RECRUITMENT PRIVACY POLICY “WORK WITH US”

PRIVACY POLICY PURSUANT TO ARTICLES 13 AND 14, RECITALS 60-62, EU GENERAL DATA PROTECTION REGULATION 2016/679 (EU-GDPR)

DATA CONTROLLER
Lincotek TrentoS.p.A.

Address of its Registered office and Administrative headquarters:Via al Dos de la Roda 60, 38057 Pergine Valsugana, Trento (TN) Italy
Phone: +39 0461 518901
Fax: +39 0461-518922
Mail: medical.EMEA@lincotek.com
Certified e-mail address: medical.TN@pec.lincotek.it
VAT number, Tax Code and ITVAT: IT 01305350223
Economic Administrative Index No.:TN -129060
Paid-up Share Capital € 1.806.000,00

www.lincotekmedical.com
privacy@lincotek.com

Business sector and activities:

  • Treatment and coating of metals. Provision of special services for the orthopaedic industry.

 

PRINCIPLES
One of our main goals is to protect personal data.

In this section you can submit your application by filling in the specific application form. For the purposes of this Job Posting following information are required: personal details (name and surname), application by geographical area, contact details (e-mail address). In the dedicated field “Other information” it is also possible to write a short message, for example to introduce oneself, as well as to attach and submit your CV in PDF format.

Personal data are processed lawfully, fairly and in a transparent manner, and they shall be adequate, relevant and limited to the minimum necessary and, where necessary, kept up to date and collected for specified, explicit and legitimate purposes pursuant to Articles 5 and 6 of EU General Data Protection Regulation 2016/679 (GDPR) following consent if so required.

Personal Data shall be processedin a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing, and against accidental loss, destruction or damage, by taking suitable technical and organisational measures (Integrity and Confidentiality).

The Personal Data and otherspecial category data that Data subjects have provided to us or that we have legitimately collected shall be processed for the purposes of recruitment, profile assessment and personnel search and selection if need be.

Procedures and suggestion to submit your CV:

  1. How to submit your resume as a PDF document:
  2. You should avoid, where possible, to provide sensitive Data (or those that could reveal racial or ethnic origin, political opinions and/or trade union membership, religious or philosophical beliefs, healthcondition or sex life or sexual orientation) as well as data relating to family members, if not relevant in relation to the job offer and/or if not strictly necessary;
  3. give your consent to the processing using following statement: “In accordance with national and European law on data protection and privacy I hereby authorize you to process my personal data including any sensitive information that I have voluntarily provided to you through my CV and for the purpose of personnel search and recruitment”.

In case of substantial modification to this Privacy Policy and to the related data processing the User shall be informed and shall have the right to decide whether or not to authorize us to process his/her personal data for the purposes set out below.

 

SOURCES OF PERSONAL DATA
Personal data collected from the Data Subject:

  • Data Controller’s main offices
  • Web pages and/or Social Media Profiles of the Data Controller.

 

CATEGORIES OF DATA SUBJECTS
  • Unsolicited applications.
  • Applicants (persons with potentially objective and subjective work characteristics that meet the requirements of a personnel recruitment and selection process).

 

PURPOSE OF DATA PROCESSING DESCRIPTION OF PURPOSE AND LAWFULNESS OF PROCESSING DURATION OF THE PROCESSING AND DATA RETENTION PERIOD
1Recruitment.
 Purposes related to personnel recruitment and selection.

Unsolicited applications:

  • Storage of work profiles that could be useful for future personnel search and selection.

Applicants:

  • Data processing and possible disclosure to authorized parties involved in the processing, only if necessary;

Lawfulness of processing:

  • Consent (expressed in the CV);
  • Implementation of pre-contractual measures
  • For a periodstrictly necessary until the first personnel recruitment and selection procedure and data retention for a maximum period of 24 months.
  • For a period of time strictly necessary for the correct and complete management of the personnel recruitment and selection process; Possible retention period at the Data Controller’s discretion, until the next personnel recruitment and selection procedure and for a maximum period of 24 months.
2.Communication between the Group companies Transfer of personal data for recruitment and selection purposes, within the multinational group to which the company belongs.

Lawfulness of processing:

  • Legitimate interest of the Data Controller;
  • Consent is not required.
  • Contract duration (for the Data Controller) and upon termination, data retention occurs in compliance with the legal requirements in force in the Country of location (of the Recipient of the communication or Parent Company).
3.Rights of defence Establishment, exercise or defence of the Data Controller’s rights, where necessary, also in extra-judicial and judicial proceedings.

Lawfulness of processing:

  • Legitimate interest of the Data Controller;
  • Consent is not required.
  • Duation of extra-judicial and judicial litigation until the time limits for appeal proceedings have been exhausted; Retention period in compliance with the legal requirements.

 

CONTACT METHODS FOR MARKETING PURPOSES
Traditional contact methods:

  • Phone
  • Traditional mail.

Automated contact methods:

  • Text messages (SMS);
  • E-mails;
  • Video calls;
  • Chat and messaging (WhatsApp and other similar Instant Messaging solutions);
  • Data collection form in Web pages and/or Social Media Profiles of the Data Controller.
  • Recruitment Advertising delivered through specific web portals.

 

DATA RECIPIENTS
Data may be shared with and processed by external parties acting as Data Controllers such as, by way of example:

Italy:

a.Supervisory and monitoring Authorities and Bodies;
b.Judicial and Police Authorities;
c.Public bodies, the Italian National Social Security Institute, the Italian National Institute for Insurance against Accidents at Work, the Italian provincial or territorial Labour Inspectorate;
d.Italian Local Health Authority, Occupational Medicine and healthcare professionals’ organisations;
e.Employment services, vocational training and certification institutions;
f.Professional and inter-professional funds;
g.Insurance companies, Social Security Funds or Health insurance, both public and private.
h.Banking institutions;
i.Financial institutions;
j.Experts/assessors and loss adjusters;
k.Law firms;
l.Persons/entitiesproviding professional consultancy services also in partnership;
m.Persons/entitiescarrying out professional recruitment and selection services;
n.Persons/entitiesproviding ICT services (Hosting/Data Center).

European Union:

o.Companies, even foreign ones, that are associated or belong to the Group or to the Parent company LINCOTEK GROUP S.P.A. (Italy), also considering the existence of telematic IT links or of correspondence (Lincotek Surface Solution –Lincotek Medical –Lincotek Equipment);
p.Persons providing ICT services (Hosting/Data Center); companies within the LINCOTEK GROUP S.P.A. (Italy);
q.Persons/entitiesproviding ICT services (Hosting/Data Center);Switzerland:
r.Companies, even foreign ones, that are associated or belong to the Group or to theParent company.

USA:

s.Companies, even foreign ones, that are associated or belong to the Group or to theParent company.

China:

t.Companies, even foreign ones, that are associated or belong to the Group or to theParent company.

 

Personal data may also be processed by external parties appointed as Data Processors acting in the name and on behalf of the Company, after having received adequate operative instructions. The above-mentionedexternal parties are included in the following categories:

Italy:

u.Persons/entities carrying out professional recruitment and selection services;
v.Persons/entitiesproviding professional consultancy services also working in service business or in partnership;
w.Persons/entitiesconducting monitoring auditing and certification activities
x.Persons/entitiesproviding IT, ICT, Cloud, Web and Digital Marketing services;
y.Persons/entities providing credit collection services;
z.Persons/entities providing digital and physical archiving services and electronic storage;
aa.Persons/entities providing mailing services and electronic mail services;
bb.Persons/entitiesproviding market research support services;

 

OBLIGATION TO PROVIDE PERSONAL DATA
With regard to the personnel recruitment and selection process, the provision of personal data, including the sensitive data, is a statutory requirement, thereforefailure to provide such data as well as incorrect, incomplete or inaccurate data will cause the impossibility to manage the recruitment and selection process.

 

PARTIES AUTHORIZED TO PROCESS THE PERSONAL DATA
Personal data may be processed by employees and collaborators in their functions, including the recipients of the communications, responsible for the fulfilment of the above-mentionedpurposes, that have been expressly authorised to process the personal data after having been informed and appropriately trained and after having received adequate operative instructions

 

TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES
Personal data may be transferred to countries outside the EEA, in particular to

  • Switzerland: Level of personal data protection being considered as adequate by a decision of the European Commission (Art. 25, paragraph 6, Directive 95/46/EC and Art. 45, paragraph 3 of GDPR)
  • USA and China: the Personal data of Data subjects who are outside the EU/EEA shall be transferred to other parties on the basis of their territorial competence corresponding to the same area to which the Data Subject belongs
    For this reason, pursuant to Art. 3, paragraph 2 of GDPR, the Regulation is not applicable and the personal data protection law in force in the States where the Data Recipientsreside will therefore apply.

A copy of your personal data maybe obtained by following the instructions provided in the following section “Rights of the Data subject –Lodge a complaint with a Supervisory Authority”

 

RIGHTS OF THE DATA SUBJECT -LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
By writing an e-mail to privacy@lincotek.com, Data subjects have the right to obtain from the Data controller access to their personal data, blocking of data processing and subsequent data anonymization, rectification of inaccurate personal data, completion of incomplete personal data, restriction of their processingin the cases provided for in Art. 18 of GDPR, as well as objection to data processing in the event of Legitimate interest of the Data Controller.
The Data Controller shall provide Data subjects with all relevant information on their requests to exercise their rights (pursuant to Articles 15 to 22 of GDPR) without undue delay and, in any case, no later than one month after the receipt of such request, as provided for by Article 12 of GDPR.
Furthermore, when processing is based on consent or on the contract and occurs by means of automatic data processing equipment, the Data subject shall have the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data controller without hindrance, where technically feasible, (Right to data portability) as well as to obtain the permanent erasure of such data (Right to erasure /”Right to be forgotten’).
Where processing is based on consent for one or more than one purposes (Art. 6, Paragraph 1, Letter A of GDPR) or for processing special category data (Art. 9, Paragraph 2, Letter A of GDPR) withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Data subjects shall have the right to lodge a complaint with a Supervisory Authority of the Member State in which they are habitually resident or work, orof the place where the alleged violation took place.