limited to [access authorizations, authentications, firewalls, anti-virus measures, backup and disaster recovery plans], designed to provide a level of security appropriate to the risk inherent in the Processing of Personal data.

3.7. Storage and Deletion of Personal Data

We will retain Personal Data in accordance with applicable laws and solely to the extent necessary to fulfill the purposes described above. Generally, this means that Personal Data will be retained:

  • if the recruitment process results in an employment relationship, we will retain the Personal Data until the end of the employment or business relationship with us, in accordance with our Employee Privacy Policy.
  • If the recruitment process does not result in an employment or work relationship, we will retain the Personal Data for a maximum period of one year after the end of the recruitment process in order to be able to contact the interested party in case a future position matches their profile.

At the end of the retention period, we will ensure that the Personal Data is deleted or anonymised, or, if this is not possible (for example, because the Personal Data has been stored in backup archives), we will store it securely, isolating it from any further processing activities.

4. Rights to data confidentiality

Interested parties have the following rights:

  • the right to obtain confirmation of whether or not your Personal Data is being processed and, if so, the right to access and/or receive a copy of your Personal Data;
  • right to rectify or update any incorrect or incomplete Personal Data;
  • right to obtain the deletion of your Personal Data;
  • right to limit the processing of your Personal Data according to certain legal bases;
  • right to object to the processing of your Personal Data for reasons related to your specific situation, where such Processing is necessary for the purposes of our legitimate interest;
  • right to receive their Personal Data in a structured, commonly used and electronically readable format, and to have their Personal Data transmitted to another controller where the processing is carried out by automated means and is based on the consent of the interested party;
  • right to withdraw your consent at any time if the processing of Personal Data is based on your consent. The revocation of consent will not affect the legitimacy of any processing carried out before said revocation, nor will it affect the processing of Personal Data carried out relying on grounds of legitimacy of the processing other than consent; And;
  • right to lodge a complaint with the competent data protection authority.

If you wish to exercise any of the above rights, please contact us as set out in section 5 below. We will answer them all requests in compliance with applicable data protection laws.

5. Requests or Concerns

If you have any questions or concerns about how we process your Personal Data, or if you would like further information regarding this Policy, or if you wish to exercise your privacy rights, please contact:

the Director of Human Resources, currently Maddalena DE PADOVA, at the company headquarters.

6. Updates to this Policy

This Policy may be updated periodically to reflect any necessary changes in our privacy practices.