Recruitment Data Protection Notice

The aim of this Data Protection Notice is to provide you with all the relevant information regarding the collection and further processing of your Personal Data by Capgemini in the context of recruitment.

Key data protection notions

“Personal data” does not only refer to information related to your private life but encompasses any and all information which enables to identify you either directly or indirectly even where collected in  a business and/or employment context.

“Processing” means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, combination, restriction, erasure or destruction.

“Controller” means the natural or legal person which determines the purposes and means of the processing of personal data.

“Processor” means the natural or legal personal which processes personal data on behalf of the controller.

“Purpose” means the reason(s) why the controller needs to collect and further process the personal data.

Who is collecting your personal data?

Capgemini Service SAS and/or affiliates of Capgemini SE hereafter referred as “Capgemini”, are collecting and further processing your personal data as data controllers. “Capgemini Nordics” is comprised of Capgemini’s legal entities in Denmark, Finland, Norway, and Sweden, and will serve as your local point of contact for matters concerning this privacy notice.

Why and on what ground is Capgemini collecting your personal data?

Capgemini is collecting and further processing your personal data for several reasons, each of which is based on a specific legal ground as defined hereunder:

Main Purpose(s)	Legal ground(s)
To evaluate your suitability for the vacant positions you are applying for that are available via Capgemini’s recruitment platforms, including systems that are integrated to it, via social networks, or via capgemini.com	Our legitimate interest to recruit the best suited candidates.
To create a candidate database and assess your suitability for future recruitment and future roles that may become available or to match suitable candidates with similar positions within the Capgemini Group.	Your consent.
For administrative purposes, i.e., to enable management of applications and recruitment processes and assessments connected to such processes.	Our legitimate interest to operate and administer an efficient recruitment system and carry out recruitment activities.
To make assessments that candidates conduct via third-party suppliers to Capgemini.	Your consent.
To reach out to potential candidates whom Capgemini employees have recommended.	Our legitimate interest to recruit the best suited candidates.
Conducting background checks as relevant in relation to the position you are applying for. This may include but is not limited to ID verification, diploma verification, and criminal background checks. The specific information about these checks is set out in the job ad. Furthermore, we may need to verify your eligibility to work in the country of employment, if this is mentioned in the job ad.	Background checks are in general carried out based on our legitimate interest to understand the candidate’s suitability for the position being recruited for, but there are also situations where there is a legal obligation to carry out background checks and in those cases that obligation serves as the legal ground the processing.
To verify information provided by the candidate during the course of application (i.e., to verify employment certificates, study diplomas, and certifications, and to conduct reference checks).	The Processing is necessary to take steps prior to entering into a contract, and for performing the obligations under the contact.
To share your profile/CV with our clients or prospects when answering a request for proposal (RFP).	Our legitimate interest to promote Capgemini by featuring the best profiles as part of our answers to RFPs. Your CV will not be shared with a client or prospect without your approval.
To compile offers of employment to candidates, administrate agreement drafts.	The Processing is necessary to take steps prior to entering into a contract.
The facilitate interactive activities and games during preboarding. During the preboarding phase the candidates will have access to “Degreed” to follow training courses.	Our legitimate interest to present Capgemini to our successful candidates and allow them to discover the company.
Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Capgemini and how to attract talent.	Our legitimate interest of ensuring that we continually improve our recruitment processes.
Record-keeping for the purposes of compliance with applicable laws.	Legal obligations that Capgemini is subject to, such as the GDPR (General Data Protection Regulation) in relation to handling requests for exercising data subjects rights.
Perform any legally required reporting and respond to legal processes.	Legal obligations that Capgemini is subject to.
Managing access for you to our systems.	Our legitimate business interests of providing a technical system for managing recruitment matters.
To send you e-mails about webinars and similar events.	Your consent.
To contact you via SMS, WhatsApp, or similar services in connection with the recruitment process.	Our legitimate interest of keeping in touch with you in connection with the recruitment process.

Which Personal Data processed?

Capgemini will process the following categories of Personal Data:

• Contact information.
• CV, letters or any other written materials (including photographs).
• Data about your prior employment, education, and where applicable, criminal records or other data revealed during background screenings.
• Information you share in the form of the questionnaire on the Capgemini recruitment platform. When strictly necessary for the job vacancy these questions can be used by the recruiters as disqualifiers.
• Data generated by interviews and personnel involved in the recruitment process, data pertaining to various assessments (logic, technical, personality assessments, etc.).
• Documentation that is necessary as per immigration laws where applicable.

How is your personal data collected and processed?

Capgemini usually collects your Personal Data directly from you when you fill in the application form on our career’s portal, or via our chatbot, by email, or during recruitment events.

Capgemini may also collect Personal Data via third parties who you have asked to provide your personal information to Capgemini, including professional social networks (e.g., LinkedIn), talent agencies and job-search websites, or, in the case of internal candidates, from internal HR systems. Furthermore, Capgemini employees can suggest suitable candidates who will then be reached out to.

Referral program.

Capgemini employees can refer candidates as part of the Capgemini referral program, provided they obtain the candidate’s consent beforehand. When a Capgemini employee refers a candidate, Capgemini will process contact information, work experience, and other qualifications of the candidate as shared by the Capgemini employee. After having been contacted by Capgemini, the candidate may provide Capgemini with further information, including the information described above

When you request an employee to refer you for a position, they will be kept informed about your application status and any other roles you pursue. You can only be referred for the same role by one employee at a time. If you seek referrals from multiple employees for the same position, only the first person who referred you will receive updates on your progress. The others will simply be aware that you have applied, without any further details.

Offline applications.

For information received by email, or physical CV submissions and applications, your details will be entered into our database and applicant management system by our recruiters. Your submitted documents will then be returned to you or destroyed, which is why we ask you not to submit any original documents.

Registration for recruitment events.

When you sign up for a webinar or similar event on the employment opportunities at Capgemini, Capgemini will collect your name and e-mail address and process them to provide access to the events and to send you relevant communication if you consent to that.

Please note that by providing your information you will be added to a global database of candidates, and you could be contacted by recruiters located in a different country that the one you initially applied in and for similar positions that match your profile. If you agreed to it, Capgemini shall further process your information to share information about other events and job opportunities.

Successful applicants.

When your application is successful Capgemini will use the e-mail address you used for the application to Capgemini and process it to create the credentials to provide access to the optional Discovery Game in Degreed platform.

Decision-Making Support Tool

At Capgemini, we rely on tools to support our recruiters in assessing your candidate profile. When you apply for a position, our recruiters use a tool that helps pre-evaluate your suitability for a specific role based on four key criteria: skills listed in the application, location, years of experience and job titles. This tool provides an initial ranking based on how well these criteria align with the job requirements.

However, our recruiters do not rely solely on this tool to make their decisions. They apply their personal judgement and professional experience, taking into account additional factors such as but not limited to career achievements, qualifications, visa requirements, relocation willingness, and salary expectations, which are all manually reviewed. The tool simply supports in organizing and prioritizing applications, but the final decisions are always made by our recruiters, ensuring a human-centered approach.  Please note that your personal data is not used to train the tool.

Who has access to your personal data?

Capgemini shall have access to your personal data. For the above-mentioned purposes, your personal data will be shared mainly with the following functions only on a need-to-know basis: HR teams that work with the recruitment process, the hiring manager, and the competent managers.

In addition, for this project, Capgemini relies on third-party suppliers acting as data processors (and where applicable, as data controllers), which may have limited access to your personal data. Where relying on such processors, be ensured that Capgemini enters into contractual agreements to ensure that your personal data are processed safely and strictly according to Capgemini’s instructions and in accordance with applicable data protection legislations.

These categories of suppliers are:

• Job boards or agencies that collect your data to start an application process, such as LinkedIn;
• Candidate Relationship Management (CRM) provider,
• Background service providers;
• Suppliers of services related to work permit obtention;
• Technology providers for the management of offer letter or contract execution such as DocuSign; and
• Preboarding platforms (Degreed), which canidates will have access during the preboarding phase.

Furthermore, the Capgemini affiliates or the third parties accessing your personal data, may be located in third countries, thus implying a data of your personal data.

• Where such a transfer takes place between a Capgemini entity in the EU and other Capgemini entities out of the EU, it will be covered by Capgemini’s Binding Corporate Rules (“BCR”). For further information on Capgemini’s BCR, please click on the following link: https://www.capgemini.com/se-en/insights/research-library/capgemini-binding-corporate-rules/
• Where such transfer takes place between a Capgemini entity in the EU and an external third-party out of the EU, Capgemini and said third-party shall enter into EU Model Clauses approved by the European Commission, to ensure the security of the personal data.
• Where such transfer takes place between a Capgemini entity out of the EU and another Capgemini or third-party entity located in a third country, the applicable legal local requirements to frame such data transfer will be implemented according to local legal requirements.

How long does Capgemini keep your personal data?

Capgemini shall keep your personal data for no longer than is necessary for the purpose(s) for which they were first collected. Capgemini shall determine the appropriate retention period taking into account the purpose(s) of the processing and the relevant applicable legal requirements. For any candidate who has been successful, your personal data will be transferred to your personnel file and kept in accordance with Capgemini’s data retention policy. For candidates that are unsuccessful, your personal data will be kept for a period of two years from the date of the last activity. The retention period can also be defined locally, considering specific legal obligations.

What are your rights and how to exercise them?

You can request to access, rectify or erase your personal data. You may also object to the processing of your personal data, or request that it be restricted. In addition, you can ask for the communication of your personal data in a structured, commonly used and machine-readable format.

If you wish to exercise those rights, please contact our Group Data Protection Officer by sending an email to the following address: dpocapgemini.global@capgemini.com Where appropriate we will communicate your request and/or complaint to the relevant local data protection officer. For further information.

Please note that you also have the right to lodge a complaint before a data protection authority or the competent court of law.