Version 03, July 2020
Data Controller, Joint Data Controllers and Data Subjects
Reverse S.p.A. and its German subsidiary Reverse Deutschland GmbH (“Companies”), whose details can be found on the company website at https://reverse.hr, https://www.Reverse.de and https://www.reallyzation.com/ (“Website(s)”), in accordance with (EU) Regulation 2016/679 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 (“GDPR”), as well as the respective national regulations on the protection of personal data (“National Data Protection Laws”), undertake to protect the personal data (“Data”) provided by candidates (“Candidates”) (i) by means of the appropriate registration form on the Websites and (ii) contained in the CVs uploaded and managed by said candidates on the Websites for the purpose of using the personnel research and selection service with the collaborative recruiting system provided by the Companies (“Service”). It is specified that there is a joint data controller relationship between the Companies, by virtue of a specific agreement, also as a result of the data processing carried out by the subsidiary, through the IT infrastructure platform for the performance of personnel research and selection activities, made available by the parent company Reverse S.p.A.
Reference to the contractual framework
For the purposes of providing the Service, the Companies establish legal relationships of a varying nature with several parties (Candidates, Clients and Suppliers); therefore, with regard to the contractual aspects of the Service, please refer to the relevant contractual Terms and Conditions published on the Website.
Authorised Data Processors
The Candidates' Data is processed by authorised and appropriately instructed individuals, including, solely with regard to the Data contained in the CVs and to the first name and last name, by scouts ("Scouts") who examine and select the CVs in order to support the Company in the provision of the Service. The Scouts are authorised and instructed to process the data.
External Data Processors/Independent Data Controllers and Joint Data Controllers – Recipients of the processing
Depending on the circumstances, the Data may (i) be shared between the Companies, as Joint Data Controllers, with parent companies, subsidiaries/affiliates of the Company, belonging to the group, for internal administration requirements and/or to optimise the activity for the purposes of providing the Service, taking into account, in particular, the place in which the work needs to be carried out (for example, communicating the Candidates' Data to the German subsidiary, where the position sought must be performed in Germany or, conversely, to the Italian parent company where the position sought must be performed in Italy), in the legitimate interest of the Companies or the Companies' Clients; (ii) be communicated at the request of the Companies (and subject to specific prior agreement) to consultants, bodies, businesses and companies that provide services whose performance involves the processing of the Candidates' Data. In particular, these consist of
(a) suppliers of software, applications (including CRM), and hardware, as well as the relevant management, support and maintenance;
(b) service providers for connectivity, email and the relevant management, support and maintenance;
(c) providers of outsourced storage systems, including cloud-based services;
(d) legal advisors, business consultants, accountants, tax advisors.
Depending on the circumstances and the activities undertaken, certain parties may operate as Independent Data Controllers or as Joint Data Controllers, where the purposes and means of the processing are jointly determined.
The Companies provide specific information on the recipients of the Data at the Data Subject's request.
The Candidates' Data contained in their CVs may also be communicated to the Scouts and to the Company's clients (“Clients”) who purchase the Service, in any event subject to the Candidates' prior consent.
Personal data processed
Except for the Data contained in the CVs uploaded/submitted by the Candidates on their own initiative, the Companies only collect Data strictly relating to the Candidates' professional aptitudes and for the purposes of the relevant evaluation and selection. Additional Data is only required in accordance with the applicable regulations.
In general, the Candidates' Data consists of generic data, which does not fall within the definition of sensitive and/or judicial data under the National Data Protection Laws and within the notion of special categories of personal data or data relating to criminal convictions and offences under the GDPR, as well as within the definition of data relating to the Data Subject's health (jointly referred to as "Special Data"), such as, for example, first name and last name, date of birth, postal address and (mobile) phone number, email address and, in general, the information contained in the CVs concerning the professional skills required for the provision of the Service.
With the exception of any Special Data voluntarily included in the CVs by the Candidates themselves, the Companies do not process Special Data for the purposes of providing the Service.
In any event, the Candidates are asked not to include Special Data in their CVs (except for specific reasons related to the position sought or other essential elements) and, in any case, to obscure the Special Data shown on their pay slips, where these are requested by the Companies during the selection process.
Purpose of processing and the relevant legal basis for processing
The Companies process the Data for the purposes and the relevant legal basis provided below:
(a) the registration of the Candidates on the Website; the processing is necessary for the completion of pre-contractual measures adopted by the Companies at the Candidates' request, by uploading or submitting the CVs,
(b) the uploading, management and deletion of the relevant CVs by the Candidates; the processing is necessary for the provision of the Service,
(c) the examination and selection, by the Companies' authorised personnel, the Scouts and the Clients (in limited cases and in any event at an advanced stage of the selection), of the CVs of interest, based on the job offer published on the Website, the job opportunities and/or the specific selection requirements (it being understood that the Companies do not undertake any further processing of the Data contained in the CVs, the updating of which is the sole responsibility of the Candidate). The processing is necessary for the provision of the Service,
(d) the research (for example, through social media channels) and analysis of the Data of potential Candidates based on the employment positions requested by the Clients and the potential Candidates themselves, for the purposes of verifying their skills and qualifications and to contact them for the purposes of assessing their interest in commencing or continuing with the selection. The processing is based on the pursuit of the legitimate interest of the Companies or third parties (Customers), for the purposes of providing the Service.
Data retention period
The Candidates may at any time amend their CVs themselves or have them deleted by submitting a request to the Companies (privacy@Reverse.hr).
The consent to receive messages with alerts may be revoked at any time.
The Scouts process the Candidates' Data for the period of time required to provide the Service, under the conditions and within the limits provided for in the contractual collaboration agreement. Therefore, upon completion of the personnel research and selection process, the Scouts are no longer authorised to process the Candidates' Data and cannot access it.
International data transfers
For administrative requirements and/or the optimisation of activities for the purposes of providing the Service, the Companies may transfer the Data to parent companies and subsidiaries/affiliates belonging to the group, based in the European Union or the European Economic Area.
The IT service providers established outside the European Union and used by the Companies have joined the Privacy Shield; therefore, any transfer of Data is carried out in compliance with the provisions of Articles 44 et seq. of the GDPR. In any event, the Companies shall be responsible for ensuring that they use providers that comply with the guarantees provided for in Articles 44 et seq. of the GDPR concerning international data transfers.
The Candidates may contact the Companies (email@example.com) or the external Data Processors to exercise their rights under the National Data Protection Laws as applicable and the GDPR (Articles 15 et seq.), and, in particular, to access their personal data, request its correction, updating, deletion or restriction, as well as to request its portability, by sending a communication to the Companies' contact details indicated above.
Right to object
In the same aforementioned manner, the Candidates may object, in whole or in part, to the processing of their personal data, on the legal basis of legitimate interest, pursuant to and for the purposes of the provisions of Article 21 of the GDPR.
Any Candidate who believes that the processing of their Data is in breach of the GDPR, in accordance with the provisions of Article 77 of the GDPR, may lodge a complaint with a supervisory authority where the Candidate habitually resides or works, or with a supervisory authority where the alleged data breach has occurred.
Updates and revisions
On the basis of a specific agreement between the Companies, it has been established to appoint a common Data Manager ("Data Manager"), who is entrusted with the task of supporting and coordinating the relevant data processing activities and who may also act as a point of contact for the Data Subjects. The contact details of the Data Manager are as follows [•].