Personal Data Processing During Recruitment

We are delighted you are interested in joining PEN Partnership Limited “PEN” and we would like to assure you that the security and protection of our applicants and employees data are a priority in our company.

During the application process for our job offers, you will be asked to provide personal data to PEN. This data processing is necessary for the consideration of your application and is carried out in accordance with the regulations applicable to the protection of personal data and in particular, the General Data Protection Regulation.

1. Purpose and legal basis

Collected personal data is processed in order to manage candidate applications and recruitment (selection process, interview follow-up, your job alerts management…) and allows us to assess your ability to fill the job offer. These data processes are necessary for the purpose of pursuing PEN’s legitimate interests.

In the event that you are recruited by PEN, the data will be further processed for the purpose of managing your employment and career at PEN.


2. Collected data

PEN collects personal data such as:

• Identification data (name, surname, email, phone number, address…),

• Data related to your professional career (CV, professional experience, skills…),

• Cover letter

• Salary expectations

• Diversity and equal opportunity information volunteered by participants in recruitment processes.

Some of the personal data requested may be mandatory, you will be informed at the time of collection by an asterisk or by an equivalent means. If you don’t fill in the mandatory information, your application will not be processed. The optional information is intended to get to know you better.


3. Data recipients

Candidate personal data is addressed to PEN and is available to our recruitment teams, our employees involved in the recruitment process, our HR teams and our IT teams which administrate our tools. Personal data may also be communicated to public organizations, judicial officers and ministerial officers, in order to comply with any law or regulation in force, to which PEN would be required to respond (judicial or administrative request).


4. Third party services

Your application is sent via our partner SmartRecruiters, which then allows you to create an account on its website to manage your applications with PEN or other SmartRecruiters clients. Access to this site and use of this account is in accordance with the SmartRecruiters terms of use. The rights you have under the applicable regulations will be applied directly to SmartRecruiters. PEN shall in no event be liable for any damages suffered as a result of the use of this site and account.


5. Data retention

Your personal data will be retained for the duration of the application process and will then be archived for a duration of two years starting from the date of your last contact with PEN, if your application is not accepted.

If you are hired by PEN, the data will be kept for the duration of the contractual relationship with PEN, then until the expiry of the legal prescription and retainment period.


6. Rights of individuals

You can at any time exercise your rights (access, rectification, deletion, contradiction, treatment, and portability limitation) concerning your data by contacting the Data Protection Officer at dpo@wavestone.com in attaching proof of identity.

You have the possibility to file a complaint with the Information Commissioner’s Office (ICO)