The House of Data Imperiali bulletins are extracts from the articles of the Legal Information Service (SIG) edited by Mr. Rosario Imperiali d’Afflitto.

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Legal bases for personnel data processing

In its February 14, 2024 newsletter, the Italian Data Protection Authority informs of the approval of the code of conduct for employment agencies.

As specified in the press release, “the code defines good practices for the correct processing of data carried out in the context of personnel intermediation, search and selection activities“.

For the first time, the same measure by the authority also accredited the monitoring body, which is the independent body called to verify adherents’ compliance with the code and resolve any complaints.

In the approval of previous codes of conduct, in fact, the accreditation of the monitoring body had always taken place by a measure subsequent to that of the approval of the code of conduct, so the entry into force was postponed to the moment after the accreditation.

In the case of the code for employment agencies, on the contrary, it will come into force the day after its publication in the Official Gazette.

Code approval measure

As usual, the code for employment agencies is preceded by the Authority’s approval order of January 11, 2024 (web doc no. 9983415).

Specifically, the code of conduct is structured as follows:

  • The text of the code of conduct for the employment agency sector
  • Annex 1, containing an example of a typical agency processing register
  • Annex 2, which contains the model information notice for the processing of candidates’ personal data.

We defer the examination of the content of the Code of Conduct to a possible future discussion while, on this occasion, we will focus on some insights that are offered by examining the facsimile of a typical processing register for employment agencies, included in Annex 1 of the Code of Conduct.