PRIVACY NOTICE

IN ACCORDANCE WITH ARTS. 13 AND 14 OF REGULATION (EU) 2016/679

(GENERAL DATA PROTECTION REGULATION)

This notice explains how we (Avio S.p.A., with VAT registration no. 09105940960 and registered office at Via Latina, 00034 Colleferro (Rome)), as data controller, process your personal data. It is provided to you in compliance with the rules on the protection of natural persons with regard to the processing of personal data set out in Regulation (EU) 2016/679 and Italian Legislative Decree No. 101 of 10 August 2018.

1.    DEFINITIONS

To facilitate your understanding of this notice, below we provide the meaning of some of the terms used:

·        Data controller: The natural or legal person, public authority, agency or other body which determines the purposes and means of the processing of personal data. In this case, we (Avio) are the data controller.

·        Data processor: Any natural or legal person, public authority, agency or other body which processes personal data on our behalf.

·        Data subject: The identified or identifiable natural person whose personal data is being processed. In this case, you – as a candidate – are the data subject.

·        DPO: The person who we, as data controller, designated to be our data protection officer.

·        Personal data: Any information relating to an identified or identifiable natural person (i.e., a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

·        Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

·        Regulation (EU) 2016/679 (“GDPR”): Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

·        Special categories of personal data: Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or genetic data, biometric data processed for the purpose of uniquely identifying a natural person, or data concerning a natural person’s health, sex life or sexual orientation.

2.    TYPE AND SOURCE OF THE DATA PROCESSED

The information that we may collect and process for the purposes detailed below is data of a personal nature.

We process the following personal data (among others) of candidates: name, surname, gender, place and date of birth, email address, mobile phone number, tax code, address, citizenship, profession, and family status.

We may collect your personal data either directly from you at the time of the interview or from third parties, such as recruitment agencies that, as independent data controllers, have disclosed your data to us.

We do not process data that are not strictly necessary for the purposes set out below.

Special categories of personal data must not be disclosed unless they are expressly required for recruitment purposes (e.g., data relating to protected categories).

3.    PURPOSES OF PROCESSING

All personal data are processed in accordance with the law for purposes related to

recruitment at Avio. With respect to these processing operations, we need to disclose your personal data to proceed with the correct classification of your position within Avio’s organisation chart.

We process your personal data on the basis of pre-contractual negotiations for recruitment purposes.

In the event of litigation in connection with recruitment, we may process your personal data on the basis of our legitimate interest in asserting our rights in court.

4.    SPECIAL CATEGORIES OF PERSONAL DATA

Please do not indicate any special categories of personal data (particularly those regarding health, religious beliefs and political opinions) other than those that may be required as part of certain recruitment processes (e.g., data relating to protected categories).

5.    DATA PROCESSING METHODS

We process your personal data by means of the operations indicated in Art. 4(2) GDPR, namely through the collection, recording, organisation, storage, consultation, alteration, selection, retrieval, alignment, use, combination, blocking, disclosure, erasure and destruction of data. Your personal data are subject to hard-copy, electronic and/or automated processing. We may also process your personal data by using our technological tools.

6.    DATA RETENTION

When the purposes of the processing have been fulfilled, your data will be erased unless the recruitment process requires a longer period. In any case, your data will be stored for no longer than 6 months after collection.

More specifically, your data will be retained for:

·        coordination, selection and application evaluation purposes relating to the potential establishment of an employment relationship with us, for a maximum of 12 months from the date of your last interview with us or, if we do not contact you for an interview, from the date you submitted your CV; and

·        purposes relating to the management of any recruitment-related disputes, for the period strictly necessary for any litigation and, in any case, no longer than the applicable legal time limits.

7.    CATEGORIES OF PERSONS YOUR DATA MAY BE DISCLOSED TO

To carry out some of the activities related to the processing of your personal data, we may disclose your data to trusted external companies or other entities that collaborate directly with us in their capacities as independent data controllers and/or data processors.

More specifically, we may disclose your data to:

·        companies that provide data acquisition, registration and processing services; and/or

·        companies involved in recruitment.

Similarly, we may also disclose your data to people in Avio’s HR department who are in charge of recruitment and who we, as data controller, have authorised to process such data.

8.    POSSIBLE TRANSFER ABROAD OF YOUR PERSONAL DATA

Your data are managed through and stored in filing systems (as hard copies) and on servers owned by us and/or by companies appointed as external data processors. The servers used to store your data are located in Italy and, in any case, in the EU. Your personal data are not transferred outside the EU.

However, we may, if necessary, move our filing systems and servers to other parts of Italy, to other parts of the EU, and/or to countries outside the EU. In that case, we ensure that any transfer of data outside the EU will take place in accordance with the applicable legal provisions and that we will enter into any agreements necessary to guarantee an adequate level of protection and/or adopt the standard contractual clauses provided by the European Commission.

9.    DATA SUBJECT RIGHTS

Under the GDPR, you have the right to access your data: particularly to obtain confirmation of your data’s existence or non-existence at any time, to know your data’s content, origin and geographical location, and to request a copy of your data. You also have the right to verify the accuracy of your data, to request that it be supplemented, updated, rectified, limited, erased, anonymised or blocked if processed in violation of the law, and in any case to object to the processing of your data. Furthermore, you have the right to request the portability of your personal data.

10. EXERCISE OF YOUR RIGHTS

To exercise your rights under section 9 above, contact us or our DPO by writing to:

Avio S.p.A.

Via Latina

00034 Colleferro (Rome)

Phone: +39.06.97285201

Alternatively, you can email: [email protected]. 

You can also contact our DPO in one of the following ways:

·        by sending a registered letter with return receipt for our attention (as data controller) to Avio S.p.A., Via Latina, 00034 Colleferro (Rome);

·        by sending an email to the certified email address: [email protected]. The mailbox can receive emails from/forward emails to non-certified email addresses. It can also receive/send documents as long as they do not exceed 10 MB and are drawn up using static formats without macros or executable content, e.g., PDF/A, Office (e.g., Word and Excel), ZIP and RAR files; or

·        by sending an email for the DPO’s attention: Ivan Rotunno - [email protected].

You will receive a response within 30 days, though we may extend the response time to up to 3 months in particularly complex cases. In the case of an extension, we will provide you at least one interim response within the first 30-day period.

The exercise of rights is, in principle, free of charge. We reserve the right to request a fee in the event of manifestly unfounded or excessive (including repetitive) requests, including in light of any indications from the Italian Data Protection Authority.

11. DATA PROTECTION AUTHORITY

You may file a complaint with the Italian Data Protection Authority through its website: https://www.garanteprivacy.it/web/garante-privacy-en/home_en.