Last Updated 31/10/2023
Data protection policy applicable to recruitment carried out by relevanC
The data collected during the examination of your profile as well as your application, are the subject of computerised processing by the human resources department of RelevanC, a simplified joint stock company, with a capital of 252,631,00 euros, registered under number 824 155 824 at the RCS of Saint-Etienne (hereinafter «RelevanC»), allowing it to manage the recruitment process of its future employees.
What is the purpose of processing your personal data, and what are the legal bases applicable to such processing?
The processing deployed by RelevanC’s human resources department has the following purposes:
Search for relevant profiles: use of websites offering job offers on the Internet to candidates (Welcome to the Jungle and LinkedIn)
The development of a “pool of applications” database or the creation of a CV library.
Consent when you make a spontaneous application when no position is available or when you expressly request to join our pool of candidates in order to receive our job offers.
Legitimate interest when your application is not selected after a recruitment process, but the human resources department informs you that it wishes to keep your CV in order to offer you future job offers. In this case, you have the right at any time to object to the retention of your CV by RelevanC under the conditions detailed below.
Screening and selection of candidates: sorting, recording and filing of CVs and cover letters in paper form or in a database, etc.
Performance of the contract (pre-contractual measures)
Contact with the candidate to assess the candidate’s ability and measure his professional skills: processing of information collected during telephone interviews, face-to-face, etc.
Legitimate interests when the human resources department contacts you without prior solicitation from you (for example, as part of the direct approach of candidates).
Performance of the contract (pre-contractual measures) when the contact by the human resources department is made at your request (for example, as part of a spontaneous application or a response to a job offer).
Only when your application has been successful:
Performance of the contract (pre-contractual measures) and compliance with legal obligations
What personal data type will be collected and processed?
To meet these purposes, only personal information strictly necessary to assess your ability to perform the proposed role. To this end, we will ask you for data relating to the diplomas you have obtained, your professional experience, your professional skills and abilities in connection with the proposed position. Failure to provide this data will make it impossible for you to participate in the recruitment process.
In the event that your application is successful, we will ask you for information and supporting documents necessary to complete the mandatory formalities for the conclusion of your employment contract. The transmission of this information determines the conclusion of the employment contract for the selected candidates. In addition, the communication of certain categories of information and supporting documents (marital status, domicile, social security registration number, regularity of stay, etc.) has a regulatory character for selected applications. Consequently, failure to provide this data will make it impossible to conclude the employment contract.
What is the storage period for your personal data?
Your data is kept for the time necessary to complete the recruitment process.
The data concerning the selected candidates will be included in their administrative file and will be kept for the applicable retention period (up to six years after the end of the employment relationship).
In case of an unsuccessful application, your data will be kept exclusively in order to feed our CV library and to offer you, the case may be, new job offers. In this case, your data will be kept for a period of two years from our last contact with you, unless you object to the retention of your CV by RelevanC.
Data concerning candidates may be kept in an intermediate archiving database for probationary purposes (e.g., in case of discrimination claim) for a period of five years from the end of the recruitment process.
Who accesses the personal data collected during the examination of your application?
Your file is treated confidentially. Only those responsible for the departments interested in your application (recruitment officers, managers, etc.) have access to the personal data contained therein.
Furthermore, when you submit your application on websites offering job offers (e.g. Welcome to the Jungle or LinkedIn), your data may be processed by these third-party entities. For more information on the processing of your personal data by these third parties, we invite you to consult the privacy policies specific to each of them.
Your data may also be transmitted to the publishers of software solutions used by RelevanC in the context of recruitment.
Finally, in case of a positive outcome to the recruitment process, in order to finalise the recruitment, the human resources department will have to transmit some of the information collected to the organisations informed of your hiring (including employment insurance, health insurance, pension, mutual insurance).
The transmission of personal data to the recipients (subcontractor, controller or simple recipient) is carried out in a secure manner and pursuant to an agreement between RelevanC and each recipient. RelevanC undertakes to ensure that each recipient is aware of the guiding principles for the protection of personal data and is subject to them in accordance with the law and/or a specific contract.
What if RelevanC collects your personal data indirectly?
RelevanC may indirectly collect your personal data in the following cases:
- Initial collection of your personal data by the Casino Group: in certain situations, your personal data may be the subject of an initial collection by Casino Services (entity of the Casino Group). Your personal data is then transmitted by Casino Services to RelevanC. In this case, RelevanC processes the aforementioned data as joint controller with Casino Services.
- Initial Collection of your Personal Data by a third-party recruitment firm: In certain situations, your personal data may be initially collected by a third party recruitment firm. Your personal data is then transmitted by the recruitment firm to RelevanC. In this case, RelevanC processes the aforementioned data as an independent data controller. The recruitment firm will proceed with this processing as an independent data controller (for example when it establishes a pool of candidates), or, more rarely, as a subcontractor of RelevanC.
- Initial collection of your data on professional social networks: in certain situations, RelevanC recruitment team will collect your personal data publicly available on professional social networks such as LinkedIn in order to contact you (direct approach of candidates). In this case, RelevanC processes the aforementioned data as an independent data controller.
The categories of personal data concerning you, which may be collected in the aforementioned cases, are as follows:
- Last name, first name, address, education, and career path, or any other information that appears in your CV (data from sources not accessible to the public) or that is detailed in your public profile on professional social networks (data from publicly available sources).
- Information collected through interviews conducted by the entity that collected the personal data such as information provided to the recruitment firm as part of a prior interview. These data are not from publicly available sources.
What are your rights, and how can you exercise them?
you have the following rights:
- right of access to your personal data;
- right to rectification of your personal data if it is inaccurate or incomplete;
- right to restriction of processing under the conditions referred to in Article 18 of Regulation (EU) 2016/679 of 27 April 2016;
- right to delete your personal data if:
- your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
- you withdraw your consent to processing that is subject to your consent (e.g.: storage of your CV into a CV library);
- you object to the processing;
- your personal data has been unlawfully processed; or
- a law requires the deletion of your personal data.
- right to object to the processing of your personal data;
- right to data portability;
- right to define guidelines for the disposition of your personal data after your death; and
- for processing based on consent, to withdraw your consent at any time.
With regard to the retention of your CV by RelevanC for the purpose of creating a CV library on the basis of legitimate interest, you have, at any time and without any need to provide justification, the right to object to this retention.
For any questions regarding the protection of your personal data or to exercise your rights, you can contact the Data Protection Officer (DPO) of RelevanC at the following email address email@example.com or by post addressed to the DPO at the following postal address 35 Boulevard de Sébastopol, 75001 Paris.
In case of difficulties, you can submit a complaint to the French Data Protection Authority (CNIL) (www.cnil.fr).