RUCODEM – Romanian Union of Cosmetics and Detergents Manufacturers (further referred to as “RUCODEM”), as a Personal Data Operator, collects and processes certain information about individuals.
These individuals, also known as “data subjects”, can include members’ representatives, service suppliers, partners, collaborators, contacts, participants to events, employees and other people whose data is processed by RUCODEM as detailed below.
RUCODEM is engaged to handle personal data in compliance with applicable data protection laws, the General Data Protection Regulation (“GDPR” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.).
- Personal data collected
Personal data means any information relating to an identified or identifiable natural person (“Data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific elements, physical, physiological, genetic, psychological, economic, cultural or social identity.
RUCODEM may collect the following categories of personal data to the extent necessary to achieve the purposes outlined in this policy:
- Identification data, such as first name, name, photographs;
- Contact data, such as email address, telephone number, postal address
- Personal information, such as age, date of birth, gender, citizenship;
- Financial data, such as bank account details;
- Education and profession and employment data, such as university, specialisation, function, past employers;
In most cases, RUCODEM collects personal data directly from the data subjects, but it may sometimes obtain personal data from third parties (such as the data subject’s employer or from a public authority).
- Purpose of the processing and the duration of personal data retention
RUCODEM processes personal data of candidates who apply for job positions at RUCODEM solely for the purpose of recruitment activities, on the basis of a legitimate interest consisting of steps taken at the request of the person concerned with a view to concluding an individual labor contract.
RUCODEM does not keep this data more then it is necessary, meaning only on the period of finalising the recruitment for the respective position.
As part of its general activities, RUCODEM processes personal data for the following purposes:
3.1.Communication with members and administration of membership fees collection
RUCODEM has legitimate interests in processing of personal data of the contact persons of Members, of contact persons appointed to be part of Council of Directors, of the working groups, and for the purpose of administering the membership and collecting membership fees.
RUCODEM also, in accordance with legal obligations regarding the organization of general meetings and board meetings, processes the data of members’ representatives.
Retention period: While possessing a membership, but not more than 4 years after the end of this membership. If the member’s representative will be replaced during this period, the data of the former representative shall be retained for a period of 4 years from the date of acknowledgment of the change.
3.2.Performing the formalities regarding the conclusion, execution and termination of the contracts concluded by the association
RUCODEM has legitimate interests in the processing of personal data of the representatives, contacts and employees of the entities with which RUCODEM has contractual services, consultancy services.
Retention period:During the duration of the contract, but not more than the legal term provided in this case. In the absence of such a term, the retention period will be 4 years from the date of termination of the contract.
3.3.Promotion, collaboration and public relations
RUCODEM processes contact details of representatives of the national/EU/International authorities and bodies, Members of the Romanian Parliament and EU Parliament, representatives of the European Commission and of EU Member States,bodies, professors, members and representatives of other national and EU associations. This processing is based on the legitimate interest of RUCODEM, which consists in carrying out the formalities for initiating or developing collaboration relations.
Retention period: During the collaboration
3.4.Organising events, seminars, workshops, conferences
RUCODEM processes identification details of individuals who register / confirm to participate to events, seminars, workshops,conferences organised by the organisation for the purpose of managing the registration and participation to such events, based on the necessity to meet its obligations as organiser of the events under the general terms and conditions that are expressly accepted by the individuals and/or based on consent for providing certain personal data.
Retention period: While possessing a membership, but not more than 4 years after the end of the membership. If the member’s representative will be replaced during this period, the data of the former representative shall be retained for a period of 4 years from the date of acknowledgment of the change.
For consent-based processing, the data is retained until the consent is withdrawn, but not later than the dates indicated above.
3.5. Navigating the web site
Retention time: During the session
3.6. Contact with website users and management and treatment of their requests
The personal data of users who contact RUCODEM via any of the contact channels made available through the Website to receive requests and / or user requests will be processed in order to maintain contact between the parties, management of website users, the provision of user support services and the management and resolution of such demands and requests.
Retention time: During the resolution process of the request/resolution, but no later than 3 years from the date of collection
3.7. Carrying out the recruitment process
RUCODEM processes personal data received from the candidates applying for vacancies under its legitimate interest in taking action at the request of the data subject for the conclusion of an individual employment contract.
Retention time: During the recruitment process.
- Transfer of personal data
RUCODEM does not transfer personal data outside of the European Economic Area (EEA), unless necessary and lawful reasons.
In the context of the operations described above, your personal data may be transferred abroad to European Union (“EU”) countries or the European Economic Area (“EEA”).
As regards the transfer to states that do not provide an adequate level of protection for the processing of personal data, RUCODEM will use the following mechanisms to ensure the safeguards required by the GDPR: standard clauses that can be obtained from RUCODEM or consulted at the firstname.lastname@example.org
- Rights of data subjects and the way to exercise them
As data subject, you have the following rights with view to personal data RUCODEM holds about you, subject to applicable legal restrictions:
- Right to access your personal data – You have the right to access your data to know which of the personal data we process concerns you and what are the conditions under which it is processed
- Right to rectify or deleteincorrect or incompletepersonal data – Under certain circumstances, you have the right to rectify personal data that you consider to be inaccurate and concerns you, and is subject to processing by RUCODEM, as well as the right to request data deletion when, among other reasons, the data is no longer required for the purposes for which it was collected.
- The right to restrict the processing of your personal data – in certain circumstances, you may request that your data processing be restrained, in which case we inform you that we will retain the data with which you requested restriction of processing solely for the exercise or defense of a right in justice.
- The right to data portability, that is to say, the right to receive personal data concerning you in a structured, commonly used and readable form, and to transmit this data to another operator;
- The right to objectto all or part of the processing, when legally allowed;
- The right not to be subjectto automated individual decision-making, including profiling within the limits set out by the law;
- The right to withdraw consent atany time when we process your personal data based on your consent;
- Right to lodge a complaintto the National Supervisory Authority for Personal Data Processing from Romania (ANSPDCP).
If you wish to exercise any of these rights or if you are not satisfied about how RUCODEM protects your privacy, you should address your request by email together with a copy of your ID (which will only be used to verify your identity), to RUCODEM, at the following address: email@example.com
The data subjects will not be charged for the exercise of the above detailed rights, unless the claims are unfounded or excessive (eg, repetitive). In such a case, RUCODEM may refuse to act on demand.
- Changes to this policy
Last update: December 29, 2018