CANDIDATES’ PRIVACY POLICY

Revised March 2023

1. PREAMBLE

Because a candidate who entrusts his or her application to Europa Group (hereinafter "we"), demonstrates his or her genuine interest in and confidence in us, we undertake to process his or her application with a high level of security and confidentiality, in accordance with the applicable legislation on data protection (General Data Protection Regulation no. 2006/679 and French Data Protection Act no. 78-17).

To best assist candidates (hereinafter referred to as "you") in their application process, this policy sets out the terms and conditions for the processing of their personal data to which we have access during the selection and recruitment process.

It is important that you read this policy, as by submitting your application you acknowledge that you have read, understood, and agree with it.

2. THE TYPE OF DATA COLLECTED

Europa Group, in its capacity as data controller, is the only entity competent to collect and process your data.

If you wish to know what type of personal data we may collect, please note that we only process data that you provide to us as part of your application, whether mandatory or optional.

In this respect, we process and use the following data:

• Identity, civil status, contact details (telephone, address, e-mail, social network accounts, etc.), identification data.
• Data relating to professional life (employment, career, contact details of current and former employers, training information, academic information, previous professional experience, etc.).
• Photograph (optional).
• Information collected during the interview.

And more generally, any personal data that you provide to us in the context of the implementation of our recruitment service.

We indicate the mandatory information with an asterisk and the possible consequences of not providing this information.

3. YOUR SENSITIVE DATA

We do not ask candidates to provide us with sensitive data such as: racial or ethnic origin, political opinions, religious beliefs, sexual life or orientation, trade union membership, etc.

As this data is not necessary for the selection and recruitment of candidates, we ask you to limit the information you provide to what is strictly professional and useful for your recruitment. Please make sure that the documents you send us do not contain sensitive information such as that mentioned above.

4. COLLECTION TECHNIQUES

Data may be collected in two ways:

• Direct collection of your data: this is the case when the data is communicated to us directly by you, when you contact one of Europa Group's employees directly, or when you respond to an advertisement posted on our site.
• Indirect collection of your data: this is carried out via the intervention of a specialised company, such as headhunters, via recruitment sites, etc.

5. PURPOSES OF COLLECTION

Please be assured that we only use and process your data for the purposes of the selection and recruitment process, namely:

• Administration and processing of your data.
• Assessment of the suitability of the application for the post.
• Checking your background.
• Contacting you to arrange one or more interviews.
• Preparation of an employment / internship contract should your application be successful.

6. LEGAL BASIS FOR COLLECTION

The legislation in force requires that the processing of your personal data has one or more legal bases.

This is why the processing that we carry out is carried out in accordance with the following legal bases:

• the processing of your data allows us to consider your recruitment and constitutes the execution of a pre-contractual measure likely to lead to the signature of an employment contract.
• we have a legitimate interest in collecting your data in relation to the recruitment of personalities in the context of our activity.

7. ACCESS TO YOUR PERSONAL DATA

We ensure that access to your data is restricted to those involved in the recruitment process, namely: managers, and, if Europa Group deems it necessary, employees of departments interested in your application and members of the human resources department.

Occasionally, our IT department may have access to your personal data for the purpose of maintenance and servicing of our IT system.

The recipients of your personal data as well as the IT department are subject to an obligation of confidentiality.

Your personal data will not be disclosed to third parties under any circumstances, except where we are required to do so by a governmental or judicial authority or by a regulatory body.

8. TRANSFER OUTSIDE THE EUROPEAN UNION

Your data will not be transferred and processed in a country outside the European Union.

9. RETENTION PERIOD

When an application is selected at the end of the recruitment process, it is kept under the conditions and for the duration defined in the Europa Group's employee data policy.

All unsuccessful applications are deleted at the end of the recruitment process.
Nevertheless, Europa Group reserves the right, for certain profiles, to keep them for future opportunities and for which the data may be kept for a maximum of two years from the last contact, unless the candidate concerned objects.

10. YOUR RIGHTS

The collection of your personal data does not mean that you are dispossessed of them.

As an applicant whose data is processed, you have the following rights:

• Right of access and copy: the applicant has the right to obtain from Europa Group confirmation as to whether his/her personal data are being processed and, where they are, access to said data. The applicant may obtain from Europa Group information on the purpose of the processing, the categories of data concerned and the recipients or categories of recipients.

The applicant also has the right to obtain a copy of the personal data being processed. For any additional request for a copy, Europa Group may require the applicant to bear the financial burden of this cost. If the request is made electronically then the information provided is in a commonly used electronic form, unless otherwise requested.

• Right of rectification and right to erasure: the applicant may obtain from Europa Group, as soon as possible, the rectification of inaccurate or incomplete data. The applicant also has the right to obtain the deletion of data concerning him/her as soon as possible, when his/her data are no longer necessary regarding the purposes for which they were collected or processed in another way.

• Right to the limitation of processing: the applicant has a right to the limitation of processing when he/she disputes the accuracy of his/her personal data. The limitation of processing lasts as long as Europa Group verifies the accuracy of the data. The applicant can also obtain from Europa Group the limitation of processing when we no longer need the data for processing purposes.

• Right to data portability: The applicant is informed that he/she does not have this right if the three cumulative conditions necessary for its implementation are not met.

• Right to object : The applicant is informed that he/she has the right to object, on grounds relating to his/her situation, to the processing of his/her personal data where this is based on the legitimate interests of Europa Group. The applicant may also object to the processing carried out for canvassing purposes.

• Right to organise the fate of personal data in the event of death: the applicant may define directives concerning the conservation, deletion, and communication of his/her personal data after his/her death.

• Right to lodge a complaint with a supervisory authority: applicants may lodge a complaint with the CNIL if they consider that the processing of their personal data constitutes a breach of the regulations applicable to personal data. The contact is made at the following address:

11. EXERCISE OF YOUR RIGHTS

We have appointed a data protection officer who can be contacted on the following details for any questions relating to data processing:

Data Protection Officer
Maître Eric Barbry, Cabinet Racine Avocats ;
data.officer@europa-group.com
01 44 82 43 00

12. SECURITY AND PROTECTION OF YOUR DATA

Europa Group defines and implements security measures to prevent the destruction, loss, alteration, or unauthorised disclosure of data.

The computer systems and paper media used are organised and protected in such a way as to guarantee the security and confidentiality of your data.

13. REGISTER OF PROCESSING OPERATIONS

We undertake, in our capacity as data controller, to keep an up-to-date register of all processing activities carried out.
This register is a document or application that makes it possible to list all the processing activities carried out by the Europa Group as data controller.
We undertake to provide the CNIL, on first request, with the information enabling it to verify the compliance of the processing operations with the Data Processing and Liberties regulations in force.

14. UPDATING THE POLICY

We reserve the right to change the format and content of this policy. Any new version of the policy published on the Europa Group website will replace the previous one.

15. FOR MORE INFORMATION

For more general information on the protection of personal data, you can consult the CNIL website www.cnil.fr.