Policy on the processing of personal data of job applicants

In accordance with the regulatory provisions on the protection of personal data of natural persons of the European Regulation 2016/679 (hereinafter abbreviated as "GDPR") and Legislative Decree 196/2003 as amended by Legislative Decree 101/2018, we provide data subjects with information on the processing of their personal data as part of the evaluation of job applications.

Data Controller

The company Opto Engineering S.p.A. (hereinafter "Controller" or "Company") in the person of the pro tempore legal representative, is the Data Controller who determines the purposes and means of the processing of personal data. The Data Controller notifies data subjects of the processing of their personal data and informs them that pursuant to Article 37 of the GDPR it is not obliged to appoint a Data Protection Officer (DPO/RDP).

Contact details

Opto Engineering S.p.A.

Strada Circonvallazione Sud 15, 46100 Mantua - Italy

Phone +39 0376 699111 – e-mail [email protected]

Subjects concerned

Candidates for selection and evaluation for employment with Opto Engineering S.p.A. and its subsidiaries or affiliates.

Purpose of processing and legal grounds

The personal data acquired or collected will be processed for purposes related to the evaluation and selection of candidates for the establishment of a working relationship. The legal ground of the processing in accordance with GDPR art. 6 is based on the execution of precontractual measures at the request of the job applicant, or, in the case of a preliminary interview, on the execution of agreements with the applicant and in the legitimate interest of the Data Controller. The provision of personal data is optional: any non-communication, or incorrect communication of data, may result in the inability of the Controller to implement the intended purposes and to ensure the adequacy of processing.

Processing of special categories of personal data

During the assessment, the Data Controller may become aware of special categories of personal data as defined by art. 9 of the GDPR "health data and state of health, trade union or political affiliations, religious or philosophical opinions, bio-metric and genetic data": pursuant to Legislative Decree 101/2018, the processing of such data communicated by the data subject for the purposes of assessment for job placement is allowed without the need for consent, with the exclusion of genetic data that cannot be processed even with the consent of the data subject. In compliance with Article 9 of the GDPR, the processing of these data will be carried out only if necessary, while genetic and bio-metric data will not be processed in any case.

Processing and storage methods

The processing is done with manual procedures based on paper archives and with computer procedures and electronic tools based on digital archives, by staff authorized by the Controller pursuant to Art. 29 of the GDPR, or even by third parties (e.g. employment consultants) designated as our Processor under Art. 28 of the GDPR for the processing of competence; applications received through our website will be treated by our designated Data Processor, Intervieweb S.r.l with registered office at Via Beato Sebastiano Valfrè 16, 10121 Torino, company registered in the Register of Employment Agencies-Section IV (Personnel Search and Selection)-Aut. Min. Def.-Prot. 39/ 0005262/ MA004.A003.

Furthermore, to the extent necessary for the purpose of assessing job placement, the data may be transmitted to other companies of the Controller that are controlled or affiliated pursuant to Art. 2359 Civil Code, in accordance with the principles of Articles. 5, 6 of the GDPR and with the adoption of appropriate security measures. The retention period of resumes and other data of job applicants is established for the indicative time of twelve months from collection, after this period the person concerned may update their data through the web portal of transmission of the application, otherwise the existing ones will be deleted.

Opto Engineering does not accept CVs in paper format submitted directly by the data subject to any of the Group's offices.

Rights of the data subject

The data subject has the right to contact the Data Controller, at the addresses indicated in this document, to obtain information on the processing of their personal data. The data subject has the right to know the origin of personal data, the purposes and methods of processing, the logic applied in case of processing with the aid of electronic instruments, the identity of the Controller, Processor and the representative under Art. 5, c. 2, the subjects or categories of subjects to whom the personal data may be communicated or who may gain insight into them as appointed representative in the State, as Processor or agent. The data subject has the right to obtain the updating, rectification or, when desired, integration of data; the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; confirmation that the operations referred to in letters a) and b) have been brought to the attention, also as far as their content is concerned, of those to whom the data has been communicated or disseminated, unless this requirement proves impossible or involves a disproportionate use of means with respect to the protected right; portability of data. The interested party has the right to oppose, in whole or in part for legitimate reasons, the processing of personal data concerning themselves. The interested party also has the right to lodge a complaint, in the manner and within the terms provided, with the Authority for the protection of personal data: please visit the website www.gpdp.it for more details. For further details on the legislation on the protection of personal data, please visit the website www.gpdp.it/regolamentoue.