Recruitment Privacy Notice
Privacy Notice for the Processing of Candidates' Personal Data
pursuant to Art. 13 of EU Regulation 2016/679 (GDPR)
Last updated: January 2025
Dear Candidate, this notice is provided by Plank Italy Spa Società Benefit and Plank Platform Inc. (hereinafter “Plank”) pursuant to Art. 13 of EU Regulation 2016/679 (GDPR) to inform you about how personal data collected during recruitment and selection activities is processed.
1. Data Controller
Plank Italy Spa Società Benefit
Via Privata della Passarella 4, 20122 Milan (MI), Italy
E-mail: hr@plank.global
Phone: +39 02 30559964
2. Personal Data Processed
During the selection process, Plank may process the following categories of personal data:
- Personal and contact data: name, surname, date and place of birth, residential/domicile address, tax code, phone number, e-mail address.
- Education and professional experience data: qualifications, certifications, previous work experience, technical and language skills, information contained in the CV and cover letter.
- Position-related data: salary expectations, availability, willingness to relocate, professional references.
- Data collected during interviews: notes from selection interviews, competency assessments and role suitability evaluations.
Note: please do not include special category data (Art. 9 GDPR) in your CV, such as health data, sexual orientation, religious beliefs, or trade union membership, unless strictly necessary and relevant for the application.
3. Purposes of Processing
Candidates' personal data is processed for the following purposes:
| Purpose | Legal basis |
|---|---|
| Evaluation of applications received in response to open positions | Pre-contractual measures at the data subject's request (Art. 6.1.b GDPR) |
| Management of the selection process (interviews, technical tests, assessment) | Pre-contractual measures at the data subject's request (Art. 6.1.b GDPR) |
| CV retention for future job opportunities | Data subject's consent (Art. 6.1.a GDPR) |
| Compliance with legal obligations (employment and tax law) | Legal obligation (Art. 6.1.c GDPR) |
| Possible establishment of an employment relationship | Performance of a contract (Art. 6.1.b GDPR) |
4. Data Collection Methods
Personal data may be collected through:
- Spontaneous submission of CVs via e-mail or the website contact form.
- Applications for positions published on recruiting platforms (LinkedIn, job portals).
- Recruitment agencies acting on behalf of Plank.
- Referrals from employees or collaborators.
5. Data Recipients
Candidates' personal data may be disclosed to:
- Authorized internal staff (HR team, department heads involved in the selection).
- Plank group companies (Plank Platform Inc.), where the position concerns foreign offices.
- HR service providers and applicant management platforms, acting as Data Processors pursuant to Art. 28 GDPR.
- Labour consultants and external professionals, limited to the potential hiring phase.
Data will under no circumstances be disclosed or communicated to unauthorized third parties.
6. Extra-EU Transfers
Where the application concerns positions at Plank Platform Inc. (USA), data may be transferred to the United States of America. The transfer is based on Standard Contractual Clauses (SCCs) approved by the European Commission or, where applicable, the EU-US Data Privacy Framework.
7. Data Retention Period
- Application for a specific position: data will be retained for the duration of the selection process and, in case of non-hiring, for a maximum of 24 months from the end of the selection.
- Spontaneous application: data will be retained for a maximum of 24 months from receipt of the CV.
- In case of hiring: data will be included in the employee's personal file and retained according to the terms provided by applicable employment legislation.
After the retention period, data will be deleted or irreversibly anonymized.
8. Data Subject Rights
Candidates, as data subjects, have the right to:
- Access their personal data and obtain a copy (Art. 15 GDPR).
- Request rectification of inaccurate or incomplete data (Art. 16 GDPR).
- Request erasure of data (“right to be forgotten”), in applicable cases (Art. 17 GDPR).
- Request restriction of processing (Art. 18 GDPR).
- Exercise the right to data portability (Art. 20 GDPR).
- Object to processing (Art. 21 GDPR).
- Withdraw consent at any time, without affecting the lawfulness of processing based on consent prior to withdrawal.
To exercise your rights, you may send a request to: hr@plank.global.
9. Right to Lodge a Complaint
Candidates have the right to lodge a complaint with the competent supervisory authority if they believe that the processing of their personal data violates the GDPR. In Italy, the competent authority is the Garante per la Protezione dei Dati Personali – www.garanteprivacy.it.
10. Data Provision
The provision of personal data is voluntary. However, failure to provide necessary data (e.g., personal details, CV) will make it impossible to evaluate the application and participate in the selection process.
11. Contacts
For any information regarding the processing of candidates' personal data:
Plank Italy Spa Società Benefit – HR Office
Via Privata della Passarella 4, 20122 Milan, Italy
E-mail: hr@plank.global
Phone: +39 02 30559964