Personal Data Processing Policy
Preamble
The SOFINORD group, of which ARMONIA is a division (hereinafter "the Group"), attaches the utmost importance to the protection of personal data processed as part of its recruitment activities.
This Personal Data Processing Policy (hereinafter the “Policy”) aims to clearly explain the nature of the data collected, the purposes of processing, the applicable legal bases, data recipients, retention periods, and the rights available to candidates.
Data Controller
ARMONIA – Groupe SOFINORD
2 rue du Capitaine Scott
75015 Paris
ais acting as the data controller for the operations described in this Policy.
Personal Data Collected
As part of a recruitment process, ARMONIA may collect identification and contact data such as surname, first name, email address, mailing address, and telephone number.
Information relating to professional and academic background is also processed, including curriculum vitae, degrees, professional experience, and any information helpful in assessing the application.
Exchanges with teams (interview dates, professional assessments, availability, salary expectations) may also be retained.
In some cases, publicly available information from professional networks may be reviewed. If sensitive information is voluntarily provided by a candidate, it is processed in accordance with safeguards set out in regulations.
Purposes, Legal Bases, and Retention Periods
Management of Applications
Description: Receipt, selection, and analysis of profiles; recruitment-related communications
Legal basis: Pre-contractual measures / legitimate interest
Retention period: Duration of the recruitment process if the application is not successful
Organization of Interviews and Assessments
Description: Skill analysis, interviews, and assessments
Legal basis: Pre-contractual measures
Retention period: Duration of the recruitment process
Building a Talent Pool (CV Database)
Description: Retaining profiles for future opportunities
Legal basis: Consent
Retention period: 24 months, renewable with candidate's confirmation
Preparation for Hiring
Description: Checks and procedures necessary for establishing an employment contract
Legal basis: Pre-contractual measures
Retention period: Applicable legal periods
Compliance with Legal Obligations
Description: Checks required by labor, immigration, or safety laws
Legal basis: Legal obligation
Retention period: Applicable legal periods
Information Systems Security
Description: Technical logging, supervision, prevention, and detection of incidents
Legal basis: Legitimate interest / legal obligation
Retention period: Maximum of 12 months
Data Recipients
The data is accessible only to authorized persons within the Group, namely members of the Human Resources teams, managers involved in recruitment, and, where relevant, the departments concerned by the position offered.
It may also be transmitted to service providers working on behalf of ARMONIA, such as candidate management solution providers or technical service providers responsible for hosting and maintaining information systems, as well as to legally authorized authorities where required by regulation.
All these recipients are bound by a strict obligation of confidentiality.
Transfers outside the European Union
Candidate data is hosted within the European Union.
If, exceptionally, a transfer to a country outside the European Union should be considered, it would be carried out in compliance with the GDPR by implementing appropriate safeguards, including the standard contractual clauses adopted by the European Commission and, if necessary, additional protective measures. Candidates would be informed beforehand.
Data Security
ARMONIA implements technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data. These measures include access management, environment segmentation, network security devices (firewalls, segmentation, VPN, access supervision), as well as detection and incident prevention mechanisms.
Regular controls help maintain a level of security in line with the Group's internal standards.
Candidate Rights
In accordance with applicable regulations, candidates have the right to access, rectify, erase, restrict processing, and data portability, as well as the right to object on grounds relating to their particular situation. They also have the right to withdraw their consent at any time when processing is based on that consent, as well as the right to define instructions on the fate of their data after death.
For any request concerning the exercise of your rights or for any question regarding the protection of personal data: dpo@sofinord.com
Data subjects also have the right to lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL) www.cnil.fr
Update
This Policy may be amended to reflect legal, regulatory, or technical developments. The version in force is the one published on the Site.