Information notice to the candidates regarding
the processing of personal data

Rosman Group – more precisely all the companies that are part of it, including Rosman Talent Solutions SRL, Romanian company, with registered office in Romania, Timiș county, Timișoara, George Coșbuc street, no 3, ap. 6b, having VAT NO RO 33627589 and J35/2227/2014, and Rosman IT Solutions SRL, Romanian company, with registered office in Romania, Timiș county, Timișoara, Tulcea street, no 12, with VAT no 33521307 and J35/2007/2014, undertakes to maintain the confidentiality and security of the personal data of persons interested in employment opportunities (present or future) and having discussions with Rosmanin this respect (Candidates or singularly Candidate). These data will be processed by Rosman in full compliance with the applicable legislation.

Rosman collects personal data from the Candidate’s CV, from the public ones, and possibly from what is subsequently indicated by him / her during the previous or subsequent discussions, as well as from the documents enclosed with the CV, in order to make a decision whether the Candidate fulfils the requirements related to a certain raole requested by an Rosman customer, respectively in order to identify further opportunities for employment / collaboration with the Candidate.

If it is decided to conclude a contract of employment or another type of collaboration between the Candidate and a client / third party, documents will be signed only between these parties and Rosman will not be a signatory. After that moment, the person’s candidate status will cease and the employee / collaborator status will be acquired.

Rosman complies with the provisions of Regulation no. 679/2016 on the protection of individuals with regard to the processing of personal data and on the free circulation of such data, amended and supplemented (Regulation) and has implemented appropriate technical and organizational measures to ensure the security of the processed personal data and respect the rights of the Candidate.

Contents

1. Identification of the data controller and of the joint controllers
2. Details of the contact for data protection issues within Rosman
3. Purpose of the data processing
4. Legal base
5. Processed personal data
6. Type of processing
7. Recipient of the processing
8. Processing duration and data storage
9. Transfer to other third countries /international organizations
10. Rights of the Candidate
11. Obligations of the Candidate
12. Security measures regarding the processed data
1. Identification of the data controller and of the joint controllers

Rosman and its client, who wants to identify suitable candidates for a particular role, process the data of the persons (Candidates) interested in the present or future employment opportunities indicated in the CV (the one existent on-line and / or submitted or sent in material form), appearing in public online information, as well as any of what is subsequently indicated by the candidate during the interview, prior or subsequent discussions, or in documents attached to the CV (such as education diplomas or graduation of specialized courses , recommendations, etc.).

Thus, the client determines the purpose of the data processing (namely, the occupation of a particular position in his organization) and the means – in which case the client is the controller, and Rosman is the processor; respectively the client sets the purpose and Rosman sets out the means to be followed in order to achieve the goal or their essential elements (such as how to identify potential candidates, including accessing their own database, how to contact them, the set of questions addressed, how to present the results) – in which case the client and Rosman could be joint controllers.

Regardless of the capacity they have (joint controller with the client, or its processor), Rosman undertakes to maintain the confidentiality and security of the personal data of the persons providing that data.

Also, when Rosman concludes certain support service contracts to fulfil its contractual obligations (such as talent screening), those providers who process personal data of candidates will comply with the Regulation as joint controllers with Rosman establishing the essential elements of the means used, independent controllers or processors, on a case-by-case basis.

2. Details of the contact for data protection issues within Rosman

3. Purpose of the data processing

Rosman collects personal data from the Candidate’s CV (the one existent on-line and / or submitted or sent in material form), from public information in the on-line environment, as well as from the information subsequently provided by the candidate (on the occasion of the interview, of the prior or subsequent discussions, from the documents attached to the CV, such as education diplomas or graduation of specialized courses, recommendations, etc.), in order to make a decision regarding the fulfilment by the Candidate of the requirements related to a particular role requested by an Rosman customer.

Also, for some Candidates who reach an advanced stage within the procedure, Rosman needs their ID card or passport data to mediate the purchase of transport tickets and providing booking for accommodation. If the Rosman customer requires this, Rosman will also be able to access the results of the psychological profile obtained by the Candidate following testing by a third party contracted by the Rosman customer.

If the Candidate gives his / her consent to this end, Rosman will process his / her personal data represented by surname, first name, telephone number and e-mail address in order to be able to inform him / her in the event of a future opportunity that may be relevant to the profile and his/her professional desires.

4. Legal base

Art. 6 paragraph 1 letter (a) (the Candidate has given his / her consent to the processing of his / her personal data for the purposes indicated in section 3), (b) (processing is required for the performance of a contract to which the Candidate is a party or to take steps at his/her request prior to the conclusion of a contract) and (f) (processing is necessary for the legitimate interests pursued by Rosman or a third party – usually the Rosman customer) of the Regulation.

5. Processed personal data

a. The data indicated by the Candidate in the CV presented (such as: surname and first name, home address / residence address, citizenship, telephone number, e-mail address, photo, professional training data, qualifications, professional experience, previous work, education completed, current position held, linguistic skills, hobbies, technical skills, certifications and diplomas obtained, references, possession of driving license)
b. Additional data obtained from the public environment or from discussions held (such as any of those listed under letter a, but not specified in the CV, expected salary and benefit levels, notice period set by the current employer, motivation of workplace change)
c. Data required to contact the Candidate in case of future opportunities (namely: surname, first name, telephone number and e-mail)
d. Identity card / passport details (namely: surname and first name, Personal Identification Number, series and number, date of validity of the document, issuing authority) for Candidates who have reached an advanced stage of the procedure and are not in the place where the final evaluations will be held, for whom it is necessary to mediate the purchase of transport tickets and accommodation bookings.
e. The results of the psychological profile obtained as a result of Candidate testing by a third party contracted by the Rosman customer

6. Type of processing

Collection of data included in CVs and obtained from the discussions, accompanying documents and from the public environment, for the purposes indicated in section 3.

The storing of the Candidate’s data indicated in section 5 for the time necessary to achieve the respective purposes in accordance with what is indicated in section 8, in the internal registers of Rosman that represent its electronic and secured data base, and on the cloud platform

Data transfer to Rosman customers and external collaborators providing talent screening or Rosman support activities whose work involves processing Candidate data)

7. Recipient of the processing

The Rosman administrator – has access to all the data from section 5

Rosman employees who contact and discuss with the Candidate with regard to a particular role or future opportunities – have access to all the data in section 5 except for those indicated under letters (d) and (e)

The Rosman customer who has requested the identification of suitable candidates for a given role – has access to all the processed data indicated in section 5

The company with which Rosman has signed a contract for the provision of talent screening or support activities, including its employees, has access to all the processed data indicated in section 5 except for those indicated in letters (c), (d) and (e)

The company with which Rosman has signed a contract for the provision of IT services, including its employees – has access to all the processed data indicated in section 5.

Competent authorities (including but not limited to tax authorities and labour law authorities) – have access to the data indicated in section 5 according to requests

8. Processing duration and data storage

The storage period of the collected data indicated in:

section 5 letter (a), (b) and (e) – 36 months from the moment of having obtained the CV and having conducted the first discussion with the Candidate.

section 5 letter (c) – equal with the operating duration of Rosman.

section 5 letter (d) – equal with the duration needed to perform the related bookings and payments

Upon expiry of the aforementioned durations, all personal data of the Candidates collected as above will be removed from the Rosman Records.

Its external collaborators who provide talent screening and support services, including IT for Rosman, will have access to the Candidate’s personal data strictly during the term of the signed contract between them and Rosman.

9. Transfer to other third countries /international organizations

Does not apply.

10. Rights of the Candidate

According to the Regulation, the Candidate has the following rights:

• right of access to the data (art. 15)
The candidate has the right to obtain a confirmation as to whether or not his/her personal data are being processed, by sending a simple written request at the address indicated in section 2. If affirmative, the Candidate has the right to access the information indicated in section 5. The response will be given within maximum 14 working days from the date of the request. Thus, Rosman will supply free of charge to the candidate a copy of the documents containing the processed data. For additional copies a fee of 50 RON will be paid.

• the right to rectification of the data (art. 16)
The candidate shall have the right to rectify the inaccurate data processed by Rosman, as well as to complete the incomplete data. These steps will be taken by Rosman without undue delay, no later than 14 working days after the date of the written request submitted by the Candidate at the address indicated in section 2.

The Candidate has the right to obtain the completion of personal data that is incomplete, including by providing an additional statement.

• the right to erasure of the data (art. 17)
The Candidate has the right to be forgotten, by requesting the deletion of his / her data at the expiry of the processing period indicated in section 8; if personal data is no longer required for the fulfilment of the purposes; if the candidate withdraws his/her consent and there is no other ground for processing; if he/she objects to the processing and there are no overriding legitimate reasons for the processing; if processing was made illegally; if deletion is mandatory by law. The exceptional cases provided by art. 17 par. 3 of the Regulation are applicable.

• the right to restriction of the data processing or opposition to processing (art. 18 and 19)
The Candidate has the right to obtain from Rosman the restriction of the processing made by Rosman if: he/she finds that his/her data are not exact (the restriction will operate for the period during which the situation is checked); the processing is illegal, and the Candidate opposes the deletion of the data; Rosman no longer needs the personal data, but the Candidate requests them for the exercise of a legal action; the Candidate has objected to the processing, pending the verification whether the legitimate rights of Rosman override his/hers.

RTS may further process the restricted data if the processing is necessary for establishing, exercising or defending a right in court or is necessary for the protection / defence of a natural / legal entity or is justified by public interest reasons, but only with the consent of the Candidate.

RTS will communicate to all recipients the rectification, erasure or restriction of the data unless this proves to be impossible or involves disproportionate efforts, as well as to the Candidate in the event of lifting the restriction.

• the right to data portability (art. 20)
In cases where the processing of personal data is based on consent (Article 6 paragraph 1 letter (a) of the Regulation) or on the conclusion and performance of the contract (Article 6 (1) letter (b)), and not on any other basis, the Candidate is entitled to receive from Rosman his/her processed data in a structured, easily and automatically readable format, and may request the submission of the data to another controller, in which case Rosman does not assume the responsibility for the third party’s compliance with the applicable legislation provisions on personal data protection. Rosman will do so within maximum 14 working days of the date of the written request submitted by the Candidate at the address indicated in section 2.

• the right to lodge a complaint (art. 13 paragraph 2 letter d, art. 77 -79)
In case of violation of the rights stated by the regulation and indicated in paragraph 11, the Candidate may send a request using the contact data from section 2.

An action may be brought before a court and a complaint to the competent supervisory authority in Romania (National Authority for the Protection of Personal Data), with the possibility of appealing to the competent courts against the decision of the respective authority.

• the right to withdraw his or her consent (art. 7 paragraph 3)
The candidate has the right to withdraw his / her consent at any time. The consequences of non-granting / withdrawal of consent may be the impossibility of accessing the role for which the Candidate has been approached by Rosman, as well as future opportunities for collaboration / employment. Withdrawal of consent does not affect the lawfulness of the processing under consent prior to its withdrawal.

In the case of processing of the Candidate’s data on the basis of other legal grounds (such as conducting prior formalities required for the performance of the contract between the Candidate and the Rosman customer), the withdrawal of the consent will not prevent the processing.

• the right not to be subject to a decision based solely on automated processing (art. 22)
Rosman does not apply automated decision-making processes regarding the Candidate.

• the right to object (art. 21)
In the event that the Candidate will at any time object to the processing of his or her data according to this document, the legitimate reason for the fulfilment of the legal obligations of the Rosman or processing for the purpose of establishing, exercising or defending a right in court shall prevail over the Candidate ‘s interests, rights and freedoms.

• The right to be informed (art. 12, 13)
This right is provided in this note.

If Rosman intends to further process personal data for purposes other than those listed in section 3, it will provide the Candidate prior to said subsequent processing with details of the secondary purpose and all relevant additional information.

Rosman shall inform the Candidate of the essence of the contracts concluded with the recipients receiving their personal data if he/she so requests by submitting a request to the address indicated in section 2. Thus, the Candidate will be informed of the appropriate safeguards provided by the recipients for the protection of his/her personal data.

At the request of the Candidate sent to the address indicated in section 2, if his or her personal data are not obtained directly from him/her, Rosman shall provide the candidate with any available information regarding the data source.

In the event of any restrictions by Union or internal law affecting what is indicated herein, the Candidate will be duly informed and an addendum to this document will be drawn up.

11. Obligations of the Candidate

• the obligation of unlimited confidentiality of all the information to which he/she has access or which is provided, no matter if it relates to Rosman, its collaborators or its customers and regardless of the medium on which it is stored

• the obligation to comply with internal policies and procedures

The Candidate has permanent access to Rosman ‘s internal policies and procedures for the protection of his or her personal data as well as to the internal regulation (being displayed at Rosman headquarters).

• the obligation to inform when changing his/her data

If some of the Candidate’s personal data processed by Rosman or by its collaborators are incorrect or have changed during the course of the procedure, a notification will be immediately sent to the address indicated in section 2.

12. Security measures regarding the processed data

Rosman has implemented appropriate technical and organizational measures to ensure the security of processed personal data, such as:

• the conclusion of contracts with collaborators in which they have assumed the obligation of confidentiality in respect of the information regarding the processed personal data, as well as the obligation to observe the applicable legislation in the field of personal data protection
• training all employees on the importance of protecting personal data
• setting up appropriate internal procedures
• designating a contact person for personal data issues
• implementing information security measures (installing licensed programs on employee laptops, laptop password, data encryption, etc.)
• implementing practical security measures (installing an alarm system at the location where the Candidate’s personal data is stored, keeping the documents in a closed cabinet with a key held only by the Rosman administrator, etc.)
• informing the Candidate of any amendments to the Rosman internal procedures or policies that could have a significant effect on the informed person