This privacy notice regulates the processing of personal data as regards reception of Curriculum Vitae through postal or mailing addresses, carried out by ICAP-SIRA Chemicals and Polymers SpA, currently in Via F.Corridoni, 19 – Parabiago (MI) – Telephone 0331/496111, e-mail: info@icapsira.com, Fax 0331/495005 (hereinafter the “Data Controller”), . Since the Data Controller is established in Italy, no representative has been appointed, in compliance with the current legislation in topic of data protection, including in particular the EU Regulation 2016/679 (hereinafter the “GDPR”).
1. Identity and contact details of the Data Controller
The Data Controller is ICAP-SIRA Chemicals and Polymers SpA.
Since the Data Controller is established in Italy, no representative has been appointed.
2. Contact details of the Data Protection Officer
The Data Controller has appointed a Data Protection Officer (DPO) who can be contacted at the e-mail address dpo@icapsira.com.
3. Purpose and legal basis of the processing
a) In relation to Curriculum Vitae voluntarily sent by the data subjects, the processing of personal data of the sender user is carried out in order to allow the activity of Curriculum Vitae examination and assessment; in this case, the legal basis of the processing is the legitimate interest of the Data Controller.
b) In relation to Curriculum Vitae voluntarily sent through e-mail by data subjects, upon oral or written request by the Data Controller, the processing of personal data of the sender is carried out in order to allow the activity of Curriculum Vitae examination and assessment; in this case, the legal basis of the processing is the need of processing in order to perform the contract and/or for the management of the pre-contractual relationship;
4. Methods of consent expression
For processing the personal data of the data subjects, the expressed consent is not necessary to be given.
5. Processing methods and logic
- In relation to the personal data processed and stored for the purposes referred to at point a), number 3 of this privacy notice, processing will be performed using paper instruments, automated logics and use of CRM type management software wich will make it possible to better ensure the fulfilment of the contractual obligations, as well as through the use of e-mail systems;
- In relation to the personal data processed and stored for the purposes referred to at point b), number 3 of this privacy notice, processing will be performed using paper instruments, automated logics and use of CRM type management software which will make it possible to better ensure the fulfilment of the contractual obligations, as well as through the use of e-mail systems.
6. Source from which the personal data originate
Only personal data provided into the CURRICULUM VITAE by the data subject will be processed.
7. Recipient and any categories of personal data recipients
Recipients of personal data of the data subjects may be:
- The communication company that carried out commercial communication and profiling activities on behalf of the Data Controller, which have the status of data processors;
- Companies offering information society services, including, in particular, those offering hosting services.
8. Categories of data
Personal data will be processed. The data subjects need to omit any particular data from the Curriculum Vitae, that is data revealing religious or philosophical beliefs, sexual or other orientation, membership of political parties, trade unons, associations or organizations of a religious, philosophical, political or trade union nature, data relating to health, biometric data, genetic data, data on racial and ethnic origin. Under no circumstances any Curriculum Vitae which contains such data will be processed and it will be immediately deleted by the Data Controller.
9. Data transfer
The Data Controller intends transferring the personal data to a third country or to an international organisation.
Such entities could be represented, for example, by:
- Communication companies that carry out communication activities on behalf of the Data Controller;
- Companies offering information society services, including, in particular, those offering hosting services;
- Service providers of the communication company.
The transfer of personal data to such entities, if they are established in a third country or an international organisation, is carried out in the presence of an adequacy decision of the European Commission, which has verified how the third country, territory or one or more specific sectors within the third country or the international organisation in question guarantee an adequate level of protection of rights. In any case, the Data Controller – if it deems appropriate – reserves the right to conclude specific separate agreements which oblige such entities to adopt adequate security measures, including organizational measures, aimed at offering appropriate guarantees regarding rights. Google Inc., in particular, is contractually bound to ensure adequate protection of the rights of the data subjects. The data may thus be transferred to the following countries: United States of America. To obtain a copy of these data or the place where they were made available, simply send a request to the following address: privacy@icapsira.com
10. Personal data storage period
The personal data processed and stored for the purposes referred to at point a) and b), of this privacy notice, will be stored for a period of time of not more than 5 years starting from the date of Curriculum Vitae sending.
11. Optional nature of consent and consequences of consent not being given
- In relation to personal data processed and stored for the purposes referred to at point a), number 3, of this privacy notice, the data processing is based on the legitimate interest of the Data Controller, without which it would not be possible to respond to the data subjects requests.
- In relation to personal data processed and stored for the purposes referred to at point b), number 3, of this privacy notice, the data processing is an obligation of a contractual nature and a necessary condition to carry out the pre-contractual negotiations and finalisation of the contract. The data subject may provide its personal data; in case of failure to provide such data, i twill be not possible to execute the contract i.e. carry out any contractual activity.
12. Data Subjects’ rights
12.1 Right to object
The data subject has the right to object at any time on grounds relating to the data subject’s particular situation, to the processing of personal data concerning the data subject pursuant to article 6, sub-section 1, letter (e) or (f) of the GDPR, including profiling on the basis of these provisions. The Data Controller shall refrain from any further processing of the personal data unless it proves that there are compelling legitimate grounds for processing which take precedence over the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of a right in court.
12.2 Other rights
The Data Controller also wishes to inform the data subjects of the existence of the following rights:
- Right to access: the data subject has the right to obtain from the Data Controller confirmation as to whether or not personal data concerning the data subject are being processed and, if so, to obtain access to the personal data and specific information, in accordance with article 15 of the GDPR;
- Right to rectification: the data subject has the right to obtain from the Data Controller the rectification of inaccurate personal data concerning the data subject without undue delay. Taking into account the processing purposes, the data subject has the right to obtain supplementing of incomplete personal data, including by providing a supplementary statement, in accordance with art. 16 of the GDPR;
- Right to erasure of data, including the right to revoke consent: the data subject has the right to obtain from the Data Controller the erasure of the personal data concerning the data subject without undue delay and the Data Controller has the obligation to erase the personal data without undue delay, or to revoke consent, if the reasons set out in art. 17 of the GDPR exist. With regard to the right to revocation, the data subject also has the right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to revocation;
- Right to restriction of processing: the data subject has the right to obtain from the Data Controller the restriction of processing when the conditions set out in art. 18 of the GDPR exist;
- Right to data portability : the data subject has the right to receive in a structured fromat, commonly used and readable by automatic devices, the personal data concerning the data subject provided to the Data Controller and has the right to send such data to another data controller without any impediment by the Data Controller in the cases and at the conditions specified in art.20 of the GDPR.
13. Excersing rights
The applications to exercise the rights indicated in this privacy notice, including, in particular, the right to erasure and the right to revoke consent given must be addressed directly to the Data Controller at the e-mail address: privacy@icapsira.com . Alternatively, such rights can be exercised by sending a registered letter with recorded delivery to: ICAP-SIRA Chemicals and Polymers SpA – Via F.Corridoni, 19 – 20015 PARABIAGO (MI).
14. Accessibility of privacy notice
The privacy notice is accessible at the Data Controller’s address ICAP-SIRA Chemicals and Polymers SpA – Via F.Corridoni, 19 – 20015 PARABIAGO (MI). If so expressly requested, the information can also be provided orally, as long as the identity of the applicant is proven, by means of a phone call request to the addresses of the Data Controller.
