Data protection policy
Last update - December 2021
TALAN is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.
Talan is committed to the respect of your privacy and the protection of your personal data. Therefore, Talan has adopted a "Personal Data Protection Policy" relating to the personal data it collects, that sets out how we seek to protect personal data in accordance with all applicable regulations and in particular the European Data Protection Regulation (EU) 2016/679 of 27 April 2016.
"Candidate / Applicant" refers to the person who has sent an application and/or has been contacted by a TALAN Group entity or through a recruitment agency concerning a job offer.
"Data subject" is the individual who is the subject of the relevant personal data.
"Data controller" is the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
"Data processor" is a natural or legal person, public authority, agency or any other body that processes personal data on behalf of the controller.
"Employee" refers to the person who has been recruited by an entity of the TALAN Group, regardless of their status.
"GDPR" refers to the European Data Protection Regulation (EU) 2016/679 of 27 April 2016.
"HR or Human Resources" means any department or member of a department involved in personnel management, recruitment, payroll or relations with staff representative bodies within the entities of the TALAN Group.
"Personal data" means any information relating to an identifiable person who can be (i) directly or (ii) indirectly identified in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
"TALAN Group" means TALAN SAS and all of its subsidiaries.
2. Who is the data controller?
The person in charge of the Processing is Talan SAS, simplified joint stock company, with a share capital of 1 740 672.52 €, registered with the Paris Trade and Companies Registry under number 488 601 337 with its Head office address at 19-21, rue Dumont d'Urville, 75016 Paris, France.
Telephone: +33 (0) 1 42 97 96 96 | Fax: +33 (0) 1 42 97 96 90
Talan has appointed a Data Protection Officer (DPO) who determines the procedures to be followed throughout the Talan Group and monitors the compliance of internal practices with the applicable regulations. For any question you can contact our DPO at: email@example.com
3. What data are collected?
In general, we commit to ensure that Personal Data are collected and processed in a lawfully, fairly and transparent manner. We will inform all Data Subjects of the purpose of the collection and processing of their Personal Data, only collect Personal Data that is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed, and kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
The Personal Data that we may collect are the following:
- Identifying information : your name, home address, telephone number, e-mail address.
- Job application data: your name, e-mail address, telephone number, professional experience as well as all the information that you provide to us by submitting your application and/or resume and/or interviews: photo, skills, level of education, languages spoken, salary expectations, home address, hobbies, family situation, etc., if you wish to apply for a position within the Talan Group.
- Professional data : your name, your position, your company of affiliation, your role as a Talan supplier or service provider, etc.
In the context of the management of Human resources:
- Social security data (work permit number, social security number),
- Transport/Business travel (means of transport used by an Employee, for reimbursement of travelling expenses, e.g. travel card, expenses incurred in the use of a vehicle, etc.),
- Training and career (CV, diplomas training experiences, work experience, cover letter, information provided by the Candidate, interview notes, date of interviews, work permit (yes/no), foreign languages spoken),
- Professional life (employment contract, recruitment date, Employee identification number, job title),
- Financial data (tax deductions and withholding taxes, level of salary, record of salary and other items of compensation, stock options plan, purchase option plan, relevant payments, account details),
- Video surveillance and access badge monitoring data (TALAN implements video surveillance and access control systems at its premises which leads to the collection and processing of your Data such as video recordings, access information and information on the time of collection),
- Any other additional Data that we need to collect in order to manage the employment relationship.
4. Why are your data collected?
Each Data Subject is informed in a clear and precise manner of the purpose and objective sought by the collection and Processing of their Data.
(i) Clients - prospects - suppliers: Your Personal Data are collected and processed in order to allow you to benefit from our services, enter into or perform a contract and participate in our events.
The Processing of your Personal Data aims to meet in particular one or more of the following purposes:
- Allow the performance and the administrative / commercial management of the contracts, execute the projects;
- Answer and manage any question, contact requests or appointment inquiry;
- Being able to propose to you our commercial offers on services likely to interest you, participate in our events, subscribe to our newsletters, you have the possibility to opt out of commercial prospecting at no cost, by clicking on the link of un-subscription in every email or by contacting us via the contact information indicated in paragraph 2;
- Keep our customer files up to date in order to better meet your expectations.
(ii) Candidates: Management of job applications, evaluation of the candidate during the recruitment process.
(iii) Employees: Your Personal Data are collected and processed for one or more of the following purposes:
- Management of the employment relationship (administer remuneration, payroll, and other standard employment functions);
- Administration of HR-related processes, including those relating to performance/absence management, disciplinary issues and complaints;
- Operation of security;
- Delivery of IT facilities;
- Compliance with applicable local laws (obligations in terms of maternity leave; working hours; pay, salaries and benefits due pursuant to your employment contract, annual increases and any other salary adjustments, deductions for income tax and social security contributions, etc.);
- Compilation of statistics and surveys’ conduct and research for internal and statutory reporting purposes;
- Fulfillment of our responsibilities under equalities, immigration and public safety legislation.
5. How long can your data be stored ?
We will only store your Data for the period necessary for the purposes set out in this Policy, or as provided by applicable laws. Thus, the duration of storage of your Personal Data depends on the purpose of each processing.
In order to determine how long we keep your Personal Data, we use the following criteria in particular:
If cookies are used, we determine their lifetime by following the limit set by the local competent authority;
We may store some of your Personal Data to comply with a legal or regulatory obligation, and in order to exercise our rights, we keep your data for the period indicated by law (for example: the limitation period or the legal retention period);
In the context of a job application, your CV and the information you provide during the recruitment process will be kept for up to 2 years after your last contact with Talan, unless you object to it. Only your formal consent allows for a longer retention;
The information you provide in the contact form will be stored for the necessary time to respond to your request;
Your Employee Profile and HR File will be kept by Talan Group until the end of your employment contract, with some personal data being archived for a longer period where required by law or for the exercise or defense of legal claims (ex.: statute limitation period during which someone can bring a legal action to courts).
6. What are your rights as a Data Subject and how can you exercise them?
Depending on the processing operations to which your Personal Data are subject, you may have the following rights:
Right of Access
The right to ask and obtain confirmation whether we are processing your Personal Data or not. If this is the case, you can access your Personal Data and obtain information such as the purpose of the processing, the categories of personal data concerned, etc.
Right to Rectification
The right to obtain from us the rectification of inaccurate Personal Data concerning you.
Right to Erasure (“Right to be forgotten”)
The right to obtain the erasure of your Personal Data, insofar as one of the reasons justifying this right applies to your situation.
Right to Restriction of Processing
The right to obtain the restriction of the Processing, where one of the grounds justifying the exercise of this right applies to your situation.
Right to Object
In the event of certain specific requirements applied, Employees of Talan Group have the right to object at any time to processing of Employees' personal data with reason of specific situations.
Right to data portability
The right to receive your Personal Data, in a structured, commonly used and machine-readable format, and the right to transmit such data to another data controller without hindrance from us.
The right to define the directives for the treatment of your Personal Data after your death.
To exercise these rights, you can contact us at the following address: dpo@talan. com
You will be required to prove your identity, by whatever means, in order for us to process your request in a satisfying manner. In case of doubt, we may ask you for additional information, including a copy of your identity card, signed by you.
We will do our best to comply with your requests. We will respond to any request within one month, but our response time may be extended by an additional two months depending on the complexity and number of requests. Nevertheless, should you remain dissatisfied, you are also entitled to contact any competent data protection supervisory authority.
7. Who can access your Personal Data?
Authorized individuals within the Talan Group and, in some cases, our third parties such as our contractors and our trusted service providers may have access to your Personal Data to the extent necessary to comply with Talan Group’s legitimate interests, to comply with its legal obligations, for the performance of your employment contract or in order to take the necessary steps at your request prior to entering into a contract or during the recruitment process. We make every effort to ensure that the number of such individuals is kept as small as possible and to maintain the confidentiality and security of your Personal Data.
In this regard, we share with them only the information they need to provide the service and we ask them not to use your Personal Data for any other purpose. We always make our best efforts to ensure that all our trusted service providers with whom we work, maintain the confidentiality and security of your Personal Data. We also ensure that when our relationship with a trusted service provider comes to an end, that service provider deletes your Personal Data without delay.
We select our trusted service providers with great care, ensuring that they provide sufficient guarantees, including expertise, reliability and resources, to implement the technical and organizational measures to meet the requirements of applicable legislation, including security of processing. In this regard, we ensure that our trusted service providers process Personal Data only on our documented instructions. We also ensure that their personnel are committed to confidentiality or are subject to an appropriate legal obligation of confidentiality.
Internally, your personal data can only be accessed by the HR department or any other departments having a strict need to know. This access is under strict review by our Data Privacy Officer in order to ensure the Group’s compliance with applicable laws.
8. Where do we store your Personal Data?
Your data is stored within the EEA. Transfers of personal data outside the European Economic Area are only allowed under certain conditions (list of countries deemed suitable by the European Commission, special contractual clauses, binding corporate rules for groups, etc.).
9. What security measures have we implemented regarding your Personal Data?
Talan has implemented appropriate technical and organizational measures, in light of the nature of the data and the risks involved in processing it, to preserve the security and confidentiality of your Personal Data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties.
These measures may include, but are not limited to, practices such as limited access to the data by personnel of departments authorized to access it because of their functions, contractual guarantees in the event of contracting with an external service provider, privacy impact assessments, regular reviews of our privacy practices and policies, and/or physical and/or logical security measures (secure access, authentication process, backups, anti-virus software, firewall, etc.).
Cookies are small text files placed on your computer or device when you browse the Internet. Cookies can be used to collect, store and share information about your activities on the websites and services you use.
Our sites use the Google Ananlytics measurement tool to collect traffic and statistical data. This data is anonymized in order to respect the current GDPR rules.
You can set the parameters of cookies directly from your browser and choose either the systematic refusal of cookies or their authorization on a case by case basis.
11. Link to Third Party websites - Social Media
Talan's Website may contain links to social media platforms operated by persons or organizations over which Talan Group has no control.