APPLICANTS PRIVACY NOTICE
May 2018
SEPHORA SAS, a Groupe LVMH subsidiary, located at 41 rue Ybry 92200 Neuilly-sur-Seine (hereinafter ‘ Sephora ’,‘ we ’ or ‘our ’), attaches great importance to the protection of personal data relating to its applicants (hereinafter ‘ you ‘).
Sephora respects your concerns relating to the protection of your privacy and your personal data. This Applicants Fact Sheet (hereinafter referred to as the “Fact Sheet”) describes how we use information about you collected when you apply to join Sephora.
This Applicants Fact Sheet contains information regarding the nature and the use we make of your personal data, as well as your rights relating to this use.
This Applicants Fact Sheet is therefore an important resource for you, helping to ensure that you have a positive and confident experience of Sephora’s handling of your personal data and enabling us to provide accurate and complete answers to any questions you may have and to take account of your wishes in this area.
In order to give this requirement to ensure protection of your personal data - and that of our clients - the priority it deserves, Sephora has decided to designate a Data Protection Officer (hereinafter ‘ DPO ’), with effect from the 25th May 2018, namely XXXX, who may be contacted at the following address : privacy@sephora.fr.
1. Modification of the Fact Sheet
We may occasionally wish to modify the terms of this Fact Sheet. In such an event, we shall notify you of this by changing the date indicated at the beginning of this document, which is permanently available for consultation through your applicant space (We are Sephora or any other communication resource relating to Sephora recruitment). We would encourage you to consult the Applicant Sheet on a regular basis, in order to keep abreast of the procedures implemented by Sephora for processing your personal data, as well as the methods by which you can send us inquiries regarding our use of the data.
2. Why do we collect your personal data ?
Sephora collects and processes your personal data for the following purposes:
(i) management of your application for employment ;
(ii) management of the job offers for which you may be suited ; and
(iii) compilation of statistics regarding Sephora employment opportunities.
These processing arise from Sephora’s fulfilment of its statutory and contractual obligations and from Sephora’s legitimate interests in its capacity as a recruiter.
3. What type of personal data do we process ?
We only process data that is strictly necessary for the purposes described in paragraph 2.
We collect your personal data when you send your curriculum vitae, whether online or in paper form, or when you apply for employment by indirect means, for example via an agency or recruitment firm, and more generally throughout the Sephora recruitment process.
For your information there follows a list of the categories of your personal data that we may process, depending on the purposes to be achieved by this processing:
- data relating to your civil status and identity, such as : surname and forename, address, telephone number ;
- data relating to your educational and professional background, such as : training, professional experience, references, distinctions ; and
- data enabling connection to IT equipment.
The information we collect that are required in order to process your application are marked with an asterisk on the forms presented for you to complete on our online recruitment platform. If you do not complete these mandatory fields, we shall be unable to process your application. In the case of other forms of application, if Sephora has been unable to identify the information required in order to process your application, Sephora reserves the right to re-contact you in order to collect the missing information.
4. Who can access your personal data ?
Within the Groupe Sephora, your personal data are only accessible to those individuals who need to use it in order to carry out their respective duties.
More specifically :
- Within the company :
- Employees in Sephora’s HR department ;
- Employees in Sephora’s recruitment department ;
- Sephora’s IT department, for the purposes of maintenance ;
- Outside the company :
- Groupe LVMH’s HR department ;
- The HR departments of the Groupe Sephora subsidiaries and / or of Groupe LVMH ; and
- Service providers working for Sephora and involved in achieving all or some of the purposes set out in paragraph 2.
In particular, for purposes connected to maintenance of the IT systems, your personal data may be accessible to Sephora employees or to the employees of external providers of certain IT services. These employees shall only be able to access your data in order to carry out maintenance activities on the IT systems. They shall carry out their duties in accordance with Sephora’s instructions and in total compliance with the legislation on personal data.
5. Where are your personal data stored ?
As Sephora is part of an international group, your personal data (as described in paragraph 3) may be transferred to organizations within Groupe Sephora (parent company and subsidiaries) located outside the European Union, and more specifically in the following countries : Monaco, Turkey, Serbia, Switzerland, Russia, Kuwait, Saudi Arabia, United Arab Emirates, Qatar, Bahrain, China, Singapore, Hong Kong, Thailand, Malaysia, Indonesia, New Zealand, Australia, India, Philippines, Brazil, Canada and the United States of America, to organizations within Groupe LVMH (parent company and subsidiaries), and to external service providers.
These transfers are carried out within the context of management of recruitment within Groupe Sephora and Groupe LVMH for the purposes set out in paragraph 1 above. The processing activities carried out are: organization, reading, inputting, adaptation or modification, extraction, use, communication, deletion and destruction of your personal data.
Given the fact that some of these countries does not ensure an adequate level of protection of personal data as in the European Union, Sephora shall in accordance with applicable regulations, ensure the protection of your personal data as follows :
within Groupe Sephora, through adoption of Binding Corporate Rules (or ‘ BCR ’) applicable in each of its subsidiaries ; and
with its external service providers, through the implementation of standard contractual clauses published by the European Commission.
Copies of these documents may be obtained by sending an email to the following address: [Address to be completed].
6. How long do we store your personal data ?
Sephora keeps your data for a maximum period of 2 years after the last contact between Sephora and yourself. In this way we will be able to re-evaluate your application if a similar post becomes vacant and Sephora believes it may interest you.
At the end of these periods, your personal data are deleted.
7. Your rights
As specified in the legal provisions applicable in this area, you have the right to access data relating to you, and if applicable to request their rectification and deletion.
You may exercise your right to object to the processing of personal data that relates to you on grounds of your specific situation, or to seek a restriction on the processing of your data.
You are also entitled to request a copy of your personal data in a format that is structured, commonly used and machine-readable.
Furthermore, you have the right to issue advance instructions regarding use or disposal of your personal data after your death.
We would invite you to exercise these rights by writing to the following address: XXXXXXX or by contacting the DPO at this address: privacy@sephora.fr.
Finally, you have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (National Commission for Information Technology and Civil Liberties) at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07. We would however suggest that you first send us any claims via the DPO, so that we can deal with your questions and work together to find solutions that will resolve any issues you may have.
8. Notification of changes
We will keep you informed of any modifications to our Applicants Fact Sheet.
This Applicants Fact Sheet was last updated and revised on the [please insert date].