Updated on December 11th, 2020
In order to assess applications for positions offered on its Website, PENTALOG needs to collect Candidates’ personal data.
PENTALOG is committed to giving a clear position on the use of its Candidates’ data.
This chapter is intended for Candidates who apply for one or more job offers or internship(s) proposed by PENTALOG GROUP’s affiliates as well as for the candidate’s referents when these are indicated in the applications (with the latter’s prior agreement).
Unless otherwise stated, PENTALOG will refer to the groups of persons referred to above, collectively as "you" or "the Candidates".
1. Data subjects
1.1. Direct Candidates
As mentioned in the preamble, PENTALOG may receive data directly from individuals looking for a job or an internship who apply directly on the Website.
Candidates may also send speculative applications by email.
1.2. Contact details received indirectly
Candidates’ data may have been provided to PENTALOG by third parties, such as:
- A recommendation from someone inside or outside PENTALOG;
- A Candidate who provides references contact details in their application;
- A Candidate who provides emergency contact details;
- A PENTALOG’s supplier who nominates a Candidate for a position;
- A company in the PENTALOG GROUP that forwards an Application for a job position.
2. How PENTALOG collects data
2.1. Direct sources
PENTALOG receives applications directly from Candidates themselves. This is the case, for example, when:
- A curriculum vitae is sent to PENTALOG (to a PENTALOG’s employee, representative, etc.)
- A Candidate applies directly for a job or internship published on one of PENTALOG GROUP’ websites (e.g. Pentastagiu, SkillValue etc.).
2.2. Indirect sources
PENTALOG receives indirect applications in several ways:
- A Candidate who applies for a job published on a third-party website;
- A Candidate whose profile matches a job offer may be identified on a public platform or social networks on which PENTALOG employees are also registered (e.g. LinkedIn, Viadeo, etc.);
- The Candidate may come from a specialist third-party job-hunting website on which PENTALOG is registered as a recruiter;
- An application may be received through a recommendation of a PENTALOG or external employee;
- PENTALOG may also receive an application for a job offer advertised by a partner (e.g. Pentastagiu);
- PENTALOG may receive an intra-group application or an application from a supplier such as SKILLVALUE, a company in the PENTALOG Group.
- The Candidate and a PENTALOG’s employee or representative may be introduced to each other at a public event organized by PENTALOG or a third-party and then may exchange their contacts.
3. Legal basis for processing
3.1. PENTALOG complies with the GDPR for all kinds of processing. Indeed, a processing may be carried out with or without the consent of the data subject in accordance with the GDPR.
3.2. According to article 6 of the GDPR, the legal basis for processing must be clearly established. For the purpose of this requirement, the main legal bases for PENTALOG’s processing of its Candidates’ personal data are described below:
- Preparation of a contract: if the Candidate and PENTALOG find common ground, PENTALOG shall have to process some of the Candidate’s data in order to prepare a contract. The Candidate can expect its data to be processed for this purpose.
- Legal requirement: PENTALOG shall process a Candidate’s personal data if legally required to do so.
- Processing is necessary for the purpose of legitimate interests pursued by PENTALOG: PENTALOG will use its legitimate interests when consent has not been obtained and when data has been collected indirectly. PENTALOG can confirm that the use of the legitimate interests does not take priority over the interests or fundamental rights and freedoms of the individual concerned, and that interested parties can expect PENTALOG to process their personal data. However, Candidates can always oppose this kind of processing at any time.
- Consent: This is obtained when a Candidate applies directly for a position (in a speculative application or for a position offered on the Website). If consent is not obtained, PENTALOG uses another legal basis for processing.
- Skills assessment: If an employment contract is offered, PENTALOG may decide at any time to carry out a skills assessment. This shall involve PENTALOG’s processing of the Candidate’s personal data by or its testing providers in accordance with this Policy.
4. How PENTALOG uses Candidates’ data
PENTALOG uses the data collected for the purposes of:
4.1. Assessing applications and confirming information provided by Candidates;
4.2. Contacting Candidates’ referring if necessary;
4.3. Creating a Candidate file on PENTALOG’s internal system to track conversations, follow-ups and the signing of the employment contract;
4.4. Putting the Candidate in contact with PENTALOG’s managers for the position that may be offered or for which they have applied;
4.5. Due diligence: preparatory step for the signing of a contract with the Candidate;
4.6. Due diligence: to enable the checking and validation of tests taken by Candidates;
4.7. Communicating with Candidates and building a professional relationship with them;
4.8. Allowing Candidates to use interactive social networks (e.g. LinkedIn, Viadeo, etc) functionalities if they wish;
4.9. Matching Candidates with jobs offer or internships offer;
4.10. Keeping Candidates informed of job offers matching the information provided in their application or according to results obtained in tests, in accordance with the terms and pursuant to the Candidates’ consent where required by law. Information sent to users may include advice on their assessment relative to offers available on the Website, and the use of users’ data to send them messages likely to interest them;
4.12. Optimising the management and operation of the Website and offering Candidates a better experience;
4.13. Informing Candidates of changes made on the Website;
4.14. Giving Candidates access so they can change their profile;
4.15. Managing the Website to maintain an optimal level of use by our technical teams.
5. Sharing your Data: who might be the recipient?
5.1. When necessary, PENTALOG may need to share applications with its affiliates specialising in recruitment, such as SKILLVALUE, in order to assess the application or offer the Candidate jobs tailored to their profile within the PENTALOG GROUP. Candidates may withdraw their consent for such processing by PENTALOG at any time.
The sharing of your data can also be done for purely administrative or technical purposes to services of the PENTALOG GROUP, some located outside the European Union. The sharing of your data to our services can also take place in the event of legal obligations.
5.2. Your data may also be shared to third parties such as subcontractors, service providers who support us in the recruitment process.
6. Information collected by PENTALOG
PENTALOG may collect and process the following data:
6.1. Information provided by Candidates
By using its Website, Candidates may submit information to PENTALOG, some of which may directly or indirectly identify them (this is ‘Personal Data’ within the meaning of article 4.1 of the GDPR.
This is particularly the case:
- when Candidates fill in forms;
- when they contact PENTALOG;
- when they post a comment on the PENTALOG blog, whether by email or any other means of communication, or when they report a problem to PENTALOG;
- when they subscribe to the PENTALOG newsletter.
6.2. Data required for Candidates to register on some websites on the PENTALOG’s platform
This information includes the following data:
- first name and surname;
- email address;
- city and country.
This information is mandatory (e.g. PENTASTAGIU). If it is not provided, PENTALOG shall not be able to provide the services offered by the Website and Candidates shall not be permitted to create an account on the Website.
Depending on the information provided by Candidates, PENTALOG also collects:
- A photograph (only if a user attaches it to a Curriculum Vitae or includes it in their profile on the website);
- Place and date of birth (only if a user includes it in their Curriculum Vitae);
- Postal address (only if a user includes it in their Curriculum Vitae);
- Education and work history, references, membership of organisations, hobbies and interests (only if a user includes this information in their Curriculum Vitae, it is available on a social network or the user provides it on the Website);
- A copy of all conversations between users and PENTALOG;
- Detail of visits to the Website;
- Answers given in tests or competitions and time taken;
- Data that may be provided by Candidates at PENTALOG’s request when reporting a problem online relating to its services or the operation of its website;
- Links to social networks provided by Candidates or collected by PENTALOG on open-access social networks.
6.3. Data collected automatically or indirectly by PENTALOG
6.3.2. PENTALOG may also collect personal data when Candidates interact with social network functionalities such as ‘likes’ and comments.
6.3.3. In accordance with the applicable legislation and the Cookie Charter, when users visit its website, subject to their consent where required, PENTALOG may collect information relating to the networks from which they access the Website, such as IP addresses and clickstream data. PENTALOG may also collect content accessed by users, pages accessed on the Website, and search terms used.
6.3.4. Some applications may come from third-party websites (e.g. PENTASTAGIU) or PENTALOG affiliates, such as SKILLVALUE.
7. Storage of Candidates’ personal data
7.1. PENTALOG does not intend to store the personal data of Candidates any longer than is necessary but to keep them at least during the recruitment process.
7.2. PENTALOG may store Candidates’ data for the following reasons:
- The Candidate remains in contact with PENTALOG (Human Resources department or e.g. Pentastagiu), in order to be informed of new opportunities;
- PENTALOG and the Candidate communicate by email or telephone;
- The Candidate interacts with PENTALOG by opening newsletters, etc.
7.3. For all marketing communications, Candidates’ personal data shall be stored for two (2) years from the date of last communication with the Candidate or from the date the Candidate has unsubscribe from PENTALOG emails campaign.
7.4. When an account is closed (e.g. Pentastagiu), the Candidate’s personal data is usually removed within 24 hours. All information on the Candidate’s account shall be removed within 30 days, with a few exceptions:
- If PENTALOG has to comply with legal requirements under applicable law;
- PENTALOG shall store some anonymised data for statistical purposes.
7.5. If a user account has been suspended or blocked as a result of a malicious activity, data shall be stored from the suspension for a period of between 1 and 10 years in order to avoid any attacks on the integrity of PENTALOG.
7.6. For issues related to recruitment, computing and legal, Candidates’ data shall be stored for the aforementioned period unless PENTALOG is legally required to store it for a longer period. After this period, PENTALOG shall no longer process this data.
Return to Chapter "GENERALITIES".