GENERAL PRIVACY POLICY FOR USERS THAT APPLY FOR A WORK POSITION

This page describes the methods for managing the In-Recruiting portal with respect to the handling of personal information of users that consult and use it in order to submit their job application. The information also concerns the method, time and nature of the information that the owners of the processing must supply to users when the latter are connected to the web pages, no matter what the purposes of the connection are.

Owner of the Personal-Data Processing

The CVs, the information and data relevant to the interested user are consulted, used, and classified jointly or individually by the owners of the personal-data processing (consortium and members of the consortium) in the following list:

1. Compagnia di San Paolo (CSP)
2. Compagnia di San Paolo Sistema Torino (CSP-ST)
3. Collegio Carlo Alberto (CCA)
4. Fondazione per la Scuola
5. Fondazione 1563 per l’Arte e la Cultura
6. Hugef
7. Istituto Superiore Mario Boella (ISMB)
8. SiTi
9. Ufficio Pio
10. XKè? ZeroTredici

The owners of the processing carry out, each within the scope of its province, all the operations needed to guarantee that the information is managed in a safe and protected way.

The portal is jointly managed by CSP and CSP-ST. However, the data is shared within the whole consortium. Access to the portal database is solely limited to the persons in charge, and specific measures are adopted in order to prevent access by non-authorized persons, although such limitations could be gotten around in a fraudulent way.

Type of Processed Data Data willingly supplied by the user

The portal gathers CVs, personal information and data, possibly sensitive data, which users, in their capacity as interested persons, choose to supply when inserting or updating their spontaneous application for one of the work positions or for a collaboration offered by the consortium or by consortium members. This data can be directly uploaded on the portal or on some specific internal pages (e.g. lavora-con-noi, job opportunity, etc.) of the public web sites of the consortium, of consortium members, and on multiposting portals.

Technically essential browsing data

The computer systems and software procedures that oversee the functioning of this web site acquire, during the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not gathered in order for it to be associated to identified interested persons; however, because of its nature, it could allow the identification of users through elaborations and associations with data held by third persons. This category of data includes IP addresses or dominion names of the computers utilized by users who connect with the web site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used for submitting the request to the server, the dimension of the file obtained in answer, the numeric code indicating the status of the answer given by the server (positive conclusion, error, etc.) and other parameters relevant to the operating system and to the computer environment of the user. This data is used with the sole purpose of obtaining anonymous statistical information about the use of the web site and of controlling its correct functioning, and it is immediately deleted after the processing. The data could be used to assess liabilities in case of hypothetical computer crimes damaging the web site, in order to detect and solve problems and to improve the services provided.

Profiling data

No profiling data concerning consumer habits or choices of the interested person is directly acquired.

Purposes of the processing, data communication and spreading

The gathered personal information is used with the only purpose of carrying out the requested services or performances and it is communicated to third parties only when it is necessary towards this purpose.

The objectives of the processing and of the use of personal information are:

• Consultation and mere fruition of the portal and its contents;
• Registration and access to the reserved area of the portal;
• Gathering of applications and CVs from those users that autonomously submit them;
• Selection of personnel by the consortium and consortium members that are interested in evaluating the applications and recruiting personnel, through the material that the applicants have voluntarily inserted;
• Sending semi-automatic and non-periodical communications relevant to:
• New job opportunities with the consortium and consortium members
• Requests for information updates
• Requests for interviews (also through videoconference)
• Updates of the portal also with respect to new functions, including updates in the used software
• Surveys

For some services, in-depth indications are set up.

In any case, no data coming from the web services is spread or published without the prior consent of the interested person.

Any sensitive data registered in the portal:

• Is not processed for the purposes of personnel selection on behalf of third parties different than the owners of the processing (consortium and consortium members);
• Is not used for opinion polls, market researches, and other sample surveys.

Lastly, we remind you that in some cases (not subject to ordinary management) Public Authorities can request news or information, including personal information, with which the Owner of the processing must comply.

Optional Submission of Data

Except for what has been specified about the browsing data that is technically essential, users are free to submit their personal information. Failure to submit some of the data considered as essential may imply the impossibility to obtain what has been requested or to positively complete the requested procedure.

Management of the agreement to the processing of personal information

Whenever it is mandatory and, in any case, subject to having read the information on privacy practices, the interested persons are requested to express their agreement to the processing and communication of their personal information for the purposes and within the limits described above, failing which it becomes impossible for the entity in charge of processing the data to fulfill and carry out the services requested by or proposed to the interested person.

Users can deny their agreement also subsequently, in particular with respect to the sending of communications.

In-depth Presentation of Specific Services Reserved area and management of own information by users

Candidates who submit their application receive an e-mail confirming the registration and communicating the access credentials (email and password) for their reserved area: here they can modify their profile and the attached documents, verify the history of the sent applications, interact with the company (through messaging, the calendar, surveys, video-interviews), and manage the requests connected with privacy protection laws (at any moment, they can request the cancellation, anonymity, and the deactivation of their own profile).

In the last case, the previous information relevant to the user will be deleted, but the logs and other statistical and demographic information of the user may be kept, anonymously saving a filed copy of such information.

After 24 months without any updates, the personal information is removed within 15 days from the prior request to the interested users to review their profile, thus newly extending the time period of their storing and use.

The information (texts, videos and images) that users upload in the reserved area is protected by coding and authentication systems and is accessible only by authorized users or by the directly interested persons and/or involved intermediaries. Such information cannot be subject to disclosing operations.

Personal Information Processing Method

The processing of personal information, intended as the gathering, registration, organization, storage, processing, modification, cancellation, and destruction, or the combination of two or more of such operations, takes place through manual, computer, and telematic devices, including automatic devices, according to rationales that are strictly related to the declared purposes and, in any case, so as to guarantee its security and confidentiality and for the time period that is strictly necessary to reach the goals for which it has been gathered.

The information is processed lawfully and fairly. It is gathered and registered for specific, explicit, and legitimate purposes; it is precise and, if necessary, updated, pertinent, complete, and not exceeding the purposes of the processing, with due respect for the minimum safety rules and for the fundamental rights, liberties, and dignity of the interested person, with particular reference to confidentiality and personal identity.

Specific safety measures are observed in order to prevent the loss of data, unlawful or unfair use, and unauthorized accesses.

Rights of the Interested Persons

The persons, whom the personal information refers to, have the right at any moment to obtain confirmation about the existence or absence of said information, and to know its contents and origin, verify its accuracy or request its integration or update, or its correction. Moreover, there is a right to request its cancellation, its transformation into anonymous form, or the block of data processed in violation of law, as well as to oppose, in any case and for legitimate reasons, its processing.

Applicable law

The European and Italian laws apply to the processing of personal information relevant to the web site, in particular the Legislative Decree 30 June 2003, nr. 196 and subsequent modifications and integrations, and the measures taken by the Autorità Garante for its protection.

Addresses

To contact the entity in charge of the processing of personal information you can refer to the following list: 

• for matters relevant to the In-Recruiting portal:
• CSP: email risorseumaneorganizzazione@compagniadisanpaolo.it
• CSP-ST: email selezionepersonale@csp-st.it

• for matters relevant to interviews, their outcomes, etc., managed directly by the employer (consortium or consortium entity), besides the above addresses:
• CSP: email risorseumaneorganizzazione@compagniadisanpaolo.it
• CSP-ST: email selezionepersonale@csp-st.it
• Collegio Carlo Alberto: email selezionepersonale@csp-st.it
• Fondazione 1563 per l’Arte e la Cultura: email selezionepersonale@csp-st.it
• Fondazione per la scuola: email selezionepersonale@csp-st.it
• ISMB: email selezionepersonale@csp-st.it
• HUGEF: email selezionepersonale@csp-st.it
• SiTi: email selezionepersonale@csp-st.it
• Ufficio Pio: email selezionepersonale@csp-st.it
• XKè? ZeroTredici: email selezionepersonale@csp-st.it

The name of the entities in charge of the processing can be learned upon request, by writing to the known addresses. 

User Terms and Conditions – Rights and Responsibilities of in-recruiting Users of Compagnia di San Paolo Sistema Torino

1. Subject Matter of the Contract

This page, to be read carefully, establishes the “General Conditions” that rule the use of in-recruiting (hereinafter, the “Portal”). In order to use the services offered on our Portal, you must accept the present General Conditions by clicking on the specific button. If you do not accept the present General Conditions, you may not use this Portal and enjoy the services it offers. These General Conditions can be modified at any time without need for prior notice. The terms “you” and “User”, used below, indicate the physical and legal persons that access this Portal for any reason.

The Portal is used by the Compagnia di San Paolo Sistema Torino (hereinafter, “Consortium”) and by the Consortium Members in order to publish their ads and work opportunities, allowing applicants to register and submit their application, also by means of attachments, videos, and interviews. No guarantee is given about a real possibility to enter into an employment or collaboration agreement. The Portal only allows organized management of the information relevant to offers and applications.

2. Permitted Use of the Portal

General Rules: Users cannot use the Portal with the purpose of transmitting, distributing, memorizing, or deleting Material (a) in violation of applicable laws or regulations, (b) so as to breach any copyrights, trademarks, industrial secrets, or other intellectual property rights, or in any way violate the privacy or personal rights of third parties, and (c) in any way that might be defamatory, obscene, or contrary to good moral standards or public order.

Safety Rules: Users must not breach or try to breach the Portal’s security system. It is also prohibited to: (a) access data that is not permitted to one’s User privileges or to enter the server or an account to which access is not allowed to the User, (b) try to analyze, find out, or test the system or network’s vulnerability, or breach the security or identification measures without specific authorization, (c) try to interfere with the service provided to any one of the other Users, including, but not limited to, introducing a virus in the Portal, overloading the system, or using flooding, spamming, mailbombing or crashing techniques, (d) send unrequested emails, including promotions and/or advertisements of products or services, or (e) counterfeit any TCP/IP packet header or any information relevant to the heading of email messages to individuals or groups of people (newsgroup). Violations of system or network safety measures might entail civil or criminal liability. The Consortium and Consortium Members will thus investigate those behaviors that might result in the breach of criminal or civil laws and may request the intervention of, or cooperate with, any Public Authorities having jurisdiction in prosecuting any Users involved in such breaches.

3. Prohibited Specific Uses

The Portal may be utilized only for the uses allowed by the law by persons looking for employment or for information concerning future job opportunities offered by the Consortium and by Consortium Members. The following uses of the Portal are prohibited (and all Users accept not to use the Portal in the following way):

 (a) entering any personal information that is incomplete, false, inaccurate, or in any case information that does not correspond to one’s personal profile;

(b) cancelling or modifying Materials inserted by other Users;

(c) using any device, software, or routine that might interfere with the Portal’s functionality or with any activities carried out on the Portal;

(d) undertaking any action that imposes an unreasonable or disproportionate load on the Portal’s infrastructure;

(e) disclosing or sharing a password with third parties, or using the password for any unauthorized purposes, whenever the password allows access to reserved areas on the Portal;

(f) subject to any different provisions in the present General Conditions, using or trying to use browsers, software, and other devices or mechanisms (including, without limitation, browsers, spiders, robots, avatars, or intelligent agents) in order to surf or explore this Portal, unless these are devices or browsers made available on the Portal by the Consortium and the Consortium Members, or browsers made available to the public in general (e.g. Netscape Navigator, Microsoft Internet Explorer);

(g) trying to decipher, decode, disassemble or reconstruct the content of a software used to structure the Portal.

4. User’s Personal Information

The registration procedure on the Portal requires you to supply some personal information (hereinafter, the “Personal Information”). Concerning the processing of Personal Information, please refer to the “Privacy Policy” clauses available on the web site. In this respect, we remind you that your agreement to the processing of Personal Information is a necessary requirement for your registration to the Portal and for the supply of the services offered in the Portal.

5. User’s Obligations

Users are responsible for the consequences that might result from inserting any kind of data, information, and material. It is prohibited for Users (a) to insert material that is protected by copyright, unless the User is the owner of such copyright or is authorized by the copyright owner; (b) to insert material that discloses industrial secrets, unless the User is the owner of said secrets or is authorized by the owner; (c) to insert material that breaches any third party’s intellectual property rights or that violates their privacy or rights relevant to advertising agreements; (d) to upload, publish, insert or otherwise transmit material that is illicit, threatening, obscene, defamatory, racist, or contrary to public order or good moral standards; (e) to insert sexually explicit images or texts; (f) to upload, publish, send by email, or otherwise transmit or spread promotional material, junk mail, spam, or any other form of unauthorized or unrequested solicitation; (g) to insert chain letters or pyramids; (h) to falsify one’s personal identity; and (i) to upload, send by email, or otherwise transmit any material containing viruses, Trojan horses, worms, time bombs, cancelbots, or other codes, files, or software created in order to interrupt, destroy, or limit the functioning of the software, hardware, or telecommunications systems belonging to third parties. The Consortium and Consortium Members do not guarantee in any way the truthfulness, accuracy, and reliability of the statements inserted by Users and do not assume any responsibility with respect to the opinions expressed by Users. Users acknowledge that the Consortium and Consortium Members do not guarantee the truthfulness of the materials inserted by other Users, therefore the use of said materials takes place at Users’ risk and danger.

The Consortium and Consortium Members have no obligation to assess in advance the communications, data, and information entered by Users, as the Portal is a simple interface for the online publication of information and data inserted by each individual User. Should a User report that the communications, data or information inserted in the Portal are presumably non-compliant with the present General Conditions, an investigation will be started on the basis of this report and it will be decided in good faith whether to remove or to request the removal of said material. We reserve the right to expel Users and to prohibit their subsequent access to the Portal, if they are responsible for breaching contract clauses or rules of law. Moreover, we reserve the right to remove material that is threatening, obscene, defamatory, racist, or contrary to public order or good moral standards. At our discretion, we may take all the necessary and useful measures concerning the material supplied by a User, whenever we deem that such material might determine a liability for the Consortium and/or Consortium Members, or it might cause a loss or reduction of the services of its ISPs or of other suppliers. Subject to the provisions of applicable laws and regulations, by inserting materials (excluding personal information) in the Portal (including the spaces for messages, forums, contests and chat rooms), Users grant the perpetual, irrevocable, non-exclusive right, that can in turn be sublicensed, as well as the license to use, reproduce, modify, adapt, publish, translate, rework, distribute, communicate to the public, show, and use the above material (wholly or partly) worldwide and/or include it in other works in any form, with any communication means or technology known to this day or that will be developed in the future. Each User guarantees that any owners of the rights on the materials inserted by said User have wholly waived their rights and have given the User the right to grant the above-mentioned licenses. Each User allows any other user registered in the Portal to access, show, examine, memorize and reproduce said material for personal use. Subject to the provisions above, the owner keeps all the rights relevant to the material inserted in the Portal.

6. Account and Password

At the end of the registration procedure, you will receive an account and a password. Keeping the secrecy of the account and password is your sole and exclusive responsibility and, therefore, you will be the only and exclusive person responsible for any activities carried out through the use of your account or password by any third parties to whom you will have given the above identification data or who will have entered into the possession thereof due to your negligence. You undertake to timely notify any unauthorized uses of your password.

7. Responsibility of the Consortium and of Consortium Members

Together with the Consortium Members, the Consortium gives applicants the possibility of inserting their profiles in the Portal without carrying out any monitoring and controls on the material inserted in the Portal and without having any control over the quality, safety, or lawfulness of the profiles, over the truthfulness or accuracy of the entered data, over the applicants’ work skills. The Consortium and Consortium Members expect you to apply a great deal of cautiousness and discernment in using the Portal.

Furthermore, we inform you that the Material can contain inaccuracies or misprints. The Consortium and Consortium Members do not guarantee the accuracy, reliability, completeness, and timeliness of the information contained in the Portal or the Material. Using our Portal and Material is totally at your risk. Also, please keep in mind that modifications are periodically made to the Portal, and that this can happen at any moment. In any case, please acknowledge that you are the only person responsible for the form, content, and accuracy of the material/s that you insert in the Portal.

The Consortium and Consortium Members do not guarantee that the Portal is free of errors or that the Portal or the server are free of viruses or other technical defects of any nature. Should the use of the Portal or of the material produce damages to your computer or to your data, the Consortium and Consortium Members are in no way responsible for the costs relevant to maintenance services, repairs, or replacements. The Portal’s services and material are offered without any kind of guarantee (on an “as is” basis). The Consortium and Consortium Members, within the limits of the provisions of the law, exclude any kind of explicit or implicit guarantee. To this respect, the Consortium and Consortium Members do not issue any guarantees concerning the accuracy, reliability, and completeness of the material, services, software, texts, graphics, and links. Users acknowledge that neither the Consortium nor the Consortium Members, nor anyone else that might have taken part in the creation, production or supply of the Portal’s services, may be held responsible for any damages of any nature, both by contract and outside the terms of a contract, due to the activation or use of the services offered on the Portal and/or to the interruption of the Portal’s operation. In no case shall the Consortium and Consortium Members be held responsible for the malfunctioning of the offered services due to failures in the telephone and electric lines, and to overload or interruption in the national, world or international networks.

8. Indemnification Clause

Users declare and guarantee that they will indemnify the Consortium and Consortium Members, as well as any persons connected to or controlled by the Consortium and Consortium Members, their representatives, collaborators, and employees for any damages (including reasonable legal fees) that might result against them from the use of the Portal and the Material by the Users or from the breach of the present General Conditions.

9. Links with Other Web Sites

The Portal can contain links to other web sites; the Consortium and Consortium Members are in no way responsible for the contents of such sites: the Consortium and Consortium Members, therefore, do not issue any guarantees concerning the contents and accuracy of the material present in the above web sites. If you decide to access web sites that have a link inside our Portal, this access will take place under your sole responsibility.

10. Prohibition to Resell or of Unauthorized Commercial Use

You undertake not to resell or assign your rights or your obligations resulting from the present General Conditions for the use of the Portal. You also undertake not to use the Portal for unauthorized commercial purposes.

11. Duration and Termination of the Agreement

Users acknowledge that the Consortium and Consortium Members can, at their discretion, disconnect a User’s password and account or interrupt the use of the service at any moment, with at least a 5 days prior written notice sent by email to the User. The Consortium and Consortium Members reserve the right to declare the present agreement to be terminated, as provided for by article 1456 Civil Code, by written notice sent by email to the User, in case the User fails to comply with one of the obligations under articles 2, 3, 4, 5, and 9 of the present General Conditions. 

12. General Rules

Should one of the provisions of these General Conditions be considered invalid by an authority having judicial competence, the invalidity of such a provision will not affect the validity of the remaining provisions, which will continue to be in force. Subject to the express provisions in further contract terms and conditions for the use of the Portal, with a particular Legal Note, in the Software License, or in other particular Web pages, the present General Conditions contain all the provisions that rule the contractual relationship between you and the Consortium and Consortium Members with respect to the use of the Portal.

13. Further Conditions for Using the Portal

Other areas accessible from this Portal are subject to further and different terms and conditions for the use of the services. By using such different areas of the Portal, you accept the further provisions that apply to those areas.

14. Applicable Law and Arbitration Clause

These General Conditions and the relations between the Consortium and Consortium Members and the Users are ruled by the laws of the Italian Republic. All controversies that may arise from this agreement shall be finally settled by an Arbitrator at the Court of Justice of Turin, Italy.