Information on the processing of personal data in connection with job applications pursuant to Art. 13 of the GDPR

Transparency and confidentiality in connection with the processing of your personal data are the basis for a solid working relationship. Therefore, Rheinmetall Italia S.p.A. (or ‘Rheinmetall Italia’) as data controller informs you about how we process your data and which rights you can exercise according to the European General Data Protection Regulation (GDPR) and current Italian law. The following information will give you an overview of how we collect and process your personal data in connection with your application for a position with our company.

1 Who is the Data Controller?

Rheinmetall Italia S.p.A.

The electronic applicant management system is operated by Rheinmetall AG (our holding company) as a central recruiting service for handling the application process also for other Rheinmetall Group companies.

2 How can you contact us?

Address: Via Affile, n.102, Roma

E-Mail: privacy@rheinmetall.it  Phone: 0643612967

3 What personal data about you is used by our company?

We process your personal data in order to assess your application for possible employment or other relationship with Rheinmetall Italia S.p.A. or other Rheinmetall Group companies.

Among others, the data we process are:

• personal master data (e. g. name, surname, title);
• contact details (including private address, mobile phone, e-mail address);
• previous work experience;
• qualifications and education obtained;
• special data (if contained in your Curriculum Vitae).

Special categories of personal data (information on political opinions, religious and ideological beliefs, trade union membership, health or sexual orientation, genetic and biometric data) are not requested or collected by Rheinmetall Italia (with the exception of voluntary information on severe disabilities). Consequently, we ask you not to provide information related to the aforementioned subjects in the context of your application.

If the nature of the position/job requires special information, we might request additional documents or inputs such as:

• Certificates of pending charges and criminal records;
• Aptitude and knowledge tests or tests;
• Medical fitness examination (fit, unfit, conditionally/limitably fit);
• NOS;

The provision of such personal data is not required by law or contract, nor is the user obliged to provide it. However, it may be necessary for the execution of the application process. This means that if you do not provide us with the personal data requested at the time of application, we will not be able to complete the application process.

These data will be collected regularly for and in the course of the evaluation and selection procedures of your application for possible employment at Rheinmetall Italia.

4 What is the source of the data?

Your personal data are collected for and in the course of the evaluation and selection procedures of your application for possible employment at Rheinmetall Italia.

Please also note that we may have received your data from Third Parties including Recruitment Companies and Employment Agencies.

Should you be considered in the application process, we may have to check official sanctions and terrorist lists. In addition, for some positions, we could check and validate your data and information provided by you, in which case you will be informed separately during the application process. If necessary, we may verify your information by also carrying out searches with the employers you have indicated and by searching on Google, LinkedIn and other social media platforms.

5 For what purposes do we process your personal data and on what legal basis?

We process your personal data in accordance with the European General Data Protection Regulation (EU Regulation 2016/679 GDPR) and applicable Italian law in order to proceed with the verification of the skills necessary for employment or for the beginning of a working relationship with Rheinmetall Italia, as well as for purposes connected with or instrumental to the performance of the activity of search and selection of candidates. The main legal basis for this is Art. 6 (1) lit. b GDPR.

The necessity and extent of data collection are determined, inter alia, by the position to be filled. If the position being applied for is associated in particular with the performance of particularly confidential tasks or with greater personal and/or financial responsibility, or is linked to certain physical and health requirements, more extensive data collection may be necessary. Such data collection or special procedures (e.g. aptitude test, police clearance certificate, pre-employment screening) usually take place only at the end of the application process or immediately before employment and are accompanied by separate information.

In some cases, we also process your data to protect our legitimate interests or those of third parties, for example, to pass your data on to other companies of the Rheinmetall Group or to perform due diligence checks, insofar as this is necessary to complete the application process. The main legal basis here is Art. 6 (1) lit. f GDPR.

In addition, we  could perform certain data processing activities, in particular  to compare your data with official sanctions and anti-terrorism lists (in accordance with EU regulations 2580/2001 and 881/2002). The legal basis here results from our legitimate interests based on Art. 6 (1) lit. f GDPR.

In some cases, we also process your data on the basis of your voluntary consent. In this case, your consent in accordance with Article 6 (1) lit. a GDPR is the legal basis for the respective data processing.

We process data on the basis of your consent in particular for:

• voluntary inclusion in the candidate pool (so-called ‘Talent Pool’), i.e. storage of your application documents beyond the current application process, in order to consider you for further or subsequent positions (for more details, see Section 13 of this Policy);
• satisfaction survey in relation to the application process (for more details, see Section 14 of this policy).

6 For what purpose do we process your special data and on what legal basis?

We may also process special categories of personal data, in accordance with Article 9 of the GDPR, such as health data strictly necessary for employment or relating to membership of certain protected categories, if they are included in your Curriculum Vitae.

If you have disclosed special categories of personal data to us which we have not specifically requested, the collection and storage is based on Art. 9 (2) lit. e GDPR. Further processing by us will not take place.

7 To whom are your data transmitted?

Your personal data will be processed by the persons/departments expressly appointed by the Data Controller, belonging to the Corporate Functions within Rheinmetall Italia or – if necessary – of other Rheinmetall Group companies such as Recruiting, HR, IT, Administration, and, if necessary with reference to the position for which you are applying, to other Functions relevant to that position.

Moreover, with your explicit consent, some of your personal data, such as your name, surname, e-mail address and qualification, may be sent to external companies in order to carry out further tests and assessments on your skills.

The electronic applicant management system is operated as "software as a service" by an IT service provider, which means that the latter could also gain access to the system and thus po-tentially to your data in the course of maintenance and service activities. Appropriate data protection and confidentiality agreements have been concluded with the service provider.

8 Is your data transferred to countries outside the European Union (third country transfer)?

In general, your personal data is processed within the European Union by Rheinmetall Group Companies and is not transferred outside the European Union.

The applicant management system is operated for Rheinmetall Italia as part of a commissioned data processing in accordance with Art. 28 GDPR.  As this system is used worldwide for Rheinmetall as an internationally active group, it is hosted by our IT service provider (processor) at Amazon Web Services EMEA SARL, Luxembourg (AWS Europe) with servers located within the EU.

The applicant management system stores and transmits the data in encrypted form. To ensure an adequate level of data protection, the service provider has also entered into EU standard data protection clauses with AWS pursuant to Article 46 (2) c of the GDPR.

9 How long will your data be stored?

In the event that the evaluation process of your application does not result in the establishment of an employment relationship with you, your personal data provided for the above-mentioned purposes shall be kept for a maximum of 18 months from the date of the termination of the above-mentioned process, in order to allow Rheinmetall Italia Italy to evaluate your application for future positions that become available and that are compatible with your Curriculum Vitae.

If, on the other hand, the selection process ends with the establishment of an employment or other relationship with Rheinmetall Italia, the processing of your personal data shall be in accordance with the terms of the information notice that will be provided by Rheinmetall Italia at the time of the establishment of said relationship.

In the event of voluntary inclusion in the Talent Pool (see Section 13) and the associated stor-age of your personal data, the data will be deleted after 8 months, but with the provision that we will generally request an update of your consent to remain in the Talent Pool from you 30 days before the 8-months period expires. If you do not respond to this request or do not update your consent, we will remove you from the Talent Pool and delete your personal data and your applicant profile.

10 Processing by automated processes or profiling measures

We do not use automated processing or profiling measures to make a decision on the establishment, performance or termination of an employment relationship.

11 Exercise of Your Rights      

As the data subject of your personal data processed by Rheinmetall Italia, you have and may exercise at any time the right of access to the data pursuant to Article 15 GDPR, the right to rectification pursuant to Article 16 GDPR, the right to erasure pursuant to Article 17 GDPR, the right to restriction of processing pursuant to Article 18 GDPR, the right to object pursuant to Article 21 GDPR and the right to portability pursuant to Article 20 GDPR.

11.1. Right of access

You have the right to request information on the storage of your personal data and you have the right to obtain confirmation as to whether or not personal data concerning you exist and, if so, to obtain access to and a copy of such data. You have the right to obtain information on the source of your personal data, the purposes and methods of the processing of your personal data, the identification details of the Data Controller, the Governance Representative and, if appointed, the Persons in charge, the subjects or categories of subjects to whom the personal data may be communicated and the storage period established for the processed data.

11.2. Withdrawal of consent

You may withdraw your consent to the processing of your personal data at any time. Such withdrawal of consent shall not affect the lawfulness of the processing based on the consent before the withdrawal.

11.3. Right to object

Pursuant to Art. 21 (1) GDPR, you have the right to object at any time to the processing of your personal data collected under Art.6 (1) (e) GDPR (processing of data for the performance of a task carried out in the public interest) or Art.6 (1) (f) GDPR (processing of data for the pursuit of the legitimate interest of the data controller) on grounds arising from your particular situation.
If you object to the processing, we will no longer process your personal data unless we can demonstrate compelling reasons to justify our legitimate interest, or if the processing is necessary for the exercise or defence of legal claims.

11.4. Further Rights

What are your rights when data is processed on the basis of legitimate interest?

In addition, you have the right to request the correction or deletion of inaccurate data. If there is no reason for further storage, we will delete your data, otherwise we will proceed with the restriction of processing pursuant to Article 18 GDPR. You may also request to receive any personal information you have provided to the us in a structured, common and machine-readable format to another person or company of your choice.

11.5.  Right to lodge a complaint with a Supervisory Authority

In addition, you have the right to lodge a complaint with the Data Protection Authority (pursuant to Article 77 GDPR) or appeal to a judicial authority pursuant to Article 79 GDPR.

11.6. Exercising your rights

In order to exercise your rights as a data subject, you may submit a request, even informal, to the Privacy Function, through the e-mail address privacy@rheinmetall.it  or the PEC address privacy@pec.rheinmetall.it . Such requests will be handled in compliance with the timeframe provided for by the applicable legislation.

12 Is there an obligation to provide personal information?

The provision of data by the Candidate is optional and depends on the Candidate's willingness to submit his/her curriculum vitae and application data. With regard to the data subsequently and eventually requested by the Data Controller, failure on the part of the Candidate to provide, in whole or in part, personal information necessary for the verification of the skills and indispensable conditions with reference to the job position being sought, will prevent Rheinmetall Italia Italy to carry out the activities necessary for the establishment of the eventual working relationship and/or the impossibility of taking you into consideration for available positions that are compatible with your Curriculum Vitae.

13 Inclusion in the Talent Pool

As part of the application process, we will check the possibility of including you in our Talent Pool. This is a database in which candidates' data is stored in order to be able to consider them directly in the future for suitable job offers. At the start of your application, you may voluntarily consent to your inclusion in the Talent Pool (legal basis: Art. 6 (1) letter a GDPR). In the event of a transfer of your application data to a Rheinmetall Group company outside the EU, your consent also forms the legal basis for this transfer (Art. 49 (1) lit. a GDPR).

14 Satisfaction survey

In order to improve our recruitment process, we will ask you during the application process if you would like to participate in an online survey. If you agree, we will send you an online questionnaire by e-mail and ask you for your opinion.

The legal basis for this data processing is Art. 6 (1) letter a GDPR.

Participation in the survey is voluntary and anonymous. For this reason, please do not provide any personal data (e.g. names, natural persons) in the free text fields.

You may also refuse or revoke your consent at any time with future effect. To this end, you can contact us at the following e-mail address: privacy@rheinmetall.it.

15 Job Alert

On our career pages, you have the opportunity to subscribe to a ‘Job Alert’. This is a search agent that automatically informs you by e-mail about new job offers (based on previously defined search criteria).

In this context, your e-mail address and job search criteria will be processed. You can specify the duration of the job advertisement when registering. You can also unsubscribe at any time via a link in the ‘job alert e-mails’. Alternatively, you can also unsubscribe by e-mail to privacy@rheinmetall.it. 

Our IT service provider, who is also responsible for managing our electronic applicant management system, sends out the ‘Job Alert’ and processes this data.

16 Miscellaneous

We reserve the right to adapt this Privacy Policy if changes in the legal situation or in our data processing make this necessary.

When you visit our website, only the most recent privacy policy applies.

If necessary and possible, we will inform you if any changes require your involvement (e.g. renewal of consent) or individual notification.

The addresses and contact information of other companies that we have provided in this privacy policy may change over time.

 

Rheinmetall Italia S.p.A.

Transparency and confidentiality in connection with the processing of your personal data are the basis for a solid working relationship. Therefore, Pierburg Pump Technology Italy S.p.A. (or “PPT Italy S.p.A.”) as Data Controller informs you about how we process your data and which rights you can exercise according to the European General Data Protection Regulation (GDPR) and current Italian law. The following information will give you an overview of how we collect and process your personal data in connection with your application for a position with our company.

1 Contact details of the Data Controller

Pierburg Pump Technology Italy S.p.A

Address: località Cerratina, Lanciano

E-mail: infoppt@it.rheinmetall.com

Phone: 0586 2551

The electronic applicant management system is operated by Rheinmetall AG (our holding company) as a central recruiting service for handling the application process also for other Rheinmetall Group companies.

2 Contact details of the Data Protection officer

privacy@it.rheinmetall.com

3 Categories of personal data

We process your personal data in order to assess your application for possible employment or other relationship with PPT Italy S.p.A.

Among others, the data we process are:

• Personal master data (e. g. name, surname, title);
• contact details (including private address, mobile phone, e-mail address);
• previous work experience;
• qualifications and education obtained;
• special categories of data (possibly indicated in your resume) strictly necessary for the application of regulations that recognize benefits, disbursements and/or rights for various reasons (e.g. any membership in protected categories).

Please notice that, with the exception of this information, no other special categories of personal odata must be provided (revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation).

If the nature of the position/job requires special information, we might request additional documents or inputs such as:

• Aptitude and knowledge tests;
• Medical examination (fit, unfit, conditionally/limitably fit);

The provision of such personal data is not required by law or contract, nor is the data subject obliged to provide it. However, it may be necessary for the execution of the application process. This means that if you do not provide us with the personal data requested at the time of application, we will not be able to complete the application process.

4 Data sources

Your personal data is collected for and during the evaluation and selection procedures of your application for the purpose of your possible employment in our Company/Group.

We also inform you that we may have received some of your data from Third Parties, including Recruitment Companies and Employment Agencies.

If you are considered in the application process, we may verify your information by also searching Google, LinkedIn and other social media.

5 Purposes and legal basis of the data processing

All personal data provided by you on the application platform or in the application process (including data resulting from any of your attachments) will be processed exclusively for the purpose of carrying out the application process and for the purposes specified in this privacy information.

We process your personal data in accordance with the GDPR and current Italian legislation in order to proceed with the verification of the skills necessary for hiring or for the start of a working collaboration with PPT Italy S.p.A., as well as for purposes connected or instrumental to carrying out the search and selection of candidates. The main legal basis for this is Art. 6 (1) lit. b GDPR.

The processing is primarily based on the execution of pre-contractual measures adopted at your request (Art. 6 (1) lit. b GDPR), as well as on the pursuit of the legitimate interest of the Data Controller to collect information from public sources in order to better evaluate your application (Art. 6 (1) lit. f GDPR). The provision of such data is necessary to participate in a possible selection procedure.

The processing of special categories of data is necessary to fulfil the obligations and exercise the specific rights of the Controller or the Data Subject in the field of labour law, social security and social protection; failure to provide such data will make it impossible for the Data Controller to recognize any benefits and/or rights provided for by applicable legislation. The main legal basis for this is Art. 9 (2) lit. b GDPR.

The need for and extent of data collection is determined, among other things, by the position to be filled. If the position you are applying for is associated in particular with the performance of particularly confidential tasks or increased personal and/or financial responsibility, more in-depth data collection may be required. Such data collections or special procedures (e.g., aptitude tests) usually only take place at the end of the application process or immediately prior to hiring and are accompanied by different privacy information.

In some cases, we also process your data to protect our legitimate interests or those of third parties, for example, to transmit your data to other companies of the Rheinmetall Group or to perform due diligence checks, insofar as this is necessary to complete the application process. The main legal basis here is Art. 6 (1) lit. f GDPR.

In some cases, we also process your data on the basis of your voluntary consent. In this case, your consent pursuant to Art. 6 (1) lit. a GDPR constitutes the legal basis for the respective data processing.

We process data on the basis of your consent, in particular for the voluntary inclusion in the pool of candidates (so-called "Talent Pool";For more details, see Article 9 of this policy) or for the performance of satisfaction surveys in relation to the application process (for more details, see Article 11 of this policy).

6 Recipients of the personal data

The personal data you provide will be processed by appointed personnel, suitably trained and operating under the authority and responsibility of the Data Controller. Personal data may also be processed by third parties who provide instrumental services, including personnel selection services, e-mail and mail delivery. Personal data may also be communicated to the parent company and to the other companies of the Rheinmetall Group. These communications are carried out in the legitimate interest of the group to share data and information and unify tools and procedures used in the processing.

The above-mentioned recipients will receive only the data strictly necessary for the performance of their functions. The updated list of all recipients is available at the headquarters of the Data Controller and will be provided upon your request by writing to the following e-mail address privacy@it.rheinmetall.com

The applicant management system, which is used by all Group companies, is operated by Rheinmetall AG via an IT service provider (Data Processor) and hosting services of Amazon Web Services EMEA SARL, Luxembourg (AWS Europe) with servers located within the EU. The applicant management system stores and transmits the data in encrypted form. To ensure an adequate level of data protection, the service provider has also entered into the EU standard data protection clauses with AWS in accordance with Article 46 (2) lit. c GDPR.

Insofar as the advertised position relates to employment in a Group company outside the European Union or the European Economic Area ("EEA") or your technical supervisor works outside of the EEA, your personal data will also be transferred to this Group company. To protect your data, we take special measures to ensure that your personal data is processed by us in the third countries as securely as within the European Union.

7 Retention period

If the evaluation process of your application does not end with an employment relationship, your personal data provided for the aforementioned purposes will be stored for a maximum of 18 months from the date of the termination of the aforementioned process.,

If, on the other hand, the selection process ends with an employment relationship, the processing of your personal data will take place in accordance with the privacy information that will be provided by PPT Italy S.p.A. during the signing of the contract.

In the event of voluntary inclusion in the Talent Pool (see Article 9) and the associated storage of your personal data, the data will be deleted after 8 months, but with the provision that we will generally request an update of your consent to remain in the Talent Pool 30 days before the eight-month period expires. If you do not respond to this request or do not update your consent, we will remove you from the Talent Pool and delete your personal data and your applicant profile.

8 Your rights

As a Data Subject, you have the right to ask the Data Controller for access to data concerning you, their correction or erasure, the integration of incomplete data, the limitation of processing; to receive the data in a structured, commonly used and machine-readable format; to withdraw your consent and to object, in whole or in part, to the use of the data, as well as to exercise the other rights recognized to you by the applicable regulations.

What are your rights when data is processed on the basis of legitimate interest?

Pursuant to Art. 21 (1) GDPR, you have the right to object at any time to the processing of your personal data collected under Art.6 (1) (e) GDPR (processing of data for the performance of a task carried out in the public interest) or Art.6 (1) (f) GDPR (processing of data for the pursuit of the legitimate interest of the data controller) on grounds arising from your particular situation.

If you object to the processing, we will no longer process your personal data unless we can demonstrate compelling reasons to justify our legitimate interest, or if the processing is necessary for the exercise or defence of legal claims.

You can exercise your rights by writing to the following e-mail address: privacy@it.rheinmetall.com.

Pursuant to art. 77 GDPR, you also have the right to lodge a complaint with the Data Protection Authority in the event that you believe that the processing violates the aforementioned GDPR.

9 Inclusion in the Talent Pool

As part of the application process, we will check whether you can be included in our Talent Pool. This is a database, shared globally with the companies of the Rheinmetall Group, in which the data of candidates is stored in order to be able to consider them directly in the future for the most suitable job offers. At the beginning of your application, you can voluntarily consent to the inclusion in the Talent Pool (legal basis: Art. 6 (1) lit. a GDPR). In the event of a transfer of your application data to a Rheinmetall Group company outside the EU, your consent also forms the legal basis for this transfer (Art. 49 (1) lit. a GDPR).

10 Job Alert

On our career pages, you have the option to sign up for a "Job Alert". This is a service that automatically informs you by e-mail about new job offers (based on the previously defined search criteria).

In this context, your e-mail address and job search criteria will be processed. You can specify the duration of the job alert at the time of enrollment. You can also unsubscribe at any time via a link in the "job alert emails". Alternatively, you can also unsubscribe by e-mail at privacy@it.rheinmetall.com

Our IT service provider, who is also responsible for the operation of our electronic applicant management system, sends the "Job Alert" and processes your data.

11 Satisfaction survey

In order to improve our recruitment process, we may ask you during the application process if you would like to participate in an online survey. If you agree, we will send you an online questionnaire by e-mail and ask you for your opinion.

The legal basis for this data processing is Art. 6 (1) lit. a GDPR.

Participation in the survey is voluntary and anonymous. For this reason, please do not provide any personal data (e.g. names, natural persons) in the free text fields.

You may also refuse or revoke your consent at any time with future effect. To this end, you can contact us at the following e-mail address: privacy@it.rheinmetall.com .

12 Miscellaneous  

We reserve the right to amend this Privacy Policy if changes in the legal situation or in our data processing make it necessary.

When you visit our website, only the most recent privacy policy applies.

If necessary and possible, we will inform you if any changes require your involvement (e.g., renewal of consent) or individual notification.