Personal data processing policy

Personal data processing policy

Information and express statement of consent to personal data processing for candidates

Dear Candidate,

this is to inform you that, pursuant to Articles 12 and 13 of EU Regulation 2016/679 on “Protection of individuals with regard to the processing of personal data and the free movement of such data” and subsequent amendments (hereinafter the “Regulation”), within the context of the selection process commenced with the Fondazione Human Technopole, hereinafter referred to as “HT”, the above-mentioned Foundation manages a series of personal data related to you.


1. Identity and contact details of the Data Controller

The Data Controller of your personal data is the Fondazione Human Technopole, based in Via Cristina Belgioioso s.n.c., - 20157, Milan (Italy), Phone no. +39/02-30247001,


2. Purposes and legal basis of the data processing

Your personal data will be processed by HT for the purpose of managing the candidates selection process. In particular, the processing of your personal data will be carried out for the purpose of:


a. Data acquisition in the screening phase of the applications;

b. Evaluation of the appropriateness of the professional profile;

c. Conduction of cognitive interviews aimed at recruitment.


Once the selection process has been completed, the data will be stored exclusively for precautionary purposes for the management of any litigation related to the selection process and the protection of HT’s rights.

The legal basis of data processing, for the purposes of lett. a., b. and c. consists of Articles 6, letter b) of Regulation, “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.

With specific reference to the aforementioned special categories of personal data, as for example those related to state of health, if included in the Curriculum Vitae or obtained during the selection process, the legal basis of the processing consists of Article 9, letter a) of this Regulation, “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject”.

With reference to the conservation after the end of the selection process, Article 6, paragraph 1, lett. f), “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”.


3. Nature of the data processed

Within the framework of the selection procedures, HT may process the following categories of data relating to you:

  • Common personal data such as, for example, name, surname, tax code, e-mail address, telephone number;
  • Special categories of personal data such as, for example, data concerning health and data revealing trade union membership.


4. Processing methods

Your data will be processed by computer and paper support, following the rules on protection of personal data, including those related to data security.


5. Categories of recipients of personal data

The data you have provided may be disclosed to public and private entities relevant to the purposes mentioned above.

The communication of personal data is carried out on the basis of the obligations provided by law.

Your data may be communicated to persons appointed by HT as External Data Processors for purposes strictly related to the management of selection process. Your personal data could also be disclosed to the Company that is in charge of the hosting services that is providing one virtual Server; of the aforementioned Server installation, configuration and maintenance services; of the website’s maintenance’s service; the technical help-desk and the back-up/restore services,
necessary to guarantee the optimal functioning of the website.

Furthermore, the HT’s obligation to communicate data to the Judicial Authority remains in place, whenever, in this regard, a specific request is sent.


6. Data Storage

The storage of your personal data will take place in compliance with the security measures used by HT on data protection, and access to them will be allowed only to the staff involved and duly appointed to process data.

Your data will be stored at HT’s premises and at the hosting infrastructure made available by the Company referred to in point 5, consisting of a virtual Server located in Germany. Your data will not be transferred outside the EU.

Considering that the communication of your data has been made with exclusive reference to a specific position, the collected data will be eliminated from any IT and / or paper support, with the exception made for the conservation set out in the following period, once the present selection process has been completed, unless otherwise indicated by you.

Following this event, in order to protect HT’s rights, the data will be stored - so as to be accessible only if necessary - for a period of time corresponding to the limitation period of rights that you may have against HT. This period, usually corresponding to 24 months for the selection processes, may vary according to the type of data and the possible intervention of interruptions or suspensions of the prescription itself.


7. Rights of Data Subject

You may exercise the rights provided in Article 13, letter b) and in Articles 15, 16, 17, 18 and 20 of the Regulation at any time by contacting the Data Controller, to the contact point referred to in point 1 of this Information.  In particular, as data subject, you can request:

1. access to your personal data, as provided in Article 15 of the Regulation;

2. correction of your personal data, as provided in Article 16 of the Regulation;

3. cancellation of your personal data (“right to be forgotten”), as provided in Article 17 of the Regulation;

4. restriction of personal data processing, as provided in Article 18 of the Regulation.


Furthermore, we inform you that you can object to the processing of data at any time, pursuant to Article 21 of the Regulations, in case one of the situations mentioned in Article 6, paragraph 1, letters e) and f) of the same Regulation occurs.


8. Consent and withdrawal

You can withdraw your consent at any time by contacting the Data Controller.


9. Complaint to the Supervisory Authority

Finally, pursuant to Article 77 of the Regulation, we remind you that you have the right to submit a complaint to the Supervisory Authority (Protection Authority for Personal Data Processing), if you believe that your data processing infringes the provisions of the Regulation.


10. Nature of the processing and obligation of providing data

The data required are necessary (even in fulfilment of obligations coming from legal rules) to selection process related to the potential recruitment. Failure to provide these data may result in conclusion of the selection process and the exclusion from the selection process.


11. Existence of automated decision-making processes in the data processing

It is specified that for processing of the above data there is NOT any type of automated decision-making process, pursuant to Article 22 of the Regulation.