APPLICANT PERSONAL DATA MANAGEMENT POLICY

This Applicant Personal Data Management Policy (hereinafter “the Policy”)  is published by SUMITOMO CHEMICAL AGRO EUROPE SAS, whose headquarters are located at Parc d’Affaires de Crécy, 10A rue de la Voie Lactée, 69370 St Didier au Mont d’Or, France (hereinafter “SCAE”).

By submitting your application or CV, you acknowledge that you have read and understood this Policy. If you do not want your information to be used as follows, please do not send us your application or CV.

This Policy sets out:
•    what Personal Data we collect during the application and recruitment process;
•    how we use your Personal Data;
•    who can access your Personal Data;
•    how long we retain your Personal Data;
•    how you can access and modify the Personal Data we collect about you;
•    how we secure your Personal Data;
•    how you can submit questions and comments.

What Personal Data do we collect?

This Policy applies to all Personal Data we receive from you, which we collect and process about you in the context of your application and the recruitment process.

This Personal Data includes: identification and contact information, personal characteristics (such as sex and date of birth), training and work experience (results, certificates, diplomas, references), professional preferences, areas of interest, leisure activities, financial data (current and desired salary, for example), all data from your CV and cover letter, all publicly available data from your LinkedIn profile and other social networks or public websites, as well as any other Personal Data that you communicated to us orally or in writing as part of your application (“Personal Data”).

How do we use your Personal Data?

Your Personal Data will be used as part of your application and your recruitment process, including to:
1. assess your skills, qualifications and interests in relation to our career opportunities;
2. check your data, your references and/or conduct a background check (if applicable);
3. send communications about the recruitment process and your application;
4. improve the application and recruitment process within SCAE;
5. The processing for purposes 1, 2 and 3 described above is necessary for the possible conclusion of an employment contract between you and SCAE and purpose 4 is based on SCAE’s legitimate interest.

Who has access to your Personal Data?

Your Personal Data may be shared with Sumitomo Chemical Company (« SCC ») in Japan and, if necessary, with other SCC affiliates. Within these entities, the following members of staff have access to your Personal Data:
• the staff of the Human Resources Department;
• members of the Management Committee;
• the managers to whom the candidate will report in his/her role;
• members of the team to which the candidate will belong in his/her role.
In some cases, members of the IT Department may have access to your Personal Data, but only to the extent necessary for the proper functioning of our information systems.

SCAE may use external service providers or third parties for any of the purposes described above (for example, recruitment websites or agencies conducting background checks, temporary employment agencies, recruitment agencies, etc.). In this case, access to your Personal Data will be limited to the purposes described in this Policy and in accordance with the requirements of the applicable data protection legislation.

How long do we retain your Personal Data?

If your application is not successful, we will retain your Personal Data for a maximum of three years from the submission date of your application, unless you expressly request us to delete such data immediately after the recruitment process.
If your application is successful, your Personal Data obtained in connection with the recruitment procedure will be included in your Staff record. You will then be informed separately of how SCAE processes the Personal Data of its employees.

Accessing your Personal Data and correcting it

You are legally entitled to access, correct, delete or receive your Personal Data in a commonly used, machine readable format that may be transferred to another party.

If you wish to exercise any of these rights, please contact the Person in charge of the Personal Data at this email address: gdpr@sumitomo-chem.fr indicating your full name and attaching an ID document to your request.

You remain responsible for the Personal Data you provide and the consequences of such action. Please note that you may not provide SCAE with any Personal Data that is in violation of any obligations towards third parties in terms of confidentiality, intellectual property or trade secrets, unless you have obtained the explicit consent of the person or entity to share such data with SCAE for the purposes described in this Policy. By including references, you guarantee that you have informed the relevant parties in the processing of their Personal Data as described in this Policy.

Security of your Personal Data

Our information systems are protected against unauthorised access. Only relevant staff have access to your Personal Data based on a personal login or other authentication method, and only if it is relevant to the performance of their tasks.
We have implemented appropriate technical, physical and organisational measures to protect your Personal Data against destruction, loss, alteration, unauthorised, unlawful or accidental disclosure, as well as against abuse, damage and theft.

Contact

If you have any questions, comments or complaints regarding the processing of your Personal Data by SCAE, you can contact:
• the Person in charge of the Personal Data at the postal address on the 1st page or at this email address: gdpr@sumitomo-chem.fr indicating your full name and attaching an ID document to your request.
You also have the right to (i) oppose the processing of your Personal Data, (ii) withdraw your consent to the processing of your Personal Data, if applicable.
If you are not satisfied with our exchanges, you can contact the French National Commission for Data Protection and Liberties (CNIL) at this address: CNIL, 3 place de Fontenoy, TSA 80715 75334 Paris, France.

Changes in the Policy

This Policy may be updated regularly. The latest version is always available on SCAE’s recruitment webpage. The date on which the current version was published is shown below. Please check regularly to see if a new version has been published. Any changes will apply to your Personal Data as from the date of publication.

Last modification: 1 January 2019