Privacy notice for applicants

The data controller is Talenty S.r.l., Via Antonio da Mestre 19, 30174 Venice, Italy, VAT and tax code 04468120276, REA VE-417567.

For anything concerning your data, including exercising your rights, write to info@talenty.green. We reply within one month.

We have not appointed a data protection officer: we checked that the conditions set out in Article 37 do not apply, and the assessment is documented and dated. The contact point for data protection matters is Alessandro Ardit, at the same address. The full reasoning is in the note on the data protection officer.

• Contact details: first name, last name, email, phone, city.
• Your CV and what it contains: education, experience, skills, languages.
• What you tell us during interviews, and their transcript if you consented to it.
• The outcome of the orientation test, if you choose to take it.
• Our correspondence with you, and the assessment notes we write ourselves.

Please do not include special categories of data in your CV: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation. We do not need them to assess an application, we do not ask for them and we do not use them.

If we find them in a CV we remove them before filing it, where that is possible, without discarding the CV. They are never assessed and never passed on to clients.

One exception: membership of the protected categories under Italian Law 68/1999, which you may state if you want to be considered for roles reserved to targeted placement. In that case the processing is based on Article 9.2.b. We never process criminal or disciplinary records, not even if you volunteer them.

• Your application to a job posting, through the form on the position page. The form belongs to the applicant tracking system we use and is hosted inside our page.
• A CV you sent us on your own initiative.
• A search of ours. We do head hunting, so we may contact you after seeing your profile on a public professional channel. In that case the data did not come from you: our first message tells you exactly where we found you and links this notice.
• A referral from someone who knows you professionally. Here too, we tell you at first contact.

When we look you up online we set ourselves strict limits: we only consult professional channels, and only for information connected to the skills the role requires. We do not look at personal social profiles.

We ask for references only with your explicit authorisation, never behind your back.

Each purpose has its own legal basis, and they are not all the same. In particular, we do not ask for your consent in order to assess your application, and that is not an oversight: the processing serves a request you made, and the law allows it without consent precisely for that reason. Consent asked where it is not needed would be fictitious, because you could not withdraw it without giving up your application.

• Assessing your application for the role, presenting you to the client company and running the selection process. Legal basis: pre-contractual measures taken at your request, Article 6.1.b.
• Keeping your profile in our talent pool to offer you future positions. Legal basis: our legitimate interest in maintaining a pool of qualified profiles, Article 6.1.f. You can object at any time.
• Contacting you following a search of ours, when your profile matches an open position. Legal basis: legitimate interest, Article 6.1.f. Here too you can object, and from that moment we stop contacting you.
• Meeting the legal obligations that apply to our activity, which is licensed and supervised, and our tax and accounting obligations. Legal basis: legal obligation, Article 6.1.c.
• Defending a legal claim, should it become necessary. Legal basis: legitimate interest, Article 6.1.f.
• Studying, in aggregate form, how people orient themselves in green jobs, to understand how the market changes and to improve our own tools. This purpose works only on irreversibly anonymised data, which no longer allows anyone to be identified: from that point it is no longer personal data. Legal basis: Article 5.1.b, under which processing for statistical purposes is not incompatible with the purpose for which the data was collected.

For the two purposes based on legitimate interest we have written a balancing assessment, that is the reasoning by which we weighed our interest against your rights. You can request a copy by writing to info@talenty.green.

The test comes in two forms, and the reason we process your answers changes with it.

If you find it on our website and choose to take it, it is optional and based on your consent, which you can withdraw at any time. Not taking it, or stopping halfway, has no effect on how your application is assessed, and we keep no record anywhere of the fact that you chose not to take it.

If one of our recruiters sends it to you during a live selection, it is part of the assessment for that role and rests on pre-contractual measures taken at your request: we do not ask for your consent, the outcome reaches the client company together with your profile, and if you prefer not to take it your application stands, but that part of the assessment cannot be made.

Nobody sees your answers to the individual questions. They are processed by an algorithm that produces a summary of your values and your orientation towards roles and sectors. Not even the psychologist who designed the questionnaire sees the answers. You see the summary.

The outcome goes back to you. In the test you take of your own accord, sharing it with the recruiter and with the client companies we present you to is a separate choice of yours: we ask for it with a separate tick box, which you can leave empty without consequences, because the test runs either way. In the test administered during a selection the outcome is part of the assessment and reaches the client with your profile. In both cases we pass on a written summary of your professional preferences: never the scores, never the answers, no personality labels.

The algorithm is a calculation defined by a person, not an artificial intelligence system. Technically it is profiling, but it is not an automated decision: it decides nothing about you.

We keep answers and outcome for forty-eight months from the last meaningful contact, like the rest of your application: the test has no rule of its own. If the test rested on your consent and you withdraw it, we delete them straight away.

We record which consents you gave and when, together with the exact version of the text you read: it is how we can show, even years later, what you had agreed to. At the bottom of your profile page you can read in plain words what is recorded in your name, and how to withdraw it.

Your profile is yours to reopen. The browser you took the test on keeps a technical key that lets you open it again. From another device we send it to you by email, with a link valid for twenty-four hours: delivery to your address is how we check it is you, with no sign-up and no extra password to remember. From the same page you can retake the test: the previous outcome is not deleted, it is marked as superseded.

Remote interviews take place on Microsoft Teams and may be recorded and transcribed. This happens only if you consented, and we ask for that consent in the invitation, before the call, not while it is already running.

The automatic notice that appears in the call when recording starts is not the consent: it is only a reminder. The consent is the one you gave beforehand, and it is free. If you say no, no record of that is kept anywhere and your application proceeds exactly the same.

You can change your mind afterwards too: write to us and we delete the recording. Otherwise recordings and transcripts are deleted automatically after six months. The client company receives the profile summary we write, never the recording and never the transcript.

We use it for one thing only: summarising CVs and transcripts to prepare the profile we present to the client. Every summary is read, corrected and completed by a person before it leaves.

We do not use it to score you, to classify you, to rank you against other people or to decide whether you move forward. Screening, assessment and decisions are made by people, and we do not cross that line.

You are therefore not subject to decisions based solely on automated processing within the meaning of Article 22.

The client companies we run the search for, but only after telling you and receiving your agreement, naming the company. The client receives your data as an independent controller and uses it to assess your application for that role: it must provide you with its own privacy notice, and from that point the rights over its own processing are exercised against it.

The suppliers who process data on our behalf, bound by a contract that requires them to follow our instructions: Microsoft, for the CRM, email and video calls, with data stored in Italy; Google, which hosts on Drive the profiles already presented to a client, with data stored in Europe; the United States supplier of the applicant tracking system; OpenAI, for the summarising tools; Amazon Web Services, for the website, with servers in Frankfurt.

When we present you to a client, the profile we send stays filed on Google Drive, in a company space with restricted access and data held in Europe.

Advisers and authorities, where a legal obligation requires it. We do not sell your data to anyone and we do not use it for advertising.

All the client companies we present you to are established in the European Union. Presenting a profile to a client therefore does not currently involve any transfer outside the Union. Should that change, we would tell you first, naming the company and the country.

The applicant tracking system stores data inside our own Microsoft environment, in Italy, even though the company that develops it is established in the United States and accesses it for support. The summarising tool does remain in the United States: that transfer rests on the standard contractual clauses approved by the European Commission with implementing decision (EU) 2021/914, included in the data processing agreement signed with the supplier. You can request a copy by writing to info@talenty.green.

Should we ever present you to a company established outside the European Economic Area, we would tell you first, naming the company and the country, and the transfer would rest either on an adequacy decision of the European Commission or on the same standard contractual clauses.

To be confirmed: the data processing agreements with the suppliers are still being obtained. Until they are on file, this section describes the safeguard the suppliers declare, not a copy in our possession.

• CV and application data: forty-eight months from the last meaningful contact. Every time you apply for a new role, attend an interview, reply to a proposal of ours or confirm that you want to stay in the talent pool, the clock starts again. After forty-eight months with no contact at all, the data is deleted.
• Interview recordings and transcripts: six months.
• Orientation test answers and outcome: forty-eight months from the last meaningful contact, like the rest of the application. After that we anonymise them irreversibly and they remain only as statistical data. If the test rested on your consent and you withdraw it, we delete them straight away.
• If we contacted you through a direct search: we delete within seven days any data gathered for a contact we then do not make, and within thirty days of the second and final message the profile of anyone who does not reply. If you tell us you are not interested, we delete immediately.

You can ask for deletion at any time, without giving a reason, by writing to info@talenty.green: we carry it out without waiting for the deadline. Some data stays longer where the law requires it, for example tax and accounting records, or where it is needed to defend a legal claim in a pending dispute.

Just write to us. We delete your profile, but we keep the bare minimum needed to remember not to contact you again: in practice your email address, in a list that serves only that purpose.

It sounds like a paradox, and it is instead the only way to honour your request: if we deleted everything, a year from now one of our searches could find your public profile and start over. That list is used for nothing else, it is not a marketing list, and you can ask us to remove that too.

The right to object matters most here, because two of our purposes rest on legitimate interest: you can object to staying in the talent pool and to being contacted, at any time and without giving a reason.

You can also ask us to access your data, to correct it, to erase it, to restrict its processing and to receive it in a machine readable format. Where processing is based on consent, as with the test and interview recording, you can withdraw it at any time, without affecting what was done before.

Write to info@talenty.green, saying what you want. We reply within one month, and if the request is complex we tell you within a month that we need more time, explaining why. We do not ask for identity documents unless it is necessary to establish who you are.

If you are not satisfied with our answer you can lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali, or bring the matter before a court.

If we change how we handle applicants' data, we update this page and the date at the top. When the change is significant we tell you, rather than waiting for you to notice.