Date of Issue: May 2018
Candriam Luxembourg (registered office: 136, route d'Arlon L-1150 Luxembourg), Candriam France (registered office: 40 rue Washington – 75008 Paris), Candriam Belgium (registered office: Avenue des Arts/ Kunstlaan 58, 1000 Brussels) or Candriam Switzerland (registered office: rue du 31 décembre 40-42, CH–1207 Geneva, Switzerland) and its subsidiaries (referred to collectively as "Candriam" or "we" or "our") is committed to respecting the privacy of individuals, including our candidates for employment.
For the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the Candriam entity referred to above to which you applied for a job is the "data controller" of your personal data.
Candriam Switzerland has appointed as EU representative for GDPR matters Candriam Group S.a.R.L. with registered address at 19-21 Route d’Arlon, L-8009 Strassen Luxembourg registered no. R.C.S. Luxembourg B 180524.
Personal Data We collect
We may obtain your personal data because you have submitted an application for a position with Candriam (either directly or through a recruiter). This personal data includes, but is not limited to your name, contact details, email address, interests and aspirations, gender, nationality, former employer(s), name of the employee referring you, academic background (including professional qualifications) and Curriculum Vitae (CV). We will hold, use and process that personal data in accordance with the terms of this Policy.
Please do not include any sensitive personal data as part of your application, i.e. information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status or sexuality as well as information regarding criminal convictions. If we do require this information, and more particularly information regarding criminal convictions, in connection with your application, we will inform you separately and obtain any necessary consent from you.
Please ensure you have the consent of the Candriam employee or any other referee whose details you provide alongside your application for us to use their personal data as outlined in this Policy.
Verification and Staff Checks
For some positions, it will be necessary for us to verify the details you have supplied (for example in relation to your identity, academic credentials or your employment history) and /or carry out pre-employment checks (for example in relation to previous criminal convictions or financial standing). The level of required checks will vary by position and will usually be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks.
How We Use this Information and the Legal Basis for this Use
We may process your personal data for the following purposes:
- As required to enter into and perform the employment contract with you.
- As required to operate our business and to pursue our legitimate interests to: make informed decisions on recruitment and ensure your suitability for the role or to keep you in mind for future roles; answer your enquiries; improve our recruitment processes and activities; manage our IT systems; and to conduct group administration.
- In order to comply with applicable laws and protection of our legitimate business interests and legal rights including but not limited to, use in connection with legal claims, compliance, regulatory investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation). This includes verifying that you have the right to work in the country in which you are applying to a job with Candriam.
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Notice.
As mentioned above, we may also ask for your consent to carry out certain verification and staff background checks where this is required in connection with your role. Where we do process data based on consent, your consent can be withdrawn at any time.
If it is mandatory for you to provide data for these purposes, we will make this clear at the time the data is collected and will also explain what will happen if you do not provide the data.
Disclosure of Your Personal Data
Your personal data may be disclosed to:
- subsidiaries and/or affiliates1;
- trusted third parties which Candriam uses as part of the recruitment process, such as for background checks, psychometric tests, grade point average tests or assessment tests;
- other third parties who perform services on our behalf such as professional advisors and IT consultants carrying out management of our IT systems;
- Government authorities and/or regulatory or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws; and
- in the event that we are sold or integrated with another business, to our advisers and any prospective purchaser and their advisers.
In some cases we may transfer your personal data to the United States of America, which does not have laws which provide the same level of protection to your personal data as provided by EU laws.
In order to provide adequate protection for these transfers, Candriam has executed European Commission-approved standard contractual clauses pursuant to Article 46 (2) of the GDPR. To obtain a copy of the transfer mechanism, please contact us using the details provided below.
Retention of Your Personal Data
Your details will be deleted from the Candriam recruitment systems after two (2) years from the date you submitted your details to Candriam. If you are unsuccessful most information will be deleted after two (2) years but we will retain your name and past experiences for five (5) years for the purpose of matching you with future job opportunities at Candriam. You can request that we stop holding your details for this purpose at any time by contacting us, see the Contact Us section.
Where applicable, you may have certain rights under applicable data protection law including the right to ask us for a copy of or update the personal data held about you as well as obtain supporting explanatory materials. You may ask us to make any necessary changes to your data ensure it is accurate and up to date or ask us to transfer it to other organisations or delete it at your request in certain circumstances. You may also have rights to object to some processing and where we have asked for your consent to process your data, to withdraw your consent. Where we process your data because we have a legitimate interest in doing so, you may also have the right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your personal data.
As a reminder, in France, by application of article 40-1 of the Law n°78-16 of 6 January 1978 on Information Technology, Data Files and Civil Liberties, you have also the right to give instructions on the management of your personal data after you death.
If you wish to exercise any of your legal rights, write to us at DPO@candriam.com. We hope that we can satisfy queries you may have about the way we process your data but if you have any unresolved concerns, you may also complain to the applicable supervisory authority.
1List of subsidiaries and affiliates are available on the following link