Candidate privacy notice
Most recent update: 02/29/2024
Introduction
Regarding selection processes relating to hiring staff or assigning individual tasks, Bulgari S.p.A. and its directly and/or indirectly controlled subsidiary companies, acting in their capacity as ‘Joint Controllers’ for the specific purposes defined in this Notice (and collectively referred to under the name ‘Bulgari’), collect, process and store the personal information of candidates following registration on the careers page of the website, found at: http://careers.Bulgari.com/ and/or by other means.
Bulgari may share this information with other parties in the specific situations identified below.
This Notice provides details on the policies and practices adopted by Bulgari for the collection and processing of personal data, as well as the rights and options available to the data subject.
If you have any questions regarding the information provided, please contact Bulgari using the contact information provided at the end of this Notice.
All candidate data will be processed in accordance with this Privacy Notice, providing that said processing is not in violation of the applicable legal requirements, in which case the current regulations will prevail.
Types of candidate data collected by Bulgari
Unless otherwise stipulated in this Notice, during selection processes Bulgari may collect, share and store personal information belonging to candidates, including but not limited to:
1) Personal data
a. data relating to applications: CV, name, home address, email address, telephone number, professional and academic qualifications, background (age, gender etc.), citizenship, salary and any other information included in CVs and cover letters.
b. assessment data: tests (technical, behavioral or psychometric) given to candidates, interviews and any other information collected for candidate assessment purposes. Results taken from the Occupational Personality Questionnaire (OPQ) will be processed using an automated personal data handling process in order to evaluate certain candidate qualities and, in particular, analyze or predict candidate job preferences. Test results will always go through human verification before a final decision is made on candidates.
c. candidate survey data: identifying data and information relating to birth, bank accounts, tax systems, occupation, civil status or family.
d. sensitive data: Bulgari may handle medical data belonging to candidates (such as those with disabilities or legally protected status) in order to promote diversity and inclusion, as well as guaranteeing equal opportunities and access to employment.
d. sensitive data: Bulgari may handle medical data belonging to candidates (such as those with disabilities or legally protected status) in order to promote diversity and inclusion, as well as guaranteeing equal opportunities and access to employment.
Data collection sources
Bulgari may collect personal information provided by the candidate via the Bulgari website or to Bulgari employees. Furthermore, Bulgari may collect personal data from other legitimate sources, such as other companies within the LVMH group, publicly available sources (such as the internet, but only for information relevant to the role for which the candidate is applying), search engines and information from third parties selected by the candidate and authorized by them to share their information. Examples of third parties include recruiters, professional online networks and data providers related to candidate surveys.
What Bulgari collects and uses candidate personal data for
Selection processes
Bulgari has legitimate interests for the processing of candidate personal data during employee selection processes. The processing of candidate personal data allows Bulgari to carry out selection processes, evaluate and ascertain candidate suitability for the role they have applied for or for other roles, and decide when to issue job offers or other propositions. Bulgari will only process data relating to criminal offences if required by law for specific positions at Bulgari and in compliance with the applicable Legislation.
Legal obligations
In some instances, Bulgari must process candidate personal data in order to comply with legal, regulatory and managerial obligations and to guarantee equal opportunities and access to employment.
Consent
Some candidate information that Bulgari collects may be sensitive in nature. Unless otherwise stipulated, Bulgari will only store sensitive data when prior express consent has been provided by the data subject and/or when it is required in order to comply with legal obligations.
Reporting alleged misconduct
Bulgari may process personal data belonging to data subjects in order to report alleged misconduct and carry out the necessary preliminary activities designed to verify the validity of the reported act and in order to take necessary action.
In such a circumstance, the legal basis for data processing would be I) express consent under Art. 6 (1)(a) and Art. 9 (2)(a) of the GDPR, having been provided before the report was made on the Portal made available to the Data Controller, (II) the requirement for the Controller to comply with legal obligations (see Art. 6, paragraph 2a et seq. of Italian Legislative Decree no. 231 of 8 June 2001 ), (III) the Controller's legitimate interests, pursuant to Art. 6, paragraph 1, sub-section f) of the GDPR, who, having been made aware of the report issued, intends to protect and preserve all company assets, (IV) the express consent of the reporter to the disclosure of their identity.
How Bulgari shares candidate personal data
Bulgari may share personal information belonging to candidates if required to by law or if requested in court or by a government or police authority.
In addition, with the data subject's prior consent, Bulgari may share personal data belonging to candidates with LVMH Hennessy Moët Louis Vuitton SE and its subsidiary companies worldwide (“LVMH”), as well as outside of the European Economic Area, so that candidates may be contacted for future job offers that match their profile. Should the data subject decide not to consent to their personal information being shared with LVMH, they will not be able to be contacted regarding potential offers that match their profile and their current candidacy will not be affected.
Bulgari may also share personal data belonging to candidates with a select group of third-party service providers responsible for certain activities involved in the hiring selection processes, with agencies that carry out background checks and with companies that help Bulgari store data.
Bulgari ensures that third parties with which it shares candidate personal data (whether companies within the Bulgari group or external) handle data securely, with confidentiality and in compliance with the applicable regulations, and that data is used solely for the purposes for which it has been collected.
Transferal of personal data to other countries/regions
The organizations with which Bulgari may share personal data belonging to candidates may be based in countries/regions outside of the European Economic Area
LVMH has adopted Binding Corporate Rules (BCR) validated by the French Data Protection Authority CNIL in order to regulate data transferal within the Group and ensure a level of protection that is fundamentally the same as that ensured by the European Union.
How long Bulgari stores data for
Bulgari stores personal data belonging to unsuccessful candidates for 36 months after the end of the selection process, unless the candidate authorizes an extension to this timeframe.
For successful candidates, any personal data collected by Bulgari during the selection process will be stored as long as they are employed by the company. The time periods for which personal data is stored will be communicated in a separate privacy notice sent to employees.
How Bulgari protects candidate personal data
Bulgari has implemented technical, administrative and physical security measures to protect personal data belonging to candidates from unauthorized access and improper use. Bulgari has put in place security policies and procedures based on identified industry best practices and constantly reviews these procedures in order to implement new technologies and methodologies. Unless otherwise stipulated by law, only appropriately authorized persons may view the personal data belonging to data subjects. In addition, Bulgari trains its employees on the importance of confidentiality and of the private and secure protection of candidate personal data. Finally, Bulgari carries out regular risk assessments relating to the security of the information in its possession.
Rights of candidates
Except in specific circumstances, candidates have the right to access their personal information held by Bulgari, limit or oppose to its processing, rectify the information and/or request that it be deleted. To exercise their rights, request further information about their data or ask questions regarding Bulgari's processing of said data, candidates can send an email to privacy@bulgari.com or contact Bulgari's data Protection Officer (DPO) using the information provided at the end of this Privacy Notice.
Data controllers and processors
The website www.bulgari.com is managed by Bulgari S.p.A., with registered office at Via dei Condotti 11, Rome, acting in their capacity as Data Controller for personal data in accordance with Regulation (EU) 679/2016 (GDPR).
Regarding the processing of personal data for the management of whistleblowing reports, the data controllers will be both LVMH Moët Hennessy Louis Vuitton SE and the individual companies within the Bulgari Group, with these companies acting as joint controllers pursuant to Art. 26 GDPR. A complete list of data processors designated by controllers may also be requested by sending an email to privacy@bulgari.com.