Privacy notice for unsolicited applications — homacoop.it

This notice covers data submitted through the “Work with us” page of homacoop.it and supplements the website's general privacy notice.

1. Controller and contact details

The controller is HOMA Società Cooperativa per azioni, Via Orsini Ducas 8, 73100 Lecce (LE), Italy, tax code and VAT number 04579080757, email info@homacoop.it, certified email coop.ass@pec.it. The full identification details are set out on the Legal notice page.

Data Protection Officer (DPO): Mario Nobile, attorney-at-law, privacy@homacoop.it.

2. Data, purpose and legal basis

HOMA processes first and last name, email address, optional telephone number, city, role or area of interest, optional LinkedIn link and personal introduction for two distinct purposes.

The first is to assess the profile against open positions or positions about to open: the legal basis is taking steps at the candidate's request before entering into a contract under Article 6(1)(b) GDPR.

The second is to retain the profile for later opportunities, within the period set out below: the legal basis is HOMA's legitimate interest in holding a pool of applications for future needs under Article 6(1)(f) GDPR. The candidate may object at any time by writing to the contact details given, without having to give reasons and without prejudice to any assessment already under way; the objection is acted on without delay.

The form does not accept attachments. Do not enter a CV, identity documents, health or disability data, trade-union membership, religious or political beliefs, ethnic origin or other special categories of data: under Article 8 of Italian Law no. 300 of 20 May 1970 and Article 10 of Italian Legislative Decree no. 276 of 10 September 2003, such information may not be requested or used for selection purposes, except in the cases expressly provided for by law. If the profile is of interest, HOMA will provide a suitable channel and any additional information required.

3. Provision, recipients and decisions

Name, email address and personal introduction are required to assess and contact the candidate; other fields are optional. Data is reviewed by authorised people within the relevant functions and may be processed by technical providers, which must be governed by an agreement under Article 28 GDPR.

No automated scoring, ranking or exclusion systems are used, no decisions are made solely by automated means with legal or similarly significant effects on the candidate, and no profiling is carried out.

HOMA uses artificial intelligence tools on corporate accounts held by the cooperative, provided by Google (Gemini, within Google Workspace), Anthropic (Claude) and OpenAI, and does not use personal accounts. Those tools are not used to assign scores, produce rankings or exclude applications: the preceding paragraph applies, and no scores or assessments are recorded in the internal archive of applications. Some of those providers are established in the United States: in that case HOMA relies on the standard contractual clauses approved by the European Commission and on the supplementary measures provided for in the agreements with those providers; for transfers to the United States the provider's adherence to the EU-US Data Privacy Framework is also relevant, where applicable and verified. Where these providers process data on HOMA's behalf, they must be governed by an agreement under Article 28 of the GDPR.

4. Retention

Anyone submitting the form automatically receives, at the email address provided, an acknowledgement of receipt containing a summary of the data entered; the acknowledgement is sent once only and contains no marketing communications.

Data is retained in HOMA email inboxes and in an internal archive. In the archive the application is retained for 12 months from receipt and on expiry the record is deleted automatically by the system. The period runs from receipt and does not restart: consulting the application and adding internal management notes do not extend it. For email inboxes the 12-month period is applied through periodic organisational reviews, at least every six months.

The system records consultations and exports carried out on the archive, indicating the authorised person and the time. Where an application is included in a list extracted from the archive for management purposes, that list is kept within HOMA's working tools and deleted within six months of extraction: the automatic deletion that applies to the individual record does not apply to it.

The archive is accessible only to the persons authorised for job applications. If an employment or collaboration relationship begins, the necessary data is transferred to HOMA's ordinary systems and processed under the notice applicable to that relationship.

5. Rights

Candidates may request access to their data, its rectification or erasure, restriction of processing and data portability, and may object to the processing based on the legitimate interest set out above. Requests should be sent to privacy@homacoop.it or, if preferred, to coop.ass@pec.it, or to the Data Protection Officer's contact details. HOMA replies without undue delay and in any event within one month of receipt, with a possible two-month extension in the cases provided for, of which notice is given. Exercising these rights is free of charge. Candidates may also lodge a complaint with the Italian Data Protection Authority through www.garanteprivacy.it or seek a judicial remedy.

6. Previous versions

Previous versions of this page are available on request by writing to privacy@homacoop.it.