The reason for this policy
Because it is required by Regulation (EU) 679/2016 (“GDPR”) and by Italian privacy law (Legislative Decree 196/2003 and 101/2018). Based on these regulations, we are required to provide you with information on "how" and "why" we process your personal data in the search and selection phase of the personnel who will become part of the Reverse group (the "Group").
We are a group of companies, consisting of the Italian parent company, Reverse S.p.A., and other subsidiaries (the "Subsidiaries") established in other EU and non-EU countries (you will find our subsidiaries in the footer of the language versions of the site reverse.hr). In technical/legal terms, using the terminology of the GDPR, we are the "Data Controller", i.e. the entity that decides why and how to process your data. More specifically, Reverse S.p.A. and each Subsidiary are "Joint Controllers" for the processing of your data. This is because, even if Reverse S.p.A. is the Group's "think tank" and establishes the general and specific directives and objectives, each Subsidiary contributes and supports the parent company in pursuing these directives and common objectives, without prejudice to the legal and regulatory aspects that must be managed by each Subsidiary in accordance with its own national laws. In this regard, there is a specific co-ownership agreement on data processing between the Reverse Group companies.
Regardless of the Subsidiary with which you have direct relations, you can contact us using the addresses listed at: www.reverse.hr (the "Website") or preferably firstname.lastname@example.org. Under the co-ownership agreement, you will be put in touch with the Joint Controller who manages your data and can give you the appropriate answers to your request.
What data do we process? How, why and for how long?
Processing method - the Reverse Group does not use paper; this means that you must upload your CV to the dedicated sections of our Site or send it to us by email, whether you want to apply spontaneously or to apply for one of our vacancies. Only IT and digital tools are used in the selection process (for example, software for videocalls and IT services for the management and storage of digital documents);
purpose and legal basis of data processing - if your CV is of interest to us, we have a selection process in the form of various interviews, during which Reverse personnel – duly instructed and authorised to process your personal data in accordance with privacy legislation – analyse and collect further details about you, in particular, information on your professional experience, but also on your soft skills and your people skills. In these processes, we carry out a progressivescreeningof the data in your CV and information gathered during the interviews, but Your consent is not required, because you spontaneously provide us with the data for pre-contractual purposes;
sensitive data - in some rare cases and in any case only for purposes related to the selection and evaluation of the professional requirements that apply to a vacancy (for example, for hiring protected categories of employees pursuant to Law 68/1999), we may ask you to provide us with sensitive data (in particular, regarding health) during the interviews. If you enter your sensitive data that we do not need on your CV, we will not use it and, if possible, we will delete/redact it;
data retention - Your CV is important to us and we keep it in our systems for 10 years, from the date of your application, so that we can contact you if your profile matches the professional profiles sought at that time. In the event that your CV matches one of the Group's vacancies, in addition to keeping your CV in our database, we also collect and store the data you provide during the interviews, for the duration of the selection process; this will be in digital format (as notes). In the event that selection results in a negative outcome (decision not to hire), your data is retained in accordance with the aforementioned criteria; conversely, in the event of a positive outcome (decision to hire), we retain your data for the entire duration of the employment contract with us, in accordance with the employee information provided during hiring. In all cases,
at any time, you can ask us to delete your data from our database by sending a specific request (Reverse data erasure request) to us at email@example.com. If the conditions are met, we will proceed with the deletion as soon as possible and will send you a reply by email.
Who your data is shared with
In general, we do not need to share your data with persons outside the Group, but in the following cases some persons may have access to your data in a limited number of situations and in any case governed by specific agreements: (a) questionnaires, surveys or feedback collected regarding the Group's selection processes, carried out by specialised companies appointed by us to collect and analyse the data in order to generate reports and statistics; (b) the use of IT services, such as those for video calls and remote interviews or for the management of our data bases, supplied by third-party providers and through which your data is stored.
Where your data is transferred to
Some of these external parties may have their main place of business in the United States. We are aware that, following the recent European Court of Justice rulings on the transfer of data to the United States (judgment C-311/18, so-called "Schrems II"), it is impossible for us to ensure that these persons benefit from guarantees equivalent to those provided by the privacy legislation of the European Union. However, since that ruling, most US-based providers – many of whom are global operators in telecommunications and IT services – have adopted even higher security measures to ensure that data receives as much protection as possible from interference by public authorities. Having said that, for the sake of transparency, we believe it right and proper to inform you that, since you are deciding to carry out the selection process with us, the tools we use may include services from US providers. If you find this unacceptable, unfortunately, we will not be able to process your pre-contractual request to access the Group's selection processes.
Privacy and protection rights
Please note that you can exercise a series of rights in connection with your data, by sending a specific request to us at firstname.lastname@example.org, in order to obtain: access, correction, deletion, restriction, the interruption of processing and data portability. Should you feel that your rights are not satisfied or if you believe that the Group is failing to comply with personal data processing laws, you can always contact us to try to resolve the matter amicably or send a complaint to the Personal Data Protection Authority (https://www.garanteprivacy.it).
DPO contact details
DPO means Data Protection Officer, the person who works alongside us and supports us so that your personal data is processed in accordance with the GDPR. You can contact the DPO by writing to: email@example.com.