Data Processing Policy

The Staffing Company, a French simplified joint stock company (société par actions simplifiée) with share capital of 957 euros, registered in the Evry Trade and Companies Register under number 987 388 162, having its registered office at 8 Allée de la Tour, 91760 Itteville (hereinafter the « Company » or « The Staffing Company »), represented by Insynia, a French simplified joint stock company (société par actions simplifiée), registered in the Paris Trade and Companies Register under number 983 803 388, having its registered office at 8 Allée de la Tour, 91760 Itteville, itself represented by Mr Terry Raimondo, its Chairman, collects and processes the personal data of the persons who accept it with a view to being presented as an applicant for a job offer (hereinafter the « Applicant » ou « You »).

The Staffing Company takes care to protect the privacy and personal data of Applicants. As such, it is responsible for adopting and complying with a personal data processing policy in accordance with the regulations in force and in particular the General Data Protection Regulation no. 2016/679 dated April 27, 2016 (the « GDPR ») and the French Data Protection Act of 1978 as amended.

Thus, the purpose of this policy relating to privacy and protection of personal data (the « Politique ») is to set out the terms and conditions for the processing of personal data by the Company with regard to Applicants.

The Staffing Company reserves the right to amend the Policy at any time and agrees to notify Applicants of such amendments via a notification when using the Services.

The data controller

The Staffing Company is responsible for processing personal data collected and processed in accordance with the terms of this Policy applicable to Applicants.

You may contact The Staffing Company using the contact details provided in the preamble or Article 9 « Contact » of this Policy.

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The data controller is the person, in this case the Company, who determines the terms and purposes for the processing of personal data. As its name indicates, it assumes responsibility for the processing of personal data that it implements and is the User's main contact for asserting its rights in respect of the processing.

2. Sources and categories of personal data

2.1. Source and collection of personal data

The Staffing Company collects Applicants' personal data with a view to presenting them to its clients, with the aim of facilitating the recruitment of Applicants. In particular, The Staffing Company collects and processes Applicants' personal data at the time of:

an unsolicited application from an Applicant for a job offer proposed by The Staffing Company;
direct exchanges between the Applicant and The Staffing Company employees via social media (in particular LinkedIn) as part of a profile search assignment given to The Staffing Company;
indirect collection (taking references from a former employer (colleague, client, etc.) from the Applicant; exchanges with third parties who know the Applicant, who have provided the Applicant's personal data to The Staffing Company; information obtained on professional social networks, etc.;

The Staffing Company also processes any personal data provided spontaneously and voluntarily, particularly when Applicants contact The Staffing Company.

2.2. Categories of personal data

The Company collects and processes the following categories of personal data:

Information required to contact and identify the Applicant: Personal data: last name, first name, telephone number and email address of the Applicant.
Information relating to the Applicant's training: Personal data: training (diplomas, qualifications); schools and educational institutions attended, start and end dates.
Information relating to the Applicant's work experience: Personal data: title of the position, name of the organisation, start and end dates, job description, current or desired salary, location, availability date
Information relating to assessment of the Applicant's personality: Personal data: results of personality, aptitude and motivation tests.
Information required to create the Applicant Profile: Personal data: LinkedIn URL.

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In principle it is forbidden to ask an applicant: his/her social security number and bank details (except in the specific case of temporary employment agencies in their capacity as employer); information relating to members of his/her family; if the applicant wishes to have children; his/her measurements, weight, hair colour, etc., except for certain types of specific positions (models, racing drivers, jockeys, etc.).

As part of the recruitment process, only data that is appropriate, relevant and strictly necessary for selecting the applicant for a given position and conducting the job interview may be collected.

2.3. The mandatory nature of data provision

Some information may be mandatory for putting the Applicant in contact with and presenting him/her to The Staffing Company's clients. If the mandatory data are not provided (email and telephone number), The Staffing Company will not be able to put the Applicant in contact with its clients.

2.4. Data accuracy

The Staffing Company makes every effort to ensure that personal data are accurate and complete. In order to assure You that we have up-to-date information, You may notify us of any change to your contact details or any other data, by contacting the Company using the details mentioned in Article 9 "Contact" below.

2.5. Location of personal data

The personal data collected for which The Staffing Company is responsible are hosted in the European Union on The Staffing Company's servers hosted by Google Cloud France.

Further details concerning the guarantees concerning data transfers outside the European Economic Area are given in Article 6 below.

3. Sources and categories of personal data

Personal data are processed by The Staffing Company for the following purposes:

Searching for, identifying and collecting relevant profiles to generate applications:

creation of a CV library,
making direct contact.

Assessing an applicant's ability to occupy a position, pre-selecting applicants, in accordance with Applicants' rights:

sorting, saving and filing CVs and cover letters in a database.

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For the above processing, The Staffing Company's legitimate interest is to provide its business customers with the best level of service by submitting the most relevant applications in the shortest possible time.

Finally, data are collected to meet legal obligations:

Managing collection
Detecting, investigating, preventing or taking action regarding illegal activities, abuse, suspected fraud or situations involving potential threats to the security or rights of an individual or entity and to use as evidence in litigation
Investigating, averting and preventing violations of this Policy
Protecting and defending our rights and interests, including our intellectual property rights before the competent courts

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For the above purposes, the legitimate interest of the Company is to ensure that its rights are respected and enforce them as well as to prevent fraud and any prohibited or illegal activity.

4. Provision of personal data

Collected and processed personal data may be sent to:

Authorised persons from the relevant departments within The Staffing Company;
In the event of an offence, theft or other breach of the GTCS or the law, personal data may be transferred to our insurance company and/or brokerage company, which is required to maintain the confidentiality of the data sent and, where applicable, to the police and legal services.
The administrative and judicial authorities and more generally to public bodies in the context of compliance with our legal obligations or to allow us to defend our rights and interests,
Our legal advisers and lawyers, where necessary,
If we sell or transfer our business or part thereof and your personal data relate to the part sold or transferred, or if we merge with another business, we will share your personal data with the new business owner or our merger partner, respectively.

5. Security of personal data

The Staffing Company implements organisational, technical, software and physical security measures to protect personal data against loss, unauthorised access, disclosure or alteration.

6. Data transfer outside the European Economic Area

Your personal data may be transferred to countries outside the European Economic Area (hereinafter the “EEA”), in particular to our business partners.

In order to provide protection equivalent to that offered in the EEA, a territorial area outside which the GDPR standards are not applicable, data transfers outside the EEA are governed by contractual clauses based on the European Commission's standard clauses.

7. Data retention

The Staffing Company retains your personal data for the time necessary to achieve the intended purposes, plus any statutory archiving, data retention and limitation periods, where necessary. After processing, personal data will be either deleted or anonymised by the Company.

For more information on the retention period of your personal data, please contact us using the contact details given in Article 9 « Contact » below.

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If the applicant consents, it is possible to retain the data after the recruitment decision is made for a reasonable period which must be set in consideration of the type of position concerned and for a maximum period of 10 years from the last contact with the unsuccessful applicant. The sole purpose of this data retention must be to contact the applicant again in the event of new opportunities or to enter the data into an "applicant pool" type database.

8. User rights

Users are informed that they have, under the conditions of the GDPR and the laws applicable in France, a right of access, rectification, erasure and portability of their personal data, as well as a right of limitation and objection to the processing of these data.

Users also have the right to determine the fate of their personal data in the event of death, as well as the right to lodge a complaint with the CNIL, whose website is accessible at the following address http://www.cnil.fr and whose registered office is located at 3 Place de Fontenoy, 75007 Paris.

For processing based on his/her consent, the User may withdraw consent at any time, without affecting the lawfulness of the processing prior to this withdrawal.

Users may exercise their rights with the Company, free of charge, using the contact details given in Article 9 « Contact » below, except in the event of a manifestly excessive request, in which case fees may be applied.

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Outre les informations ci-après, la Société invite l'Utilisateur à consulter le site de la CNIL :

Right of access: the User shall have the right to obtain from the Company confirmation as to whether or not personal data concerning him/her are being processed, and, where that is the case, access to the personal data and information relating to the purposes of the processing (Art. 15 of Regulation 2016/679 on the protection of personal data ("GDPR")). Manifestly unfounded, excessive or repeated requests may not receive a response or may generate fees.
Right of rectification: the User shall have the right to obtain from the Company without undue delay the rectification of inaccurate personal data concerning him/her (Art. 16 of the GDPR).
Right to erasure: the User shall have the right to obtain from the Company the erasure of personal data concerning him/her, under the conditions provided for in Article 17 of the GDPR.
Right to portability: the User shall have the right to receive the personal data concerning him/her, which he/she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party (Art. 20 of the GDPR).
Right to restriction of processing: the User shall have the right to obtain from the Company restriction of processing of his/her personal data under the conditions of Article 18 of the GDPR.
Right to withdraw consent: Users shall have the right to withdraw their consent to the processing of your data if this processing is based on consent. The withdrawal of this consent does not affect the lawfulness of the processing based on the consent granted before its withdrawal.
Right to object: the User shall have the right to object on grounds relating to his/her particular situation, at any time to processing of personal data concerning him/her, which is based on legitimate interest and under the conditions of Article 21 of the GDPR.
Right to determine the fate of his/her personal data in the event of death: the User shall have the right to define general or specific guidelines relating to the storage, erasure and communication of his/her personal data after his/her death (law 78-17 of 6 January 1978 as amended, Art. 40, II).
Right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or judicial remedy, the User shall have the right to lodge a complaint with a supervisory authority if he/she considers that the processing of personal data relating to him/her infringes the regulations applicable to personal data (Art. 77 of the GDPR).

9. Contact

For more information on the processing of your personal data or to exercise your rights, You can contact us using the following contact details:

The Staffing Company
8 Allée de la Tour
91760 Itteville

Email : [email protected]
Téléphone : +33 (0)1 69 37 96 33