Informative guide

Informative guide on the processing of personal data Spontaneous applicants for the 'A2A Life Ventures' project

Pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016¹ (hereinafter "Privacy Regulation"), you are request to take note of the following information regarding the processing² of your personal data.

1. Who processes the personal data?

The data controller of personal data (hereinafter also the "Data Controller") is A2A S.p.A., with registered office in Brescia, via Lamarmora 230, tax code and registered with the Brescia Register of Companies no. 11957540153, registered under no. 493995 R.E.A. at the Brescia Chamber of Commerce.

2. Who can be contacted?

For all questions concerning the processing of personal data and the exercise of your rights, you may contact the Data Protection Officer (DPO) at the e-mail address: dpo.privacy@a2a.it.

3. Why are personal data processed?

Purpose of processing	Legal basis for processing
To carry out the activity of selecting spontaneous applicants to be included with different forms of employment relationship (e.g. open-ended contract, apprenticeship contract, fixed-term contract, work administration, etc.) within the scope of the development of projects deriving from the "A2A Life Ventures" Programme. For the same purpose applicants may participate through video interviews.	The execution of your request to take part in the selection (attributable to the legal basis under Art. 6 c. 1 letter b, i.e. execution of a contract to which you are party or execution of pre-contractual measures carried out at your request). Conducting video interviews is based on the legitimate interest of the Controller in: - reducing selection time; - collecting additional elements that will contribute to the assessment of the applicant; - giving the applicant a better experience.
To carry out, if necessary, the processing of your special personal data (health-related data) for the purposes of personnel selection.	The fulfilment of obligations and/or the exercise of rights in the field of labour and social security law and social protection.
To investigate public lists of economic measures and sanctions (e.g. OFAC lists).	The legitimate interest of the Controller in carrying out the investigations.
The processing may be used for the purpose of answering requests from competent authorities and bodies.	Fulfilment of a legal obligation.

4. Which personal data are processed?

The following categories of data are processed:

identification and personal data (e.g. first name, surname, tax code, address, date and place of birth);
contact details (e.g. telephone numbers, landline and/or mobile, e-mail address);
educational and professional curriculum vitae provided directly by the person concerned;
any image data and voice data (in the case of remote testing, interviewing and assessment);
any special data revealing health status;
other data falling into the above categories.

5. How are data processed?

Processing is carried out by authorised personnel in the performance of their duties, with or without the use of electronic means, in accordance with principles of legitimacy and fairness so as to protect the confidentiality and rights of the person concerned at all times.
The interested party is requested to provide only the data strictly necessary for the purposes of the selection, in particular data concerning health status. Should the Controller receive data that is not relevant to the selection, it will proceed to its deletion.
For selection purposes, video interviews may be conducted with applicants.ì

6. To whom are personal data communicated?

Your personal data may be made available to:

document storage companies, computer service companies, who will act as data processors;
analysis laboratories and medical practices for carrying out any preventive medical examinations pursuant to Legislative Decree No. 81/2008 (in the event that, after the selection process, a recruitment process is foreseen), which will act as Data Controllers or Data Processors, as the case may be;
Competent authorities and bodies (where required) that will act as data controllers.

7. Are data transferred to third countries?

Your personal data will be processed, for the most part, within the European Economic Area ("EEA"). For any transfers, the appropriate safeguards provided for under the Privacy Regulation and in particular the standard data protection clauses adopted by the European Commission shall apply.

8.How long are the data kept?

Your data will be kept for the time necessary to achieve the purposes for which they are processed or to comply with legal obligations and in particular:

the data of applicant(s) not involved in the selection process (who spontaneously sent their CV but never participated in the selection processes initiated by the Controller) for 3 years after the collection of your data;
the data of applicants inserted in selection processes (who have been contacted by the Controller) for 5 years from the end of the selection process;

In the event of litigation, all of the above retention periods may be extended up to 10 years from the settlement of the litigation.

9. Which rights can you exercise?

You have the right to ask the Data Controller:

for confirmation as to whether or not your personal data are being processed and, if so, to obtain access to them (right of access);
for rectification of inaccurate personal data or to supplement incomplete personal data (right of rectification);
for deletion of the data if one of the reasons provided for in the Privacy Regulation (right to be forgotten) exists;
for limitation of processing when one of the hypotheses provided for in the Privacy Regulation applies (right of limitation);
to receive in a structured, commonly used and machine-readable format the personal data you have provided to the Controller and to transmit such data to another Controller (right to portability).

Right to object. We also inform you that, at any time, you may object to the processing carried out for purposes related to the legitimate interest of the Controller. In this case, the Controller will refrain from further processing your personal data, unless there are compelling legitimate grounds for processing or for the establishment, exercise or defence of legal claims before the competent jurisdiction.

In order to exercise your rights and request further information in relation to the processing in question and the transfer of personal data outside the European Economic Area, you should send a written request to the Data Protection Officer, at the e-mail address dpo.privacy@a2a.it

or directly to the attention of A2A S.p.A., at the address: via Lamarmora 230, Brescia, specifying that the request concerns data relating to your application within the scope of the "Call for Venture" initiative (for example, by inserting "Privacy request on Call for Venture Application" in the subject line).
Without prejudice to any other administrative or jurisdictional recourse, you have the right to lodge a complaint with the Italian Data Protection Authority if you consider that the processing concerning you violates the Privacy Regulation.

10. What is the source of the personal data?

The personal data requested for the aforementioned purposes are provided directly by you. Failure to provide the same prevents the Controller from considering your application and continuing the selection process.

11. Are data subject to automated decisions?

Your data will not be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning or significantly affecting you.

Notes:

General Data Protection Regulation (GDPR).
Processing shall mean any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic 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.

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