1. Introduction

Stirling Dynamics, part of the Expleo Group, respects the privacy of its job applicants (“you”), and we are committed to protecting their personal data. For this purpose, we have drafted this privacy policy to enable you to gain a better understanding of who we are and what are our practices with respect to the collection, use, disclosure, and retention of personal data obtained in connection the recruitment process. While we are going to address any questions you might have in relation to the processing of your personal data, please take the time to read this privacy policy as it offers a guide on our practices in relation to data protection. You should be also aware that data protection laws can vary in different jurisdictions where Expleo Group operates. We are striving to describe below the practices implemented to encompass all these different requirements. Depending on the country where you apply and/or your permission, might be situation in which stricter laws are applicable. For these situations, specific privacy practices in those locations have been adopted to satisfy those stricter requirements. The privacy policy may change over time to comply with legal requirements or to meet our changing needs. In case there is an important change, we will also inform you in another appropriate way if it is required by law (for example, via email or a pop-up).

2. Scope

This privacy policy applies to the processing of personal data of the job applicants and the potential candidates for employment purposes, those who have applied to our jobs adds, participated in the recruiting events and others who have expressed an interest in connection with Stirling Dynamics / Expleo Group ‘s career portal and recruiting activities more generally, conducted both offline and online. For additional information about our processing activities in connection with your general use of websites or our privacy notice that is outside the scope of this privacy policy, please see our dedicated pages.

3. Identity of the data controllers and the contact details of the data protection officer

Expleo Group is a global organization. Although the group has separate legal entities in many countries (“Expleo entities”), our internal processes and infrastructure are international in scope and nature and are generally transnational. “Expleo entities” mean any company within Expleo Group that is controlled directly or indirectly by Expleo Group S.A.S., with the registered office: 3, Avenue des Prés 78180 Montigny les Bretonneux, France, a French company governed by French law, simplified joint stock company with capital of 242,397,967.00 euros - Registered on the Trade and Companies Register under number 831 178 785 RCS Versailles. The entity for which you are applying, and as disclosed in the job offer, will be the Data Controller of your personal data. If you are consenting to be in the international talent pool, your data will be processed by the different entities of Expleo, as Data Controllers, for the purpose of providing you with other job opportunities. At the time of the latest update of this privacy policy, Expleo Group entities are the following, Expleo Austria, Belgium, Canada, Egypt, Engineering UK, France, Germany (Engineering), Iberia, India, Netherlands, Norway, Romania, Solutions India, South Africa, Sweden, Switzerland Engineering, Technologies India, Technology Germany, Technology Ireland, Technology Switzerland, Technology UK, Technology UK (Northern Ireland), Technology USA Inc dba Trissential, USA (North America), Global Corporate, Silver Atena (Germany), Stirling Dynamics GmbH’, Stirling Dynamics Ltd (UK), Vista International Services Srl (Romania). Please find the complete list of Expleo Group’s entities, address and contact detail following this link, or this one for our affiliates including Stirling Dynamics. The designated Group Data Protection Officer can be reached at: dpo@expleogroup.com.

4. Your personal data processed, legal basis and purpose of processing

4.1 Data Processed

As further described below, we collect personal data from you in connection with your job application and recruitment process. This data collection will be progressive and will depend on the status of your application (initial discussion to final onboarding process). For example, the generic process initially focuses on your contact details and CVs for the first reviews, then education and work-related data during interviews, to finally include other data such as financial data and ID to establish your final offer. All these recruitment processes are made in compliance with your country’s regulation, particularly regarding the personal data that shall not be collected during interviews (for example in Germany, questions regarding your marital status are not permissible). You have the control over the personal data that you are willing to share with Expleo Group, and we will only collect what is necessary. At the end of the process, and by reducing this list depending on your choice and in the strict application of the regulation of your country, the data processed may include the following:

  • Identification data: name and surname, nationality, address, personal identification number, identification data from the passport, copy of the identity document, sex, date of birth and signature, civil status.

  • Contact Details: your email address, your address, your number (landline and/or mobile phone) as well as your email address.

  • Education, certifications, and knowledge details: education history, schools you went, knowledge, skills, abilities, aptitudes, working style, preferences, professional and other work related licenses, permits, and certifications held.

  • Work related data: profession or occupation, work authorization status, CV, résumé, cover letter, previous work experience, referral names, contact information for referrals, if and when applicable, information relating to character and employment references; any other information you choose to provide to us with such as preferences, willingness to relocate, awards or professional memberships. 

  • Data related to the position(s): key words, function, level of experience, type of contract, location, business line.

  • Financial data: income, salary – past, current, desired.

  • Location Data: Country, area, postal code, city, address, relocation options.

  • Authentication and connection data: username, passwords, pins, other means of authentication IP address, log, pages visited.

  • Inferred data: This category includes data generated or inferred by us based on the data we hold about you, regardless of its source (i.e. obtained directly from you or from interaction such as interviews and other types of assignments).

  • Health data: data regarding your work capacity, the data from the medical certificates certifying the type and degree of your disabilities.

  • Other personal data: family situation, hobbies, leisure, category of driving licence, availability time.

  • Your profile on professional social networks which might include identification data, education, work experience, but also content you choose to post on such networks, and it is visible on your profile.

Except the health data necessary to establish you work capacity or to determine the logistic needs in relation to a certain disability, Expleo entities are not researching or collecting sensitive data in relation to recruitment activities (such as racial or ethnic origin, political, philosophical or religious opinion), unless it is under a mandatory legal obligation to do so. We may collect this information about you in a variety of ways, including from application forms, CVs or resumes, identity documents, third parties (such as references or background checks), certificates, diplomas, data on professional social network you are sharing with us or through interviews or other assessments.

4.2 Legal Basis

We collect and process your personal data pursuant to one or more of the following legal bases:

  • You have consented to process and retention of your personal data for recruitment purposes or consented to Expleo carrying out searches and validating personal data you have provided via the preboarding portal as may be necessary for the agreed purposes. Searches and validations may include, but no limited to, checks concerning right-to-work including ID documents. The processing is necessary in connection with our legitimate interests in recruitment and hiring candidates.

  • The processing is necessary to take steps, at your request, relating to potentially entering into an employment contract with you.

  • The processing is necessary to comply with our legal obligations, such as retaining records relating to the recruitment process for periods required under applicable laws or regulations.

4.3 Purposes of processing

Expleo entities processes your personal data mentioned above for the following purposes:

  • To communicate with you and respond to your requests and/or applications. For example, we may update you on the status of your application or invite you for recruitment activities such as a phone, online or in-person interview.

  • For recruitment, evaluation, background screening and hiring purposes when required. We may invite you to participate in assessments to evaluate your suitability for a position. Your data will also be used to facilitate the hiring process.

  • To propose your CVs to our internal teams and identify potential opportunities within the group. To enable your use of the career portal. Upon creating your account, we will send you your personal login information. This personal information enables us to manage your account including authenticating your access or changing your password at your request. We also may process your data if you encountered any problems in using the portal or if it is not functioning as expected.

  • To analyse, develop and improve our recruiting activities, with anonymous statistics. To comply with applicable laws and regulations and to operate our business. We may process your data to comply with applicable laws and regulations, such as legally mandated reporting (if any). Moreover, your data may be used for the organization management such as conducting audits or in the context of dispute resolution.

  • The same data may also be aggregately processed for statistical and reporting purposes to assess the frequency of consultation of our website and the effectiveness of our recruitment process.

  • To build our talent pool and communicate with you regarding opportunities across Expleo’s organization. We only contact candidates who meet the criteria for an opportunity and if we think this will be of interest and relevance to them. As part of this talent pool, your data will be accessed by recruiters in other countries outside of Europe.

4.4 Ways of processing for recruitment

The recruitment process can be initiated in different ways:

  • Sourcing from our recruitment teams: as part of our sourcing activities, Expleo recruitment teams may contact you and collect your profile in CV libraries or job boards (such as Monster) and professional social networks (such as LinkedIn), only after you have given your consent. Application for a specific job: In response to a job offer published by Expleo entities, you can apply by choosing to communicate your LinkedIn profile, by uploading your CV or by completing the form manually. If you apply for a job offer, you will make your personal data available to Expleo.

  • Unsolicited application: To submit your unsolicited application, you can open an account on our recruitment website in order to upload your CV, to apply via your LinkedIn profile or to manually complete a form. If you submit your unsolicited application, you will make your personal data available to Expleo.

Once collected, recruiters and authorised managers based across all our regions may view your details and may contact you about relevant opportunities and/or start the recruitment process with further interviews and pre-contractual discussions.

4.5 Ways of processing for the talent pool

When you consent that we process your data in the International Talent Pool, you are informed that your personal data can be processed and will be added in our talent pool under the terms and conditions described in this privacy policy. This consent is free and does not have any impact if you have applied for a position at Expleo Group. If you have not consented to the International Talent Pool, your will not be contacted for any other position. You are informed that this processing will allow the access to your data to Expleo entities that are situated outside of the European Union, in countries that does not provide adequate protection and that the necessary and adequate safeguards aimed at providing protection for the data cannot be completely implemented, due to the fact that a recruitment in those area will be subject to local regulations and might requires further information than European labour regulations. For example, in the USA, you can be invited to provide information related to equal employment opportunities, such as race, religion or sexual orientation. But all Expleo entities are subject to Expleo Group Personal Data Protection Policy and have implemented Expleo IT security policies. Your data will be made available to our global HR team and other internal authorised managers, to propose you with adequate job offers, if you have consented to the International Talent Pool. Your data will be also sent to our international centre outside of the E.U. in the conditions described in 4.6.

4.6 Sharing of your data

By acknowledging to this Privacy Policy and providing your personal data, you understand that your personal data will be processed outside of the European Union, including in countries that have not been recognised as providing an adequate level of data protection, such as South Africa or India. This processing is part of our international operations and service centres, delivering services for each entity of Expleo Group. The data we collect from you is stored in European Economic Area("EEA"). However, the said data will be transferred to or accessed from outside the EEA, within the scope of order processing by our international operations and service centers within Expleo. As such, it may also be processed by staff members operating outside the EEA who work for us or for one of our service providers as described below Other Group entities: In terms of the recruitment process, it takes place between, on the one hand, the Human Resources department (particularly recruitment officers) and, on the other hand, the authorised Business Unit Managers for whom the positions are open. There are cases in which these persons may belong to different Expleo entities and therefore, a transfer to another Expleo entity is needed. The transfer of your data to any other Expleo entity will benefit from the same level of protection and as such, if applicable, they are subject to intra-group agreements for the transfer of personal data. Third parties: Considering the activities of Expleo, your personal data might be shared with third parties that are linked with the job offer, for example, when you are considered for a consulting role for one of our customers. In such cases, your CV will be pseudonymised or anonymised before its transmission and your consent will be required. Third Party Suppliers: We may also use third-party suppliers and other partners with whom we may share your personal data for the purposes set out above. When we use these third parties, we ensure that they provide an adequate level of protection for the personal data they process on our behalf, and we enter into contracts with such third parties containing the standard contractual clauses adopted by the European Commission. The third-party suppliers support us in activities like the website management, information technology and related infrastructure provision such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications that may contain data about you, auditing and other similar services, perform on our behalf our satisfaction surveys and the statistical analyses associated with the use of the website. Among those providers (iCIMS, SourceBreaker, Talentsoft, Jobijoba, Monday, Data Driven, CodinGame, Predictive Index). Judicial, Public and/or Governmental Authorities: We may also be required - by law, legal proceedings, litigation and/or requests from public and government authorities in or outside your country of residence - to disclose your personal data to the authorities. We may also disclose personal information if we believe in good faith that it is reasonably necessary to protect our rights and exercise available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users. Reorganisation of activities: Like other organisations, Expleo Group may from time to time reorganise its business activities, whether by purchasing new companies or by selling or absorbing existing companies. Therefore, we may disclose personal data to potential or actual purchasers of parts of our business. According to our practices, we seek appropriate protection of the confidentiality of personal data disclosed.

5. Storage of your data

By default, your data will be kept for the duration defined in the legislation applicable to your country:

  • 6 Months: Germany, Austria, Switzerland, Spain.

  • 12 Months: Belgium, United Kingdom, Romania, Portugal, Sweden, Ireland, Netherlands, Norway & other EU countries.

  • 24 months: France, South Africa, Canada, Egypt, United Arab Emirates, Singapore, India

  • 36 months: USA

If you have consented to be in the International Talent Pool, your data will be retained for 2 years, unless you have renewed your consent. Once these durations are reached, your data will be automatically deleted. Of course, you are able to ask us to delete your data at any point in time.

6. Your rights in relation to the data processed

  • Right of access. You have the right to obtain information about your personal data which we process. In particular, you can obtain information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom your data has been or will be disclosed, the retention period, the right to rectification, erasure, restriction of processing or opposition, the existence of a right to lodge a complaint, the origin of the data, if the data has not been collected from us, as well as the existence of automated decision-making, including by establishing profiles and, where appropriate, meaningful information about such data.

  • Right of rectification. You have the right to request the rectification of inaccurate or incomplete personal data.

  • Right to erasure. You have the right to request the erasure of the personal data we retain, unless the processing is necessary for the exercise of the right to freedom of expression and information, for the performance of a legal obligation, for reasons of public interest or to assert, exercise or defend our rights.

  • Right to restriction of processing. You have the right to request the restriction of the processing of your personal data, if you contest the accuracy of the data, if the processing is unlawful, if we no longer need the data or if you object to the processing.

  • Right to data portability. You have the right to receive personal data you have provided us with in a structured, commonly used and machine-readable format, or to request its transfer to another data controller.

  • Right to withdraw consent to data processing. You have the right to withdraw your consent to the processing of your personal data at any time. Consequently, in such a case, we will not be able to continue the processing of data based on this consent. Withdrawal of consent shall not affect the lawfulness of processing based on consent prior to such withdrawal. If you wish to make use of your right of withdrawal, simply inform us by all known means of communication, in particular by e-mail dpo@expleogroup.com

  • Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with a supervisory authority. •Right to object. If the processing of your personal data is based on legitimate interests, you have the right to object to the processing of your personal data. If you wish to make use of your right to object, simply send a corresponding notification by e-mail to dpo@expleogroup.com

  • Right not to be subject to automated decisions taken on an individual basis, including profiling. You have the right not to be subject to a decision based solely on automated processing - including profiling - which will have a legal effect or similarly affect you.

7. Data Security

When you visit our websites and our social media pages, we use the widely used SSL method (Secure Socket Layer), in combination with the highest level of encryption supported by your browser. The fact that an individual page of our websites or social media page is transmitted in encrypted form may be recognised by the fact that the browser’s address line switches from “http://” to “https://” and includes the closed lock icon in the browser line. We also take appropriate technical and organisational security measures such as restricted access to your data, to protect your data against accidental or intentional manipulation, partial or total loss, destruction or unauthorised access by third parties. Our security measures are continuously improved in line with technological developments. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

8. How to contact us

We hope that we can resolve any query or concern you raise about processing of your data. To this end, please address any request you might have via the following: dpo@expleogroup.com