APPLICANTS PRIVACY NOTICE

            November 2019

SEPHORA GREECE, a Groupe LVMH subsidiary, located at 7, Dionysiou Areopagitou str.11742, Athens Greece 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, which are 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, who may be contacted at the following address : privacy@sephora.gr.

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 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. Principles relating to processing of personal data

SEPHORA GREECE applies the following principles relating to the process of personal data:

2.1. Personal data are processed lawfully, fairly and in transparent manner in relation to its candidates.

2.2. Collects and process personal data for specified, explicit and legitimate purposes as provided herein and does not process them for purposes incompatible with the initial ones.
2.3. Processes personal data to the extent they are necessary and relevant to the aforementioned purposes, limiting the relevant process to what is necessary for the purposes for which they are processed.

2.4. Makes reasonable effort with the assistance of data subjects, so processed data to be accurate and where necessary up to date, taking every reasonable step to immediately erase or rectify such data, in case of inaccuracy 

    2.5. Keeps personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
2.6. Processes personal data in way which safeguards their security, by receiving proper technical or organizational measures.
2.7. Does not process personal data for another purpose in relation to the purpose for which they have been processed.

2.8. Does not use personal data for automated individual decision-making, including profiling.

2.9 Complies with the legislation as in force from time to time and its obligations arising from such legislation under its capacity as data controller.

 

3. 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 ; We process your personal data for this particular purpose because that processing is necessary in order to take steps at your request prior to entering into a contract

(ii) management of the job offers for which you may be suited ; The processing of your personal data for this purpose is based on your consent as resulting from the sharing options you have notified us with ; and

(iii) compilation of statistics regarding Sephora employment opportunities. ;   The processing of your personal data for this purpose is necessary for the protection of our legitimate interest to continuously improve our recruitment practices.

Sephora may also process your personal information to the extent necessary for the protection of our legitimate of being able to defend ourselves in case of a dispute and to comply without our legal obligations.

4. What type of personal data do we process ?

We only process data that is strictly necessary for the purposes described in paragraph 3.

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 ;
  • Contact details,
  • Data relating to your application (such as referral source, candidature status, offer approval…) and your career expectations;
  • Results of any assessments and/or occupational testing
  • Information about your entitlement to work in the EU or in the country where you applied
  • Publicly available information of your profile on social media channels (such as Linkedin);and
  • data enabling connection to recruitment platform (such as user ID, connection data…). .

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.

5. Who can access your personal data ?

Within the Group Sephora, your personal data are only accessible to authorised personnel to the extent needed in order to carry out their respective duties.

More specifically :

1.Within the company :
 

  • Employees in Sephora’s HR department ;
  • Employees in Sephora’s recruitment department ;
  • Employees in the Sephora services issuing job offers
  • Sephora’s IT department, for the purposes of security and maintenance ;

 

2.Outside the company :

  • The relevant HR departments of the entities of the Group Sephora subsidiaries and / or of Group LVMH responsible for international careers and talent management; and  
  • Service providers working for Sephora and involved in achieving all or some of the purposes set out in paragraph 3.

 

In particular, we rely on third party processors to provide you our recruitment platform and job application. These third-party processors are only allowed to process your personal data on our behalf and upon our explicit written instruction.

In addition, for purposes connected to maintenance of the IT systems, your personal data may be accessible to Sephora IT services 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.

 

6. Where are your personal data stored and processed?

We process your personal data first and foremost within the European Economic Area (EEA).

As Sephora is part of an international group, in order to process your personal data for the purposes  outlined in article 3 above your personal data  (as described in paragraph 4) may be transferred to organizations within Group Sephora or the Group LVMH (parent company in France and subsidiaries worldwide) and to external service providers helping Sephora entities in dealing with recruitment which may be located worldwide, including  outside the European Union. , and more specifically, regarding Group Sephora entities, in the following countries : Monaco, Turkey, Serbia, Switzerland, Russia, Kuwait, Saudi Arabia, United Arab Emirates, Qatar, Bahrain, China, Singapore, Hong Kong SAR China, 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. 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.  Such safeguards will be the consequence of:

  • The country of the recipient having legislation in place which is considered equivalent to the protection offered within the EEA
  • The Binding Corporate Rules (or ‘ BCR ’) applicable in each of LVMH Group subsidiaries ; and
  • The contractual arrangements with our 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: privacyHR@sephora.gr.

7. 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.

8. Your rights

 You have the right to request access data relating to you.

You have the right to request that any personal data pertaining to you that are inaccurate, be corrected free of charge.

You have the right to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3  above or to withdraw your consent for processing the data as described above in art.3. However, we will evaluate a request for deletion against:

- overriding interests of Sephora or any other third party;

- Any legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that we limit the processing of your personal data if you contest the accuracy of the data, or the processing is illegitimate, or the data are no longer needed for the purposes mentioned in Article 3.

. You may exercise your right to object to the processing of personal data that relates to you on grounds of your specific situation, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

You are also entitled to request a copy of the personal data you have directly provided to us through automated means 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: privacyHR@sephora.gr

Finally, you have the right to lodge a complaint with the Hellenic Data Protection Authority. We would however suggest that you first send us any claims via the local DPO, so that we can deal with your questions and work together to find solutions that will resolve any issues you may have.

9. Notification of changes

We will keep you informed of any modifications to our Applicants Information Notice.

This Applicants Fact Sheet was last updated and revised on the [1.11.2019].