Privacy Statement for The SR Group (Italy) S.R.L.

The SR Group (Italy) S.r.l. with legal address in 20121 Milan, Via Giuseppe Mengoni n. 4, VAT number IT09322610966 (hereinafter “SR Group Italy”), is part of a global professional, specialist recruitment organisation that focuses on the Legal, HR, Tax and Marketing sectors trading under the names Brewer Morris, Carter Murray, Frazer Jones, SR Search and Taylor Root.

The SR Group Italy is committed to protecting your privacy and here we explain: how we collect your personal information and data (referred to in this policy as "personal information" and/or “personal data”); what we do with it; who we disclose it to; and which are your rights.

Please read this Privacy Statement carefully. Where you provide us with your personal information in person, by email, through our website or via any other method, you consent to the collection and use of this personal information by The SR Group Italy in accordance with this Privacy Statement.

Collecting your Personal Information
We may collect your name, e-mail address, postal address and telephone number, details of your current and previous employment history, work performance, education and training and we may retain a record of your correspondence with us.

There may be occasions when The SR Group Italy will source personal information from an external third party (e.g. your previous employer and referees), or from a publicly available source. You consent to the collection, use or disclosure of your personal data for the purposes of our carrying out checks with any previous employers, academic institutions or other references you may provide. Without prejudice to the preceding sentence, we will inform you according to the applicable law that we have or intend to collect personal information from the third party.

Purpose of your Personal Information

We collect your personal information so that we can:

  • provide you with information about job vacancies – to assist you in finding a suitable position;
  • provide you with recruitment services - which may include career guidance and management;
  • assist in managing our relationship with you and our clients and perform administration or operational functions to the extent it is necessary to provide you with the requested services;
  • to protect our company’s assets and/or to exercise and/or defend our company’s rights;
  • to comply with legal and/or regulatory obligations.

Upon your specific consent, we may also use that personal information for the following further purposes (hereinafter referred as “Further Purposes”):

  • to inform you of events, services and possible job opportunities by mail/email/sms/phone, further to those concerning the services that you have requested;
  • to carry out market research and marketing analysis; and
  • to directly market recruitment services to you to the extent permitted by the law

Providing your consent to the processing of your personal data for such Further Purposes is not mandatory and the lack of your consent may prevent us from using your personal information for these purposes.

If you have consented to such processing you have a right to opt-out and withdrawal your consent at any time, free of charge, by sending an email to dpo@thesrgroup.com

How is Personal Information Obtained?
Personal information may be obtained through our websites (e.g. when you submit your curriculum vitae or application) or via one of our recruitment consultants (when you send them your curriculum vitae or application or discuss a recruitment opportunity with them).

Although we do not make it compulsory to give us every item of information we ask for, the more information you volunteer (and the more accurate it is), the better we can tailor our services to your needs. If the Personal Information we have requested is not collected, we may not be able to provide the recruitment or other related services to you.

We may occasionally contact you via email with information about some of our other recruitment opportunities that we feel may be of interest to you. This will only come from The SR Group Italy and only if you have not objected.

Disclosure of Personal Information
We may use and disclose your personal information (including to trusted third parties) for the purposes for which it is primarily held or for a related or ancillary secondary purpose.

We may:
- for the purposes of providing recruitment services to you – pass your personal information to our employees or other parts of our group globally (including our subsidiaries, our ultimate holding company and its subsidiaries i.e. other related bodies corporate) and to other individuals and companies who assist us in supplying our services or who perform functions on our behalf (e.g. third parties where we have retained them to provide services that you or our clients have requested such as psychometric testing and reference/qualification checking);
- disclose or transfer your personal information to prospective employers or where you have otherwise agreed we may disc lose it;
- disclose your personal information to third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business systems; and
- in the event of a sale, merger, liquidation, receivership or transfer of assets - disclose your personal information to such third parties if they agree to only use your personal information for the purposes that you have provided it to us.

If the SR Group Italy discloses your personal information to any third party, we will require these parties to protect such personal information in the same way as we do.

We may disclose personal information, if required to do so by law or if we believe that such action is necessary, to protect and defend the rights, property or personal safety of The SR Group Italy, including those of its employees and/or of its website and/or visitors to our website.

Transferring your Personal Information across International Borders
The SR Group Italy is part of a global organisation, and as part of the services offered to you, the personal information you provide to us may be forwarded to or accessed by employees in our global offices in London, Amsterdam, Düsseldorf, Munich, Frankfurt, Dubai, Singapore, Hong Kong, Melbourne, Sydney and New York.

Where you apply for roles with employers based outside Italy, your personal information will be sent to employers in that country. By submitting your personal information to us, you are agreeing to your personal information being transferred to our offices, including our international offices and where you are applying for roles outside the country of application, to prospective employers in those countries.

Security and Storage of Personal Information
Safeguarding personal information and respecting confidentiality of our customer information is important to The SR Group Italy and we will do our best to protect your personal information.

The use of locks and security systems assist The SR Group Italy in protecting your personal information. Your personal information may be processed and stored in hard copy documents, or electronically on The SR Group Italy’s software or systems. When no longer required, personal information is destroyed in a secure manner or deleted.

Information Collected on our Website
There are inherent risks in transmitting information across the internet. The internet is an open system and The SR Group Italy cannot guarantee that the personal information you submit will not be intercepted by others.

Our websites may include links to external websites operated by other organisations. They may collect personal information from visitors to their site. The SR Group Italy cannot guarantee the content or privacy practices of any external websites and does not accept responsibility for those websites.

The SR Group Italy may also collect personal information that individuals choose to provide via online forms or by email. Any personal information provided online is treated in the same manner as any personal information collected through other means (unless specifically outlined in this statement).

IP Addresses
When you communicate with us electronically, we may collect information about your computer including where available your IP address, operating system and browser type for system administration and to analyse visitor trends and traffic on our website. This information does not identify individuals and is not passed on to third parties.

Cookies
A cookie is a small text file that is stored on your computer, for use when you return to a page/website that you visited before. In this case, it contains information required for downloading documents.

Cookies are not required to view our website but technical cookies which are not used for the purposes of marketing and/or advertising, are in the document downloads area. If you wish to download a document, a cookie will be used to remember your name and email address to keep you from having to re -enter it every time you download a document. Please see further details below.

Cookie Name

Cookie Type

Purpose

Duration

Enable/disable

ASP.NET

Strictly Necessary

To store unique identifier for your session

Session

Can be disabled through browser. https://msdn.microsoft.com/en-us/library/ms178581.aspx

SReuCookie

Strictly Necessary

To determine if the user accepted the cookie policy

1 year

If the user does not have the cookie the site will show the cookie policy banner and the user the cookie when they accept.

If Cookies are disabled, you will need to re-enter this information every time you download a file. The cookies are non-permanent and will be removed when you close your browser.

You can manage your preferences in respect of cookies through your browser settings. Instructions for disabling cookies on your browser (as applicable) are outlined below:

Google Chrome
Apple Safari
Microsoft Internet Explorer
Mozilla Firefox

Save as set out above, our website does not use third parties’ cookies.

Keeping your Records Accurate and Up to Date
The SR Group Italy regularly reviews the personal information it processes to ensure that it is up to date, accurate and not held for longer than necessary for the purposes for which it has been collected or as otherwise required by law. Your co-operation in helping us to keep your personal information accurate by informing us of any change of name or change of address is an important part of this. If you would like to review or change the details you have supplied to us, please contact your usual recruitment consultant.

Changes to our Privacy Policy
If we change our privacy policy in any way, we will post the changes on our website. We therefore suggest that you visit our website regularly to keep up to date with any changes.

Your Rights
You have the right to obtain confirmation as to whether your personal data is processed and, where that is the case, to access personal information we hold about you and obtain a copy of it. Unless required otherwise by the applicable law, we may refuse access if it would interfere with the privacy rights of other persons or if it adversely affects their rights and freedoms.
You have the right to be informed:
a) of the source of your personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried by electronic means;
d) of the data identity of the data controller and of the data processor/s, if appointed, and the local privacy representative, if any;
e) of the entities or categories of entities to whom or which the personal data may be communicated.

You have the right to obtain:
a) the updating, rectification or integration of your data;
b) the erasure, anonymization or blocking of your data if processed unlawfully, including data whose retention is unnecessary for the purposes for which it has been collected or subsequently processed, in the cases provided by the applicable law;
c) obtain restriction of processing in the cases provided by the applicable law;
d) statement of the operations as per letters a), b) and c) have been notified to the entities to whom or which the data was communicated or disseminated, unless this requirement is impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

You have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of your personal data, even though it is relevant to the purpose of the collection;
b) to the processing of your personal data, where it is made for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
You have also the right to:
a) withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before its withdrawal;
b) receive the personal data concerning you in a structured, commonly used and machine-readable format and transmit such data to another controller without hindrance, in the cases provide by the applicable law.

To make a request to access your personal information and/or exercise your rights, please contact us at dpo@thesrgroup.com

If you request to receive more than a copy of the personal information that we process, we reserve the right to charge a reasonable administration fee.

If you would like to opt-out from receiving newsletters and updates from us, please use the “unsubscribe” option included in the email or other material.

Privacy Complaints
If you believe that we have breached our privacy policy, or any other applicable privacy laws or regulations which may apply to The SR Group Italy, please make a complaint to The SR Group Italy in the first instance. You should address your complaint in writing to The SR Group data protection officer via email at dop@thesrgroup.com and you should include as much detail as you can about the personal information affected, and the circumstances that you believe amount to a breach of this policy or the applicable privacy law or regulation.

We will undertake an internal investigation, and we may contact you if we need to obtain any further information in relation to your complaint. We will generally provide a written response to your complaint within 30 days. Our response will set out the results of our investigation, including whether we agree that The SR Group Italy has breached this privacy statement or applicable privacy laws or regulations.

In any case, you have the right to lodge a complaint with a supervisory authority according to the applicable law.

Dated: 1st July 2016