Privacy Notice – Candidates

Last update: 6^th of july 2021

Stuart (“We”, “Us”) are committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will process it.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is SRT Group.

We use Lever, an online application provided by Lever Inc., to assist with Our recruitment process. Lever processes personal information as a data processor on Our behalf and is only entitled to process your personal data in accordance with Our instructions.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information in addition to Our other Privacy Notice which has been provided to you separately or is available on Our Website.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

This notice is regularly updated so please make sure to check it from time to time.

What data do we collect and how will it be used?

Information we collect from You

In order to determine whether your application corresponds to the job position that we offer, we process information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.

In particular, we collect the following data: name, geographic location, age, contact details, IP address, profession, gender, employment history, employment references, salary, CV, and any other personal details that you desire to communicate.

If you choose to apply without importing your CV, you may be asked to provide your professional experience, training, or academic background, as well as your certifications and skills (among others). In general, you will not be required to provide this information in order to apply. It is therefore up to you to choose whether you wish to communicate them or not.

If you contact Us, We may keep a record of that correspondence.

A record of your progress through any hiring process that We may conduct will be kept. If you are chosen at the final stage of the process, we will collect some data to draft the hiring letter and the employment contract.

When you visit Lever’s Website, some data will be collected; including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Lever’s Website and the resources that you access.

Stuart does not sell your personal data to third parties.

Information we collect from other sources

Lever provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles, or websites.

Lever’s technology allows Us to search various databases, some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way, We will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for Our business more generally.

Lawful basis

This processing is, in part necessary for the execution of pre-contractual procedures, namely analyze your application and determine whether your profile fits the job position and if we wish to enter into an employment contract with you, and partly based on the legitimate interest of Stuart, when we keep your file to contact you again in the event of another opportunity.

Purposes of processing

We use information held about you in the following ways:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that We receive from you with information obtained from third party data providers.
To find appropriate candidates to fill Our job openings.
To help Our service providers (such as Lever and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.

Data retention

We keep your data for as long as necessary for the fulfillment of the purposes identified.

If your application is successful and you join Stuart, your data will be kept for the duration of the employment contract and during the applicable limitation period, after which they will be deleted (5 years after your departure).

If your application is not successful, your data will be kept for a period of 2 years at the end of which they will be deleted.

We may further process this data where required by law, to settle a dispute or to ensure the security of our systems.

Automated decision making/profiling

We may use Lever’s technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates can be automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.

Disclosure of Your Information

As set out above, We pass your information to Our third party service providers, including Lever, who use it only in accordance with Our instructions and as otherwise required by law.

Where you have applied for a job opening through another service provider, and where you have consented to this disclosure, We will disclose to them certain personal data that We hold, including but not limited to information about your progress through Our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”).The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

What are your rights?

You have the right to access information we hold about you

This includes the right to ask us supplementary information about:

The categories of data we’re processing;
The purposes of data processing;
The categories of third parties to whom the data may be disclosed;
How long the data will be stored (or the criteria used to determine that period); and,
Your other rights regarding our use of your data.

We will provide you with the information, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights).

You have the right to make us correct any inaccurate personal data about you

There are certain circumstances, such as where personal data is required for the investigation of a crime, where we will not be able to correct your data.

You have the right to limit the way that we use your personal data.

This right applies in limited circumstances such as where you contest the accuracy of the personal data, whilst we are verifying this you may request to restrict the use of the data.

You have the right to be ‘forgotten’ by us

You can do this by asking us to erase any personal data we hold about you if it is no longer necessary for us to hold the data for purposes of your use of Stuart or to meet our statutory obligations.

You have the right to complain

You also have the right to complain to a Data Protection Authority (contact information above).

Automated Decision Making

For the purposes of the processing covered in this notice, we do not make any automated decisions about you.

How to exercise your rights

You can exercise these rights using the email address: dpo@stuart.com

We will respond within one month of the date that we receive a valid request. This period may be extended to two months if your request is particularly complex, we will notify you where this is the case.

How we secure your data

We use physical, electronic and management procedures to safeguard and secure the personal data that we collect. These include:

Security measures to prevent the loss or unauthorized access or use of your data;
Limiting access to your data to those who have a genuine business need (those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality);
Ensuring that our staff, our service providers and their staff, are aware of their responsibilities and have signed the appropriate contractual clauses;
Processes in place to deal with information security breaches including to notify you where we are required to do so.

If you believe your privacy has been breached, please contact us immediately at dpo@stuart.com.

Where we store your data

The bulk of the personal data that we collect is processed at our offices in Paris, France; Barcelona, Spain; London, UK; and Warsaw, Poland.

Where We store your personal data in Our own systems, it is stored within the European Economic Area (“EEA”).

The data that We collect from you and process using Lever’s Services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). Where personal data is transferred to a third party outside the EEA, we take steps to ensure that we have the appropriate mechanisms reinforced by contractual and technical measures. By submitting your personal data, you agree to this transfer, storing or processing.

Where required to do so by law, we will share personal data with government authorities including tax authorities and the police.

If you would like further information, please contact Us (see ‘Contact us’ below).

Contact us

If you have any questions or concerns about the way in which your personal data is used, please contact us via dpo@stuart.com

Alternatively, you can write to us at the following address:

SRT Group
8 avenue des Ternes, 75017 Paris
France

And our Data Protection Officer is:

Madame la Déléguée à la Protection des Données du Groupe La Poste,
CP C703 – 9, Rue du Colonel Pierre Avia,
75015 Paris,
France

How to make a complaint

We are committed to working with you to resolve any concerns you have, if we fail to address your concerns you can complain to the competent data protection authority.

In the United Kingdom:

The Information Commissioner's Office via their website.

In France:

La Commission National de l’Informatique et des Libertés via their website.

In Spain:

Agencia Española de Protección de Datos via their website.

In Poland:

President of Personal Data Protection Office, Strona główna – UODO, via their website.