In accordance with the provisions of EU Regulation 679/2016, "concerning the protection of natural persons with regard to the processing of personal data, as well as the free circulation of such data and repealing Directive 95/46/EC " (“GDPR” or “Regulation”), this document briefly summarizes the regulatory principles of data processing carried out by the Grimaldi Group SpA, Grimaldi Euromed SpA, and Grimaldi Deep Sea SpA, as data controllers, in accordance with the agreement signed on 21/05/2018, in the management of applications and the selection process of employees.

Pursuant to art. 26 GDPR the aforementioned Co-Data Controllers have determined, by means of an internal agreement, the respective responsibilities, for the "HR - Personnel" and "Crew" areas, regarding the observance of the obligations deriving from the Regulations.

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Co-data controller

GRIMALDI GROUP S.p.A., con sede in Via Emerico Amari, 8 – 90139, Palermo - Codice Fiscale 00117240820 e Partita I.V.A. IT00117240820 – Fax +390815517401 – E-mail:

Co-data controller

GRIMALDI EUROMED S.p.A., con sede in Via Emerico Amari, 8 – 90139, Palermo - Codice Fiscale 00278730825 e Partita I.V.A. IT00278730825 – Fax +390815517401 – E-mail:

Co-data controller

GRIMALDI DEEP SEA S.p.A., con sede in Via Emerico Amari, 8 – 90139, Palermo - Codice Fiscale 04068550823 e Partita I.V.A. IT04068550823 – Fax +390815517401 – E-mail:


Management of applications and selection process for employees

Juridical Base

Execution of the preliminary activities to the stipulation of the employment contract

Data transfer

Possible, with your consent

User's rights

a. Access to personal data;
b. To obtain the correction or deletion of data or the restriction of processing;
c. To oppose the processing of data;
d. To obtain data portability;
e. To propose a complaint to the competent supervisory authority (e.g. Data Protection Authority);
that can be exercised by contacting the following address

  1. Purpose of the processing

    Processing operations may involve:

    • Personal data and related photos;
    • Information related to the previous work activity and the training.

    In order to manage the candidature and the possible selection process, the need to treat particular categories of data as per art. 9 of the GDPR (eg data revealing the racial or ethnic origin, religious or philosophical beliefs, trade union membership, as well as health data) provided by the candidate. The provision of such sensitive data is optional. The acquisition and processing of the same will be necessary to fulfill the obligations and exercise the specific rights of the data controller or of the interested party in the field of labor law and social security and social protection.

  2. Purposes of data processing (Article 24 letter a, b, c Privacy Code and Article 6 letter b, and GDPR)

    This data will be processed for purposes related to the execution of activities prior to the conclusion of the employment contract.

    In particular, the data will be processed:

    1. To manage applications and the personnel selection process;
    2. To extract statistical information, anonymously.
  1. Data processing methods (Article 4 of the Privacy Code and Article 5 GDPR)

    Personal data will be processed, also with the aid of IT tools, in compliance with the methods indicated in the GDPR, which provides, inter alia, that the data is:

    • Processed according to the principles of lawfulness, transparency and correctness;
    • Collected and registered for specific, explicit and legitimate purposes ("purpose restriction");
    • Adequate, relevant, and not exceeding the processing formalities ("data minimization");
    • Exact and updated ("accuracy");
    • Stored for a period of time not exceeding the achievement of the purposes for which they are processed ("storage restriction");
    • Processed through appropriate tools to guarantee security and confidentiality, including protection against unauthorized or unlawful processing and loss, destruction or accidental damage ("integrity and confidentiality").

    Personal data is stored according to the table below.


    Storage Times

    Storage Purposes

    • Personal data and related photos, certificates issued at the time of hiring (i.e. residence, qualification);
    • Information related to previous work and training path.

    2 years from the application for administrative personnel

    3 years from the application for the crew

    Contact the candidate in reference to the open positions

  1. Legal basis

    The legal basis of the processing listed above in point 1 of paragraph 2 "Purpose of the data processing" is considered in the fulfilment of pre-contractual and legal measures in order to manage the candidatures and the selection process of employees.

  1. Data transfer and/or dissemination

    The data will not be disseminated to third parties.

    Furthermore, based on laws, legal proceedings, disputes and/or request made by public or government authorities within or outside the State of residence of the Data subject, for national security purposes or matter of public importance, we may need to disseminate personal data. When legally possible, we will inform the interested party prior to such communication.
    We may also disclose personal data if we establish in good faith that such communication is reasonably necessary to assert and protect our rights and activate the remedies available.

  1. Rights of the data subject (Article 7 of the Privacy Code and Articles 15-21 GDPR)

    The data subject can, at any time, exercise the rights:

    • To access the personal data, requesting that this data be made available to him or her in an intelligible form, as well as to the purposes on which the processing is based (pursuant to Article 15);
    • To obtain the correction (pursuant to Article 16) or the cancellation (pursuant to Article 17) of the same or the restriction of processing (pursuant to Article18);
    • To obtain data portability (pursuant to Article 20);
    • To oppose the processing of data (pursuant to Article 21);
    • To lodge a complaint with the competent supervisory authority.

    The aforementioned rights can be claimed by contacting the following e-mail address

    In this regard, we also point out that the Data Protection Officer (DPO) appointed by the Company can be contacted at the following e-mail address

  2. Nature of the provision of data and consequences of any failure to communicate data

    The provision of data is necessary for the management of the application and their failure to indicate, or the request for cancellation during the selection stages, makes it impossible to proceed with the evaluation of the application and to fulfill the legal obligations and those arising from applicable national collective labor agreements.