Source and type of data processed
As part of our communication, we process personal data that concerns you: because you have directly provided it to us, we have collected it automatically, or because we have collected it indirectly from third parties. At each processing stage, we take care to limit the data collected to what is adequate, relevant and necessary for the purposes to be achieved.
1) PERSONAL DATA PROVIDED BY YOU
The personal data we collect is the data you voluntarily provide to us and the data we ask from you when you:
- Apply for a position published by the group;
- Create and complete your HR account, following a successful application;
- Contact the human resources department via email, telephone, messaging, postal service, or any other means;
- Enroll in a training program;
- Register or activate a device (computer, mobile phone or smartphone);
- Register for events, webinars, or services;
- Subscribe to newsletters and alerts on events or information;
- Take part in surveys, competitions, or any other promotional activities.
The type of personal data we may request from you can include, but is not limited to:
- Your identity;
- Your contact details (your physical and email address, your telephone number, etc.);
- Where applicable, your professional data (for example your prior education, course preferences);
- Your login data (for example, your user name);
- Your financial data (for example, your bank account number);
- Data on your health status, provided that the situation justifies it;
- Information about your private life, if you have provided it to us;
- Data on family and friends, for emergency contact, for example, if you have provided it to us;
- Opinions you have expressed in the context of surveys.
We may ask you to provide additional personal data, for example, in the case of online surveys, to understand your needs.
2) PERSONAL DATA COLLECTED AUTOMATICALLY
Our websites (and Intranet in particular), the group’s computing equipment and third-party web analysis service providers we use, automatically collect some types of data such as your IP address, the type of device you use, your device’s ID and other technical data, via cookies and other similar tracking tools.
3) PERSONAL DATA COLLECTED FROM THIRD PARTIES
From time to time, we may receive personal data concerning you from third parties, but only when the third parties are authorized or required to disclose your personal data. The data we collect from third parties includes your contact details, professional data where applicable, data relating to your career, etc.
Processing purposes
We use the personal data we collected from you for the purpose described in the present Confidentiality Policy, and the data we disclosed to you at the time of collection, or for compatible purposes.
In particular, we use your data:
- Primarily to manage your application, or your employment contract;
- To ensure payment of your compensation;
- To provide you with professional tools, especially computing equipment;
- To organize your workload;
- To monitor your career and mobility, and provide skills monitoring on the basis of your annual reviews;
- To offer training programs to you;
- To keep mandatory registers, especially those on staff representative bodies;
- To carry out internal communication;
- To manage any HR dispute;
- To enable you to be monitored by an occupational health team;
- To monitor your credited hours scheme (PCF);
- To provide you with psychological counseling;
- To provide you the information and services you require;
- To send you important notifications concerning our procedures, enrollment conditions, confidentiality policies and other legal documents;
- To meet the requirements imposed on us by administrative and financial checks and audits;
- To carry out auditing, accounting, invoicing, reconciliation and collection activities as well as other internal commercial operations;
- To protect you and us against fraud and other illegal activities or unfounded accusations; to establish, exercise, and defend your rights and our rights and to comply with our legal and regulatory obligations in force;
- To maintain the physical security of our premises (visitor logbooks, for instance) and IT and electronic security;
We may also use your personal data in aggregate form, making it impossible to identify individuals in order to assess and improve our training programs and services
Legal basis for personal data processing
In the European Economic Area, the legal basis for personal data processing described above depends on the personal data in question and the specific purposes for which we process it. The legal basis for processing is usually provided to you in the information you were given at the time of collection and you can find the main processing operations here.
However, we only collect personal data from you when:
- In most cases, we need your personal data regarding your employment contract, or an agreement you have entered into or for the pre-contractual measures necessary for their conclusion. For example, this is the case for processing implemented regarding the management of your professional file, to pay your compensation, monitor your mobility or requests for training programs;
- We process your data in compliance with our legitimate interests, unless your interests or fundamental freedoms and rights prevail. For example, this is the case when giving you an internal directory, managing and maintaining the computing equipment provided to you, managing your email system and enabling you to connect with the group’s VPN, implementing a review and skills management procedure, and organizing training programs you benefit from;
- We are under a legal obligation to process certain types of data to meet regulatory constraints. For example, we are obliged to process or transfer some of your data in the context of professional elections, to organize meetings of staff representative bodies or to fill in your personal social declaration form (DSN).
- In certain extreme cases, we may process your data to ensure that the vital interests of another person are protected, for example, in the case of emergency medical intervention on one of our sites.
For any question on the legal basis for the collection and use of your personal data, please contact our Data Protection Officer (dpo@omneseducation.com).
Personal data recipients
We may send your personal data to the following recipients:
- All the Organisation et Développement departments, in accordance with their operational requirements for the purposes mentioned above;
- The subcontractors and service providers of Organisation et Développement and the schools, which provide us with the services required for processing data, for example from our suppliers, data hosts and the service provider supplying the key to the virtual strongbox that enables you to keep your payslips. Where applicable, details of specific recipients of your data can be sent to you at the time of collection;
- Public and private organizations involved in your compensation, social contributions, retirement plan, supplementary health insurance, and insurance;
- Any relevant law enforcement agency, governmental or regulatory agency, court or other third party, for whom it is necessary to disclose personal information (i) under the laws and regulations in force, (ii) to exercise, establish and defend our rights or (iii) to protect your interests, or those of a third party;
- Any third party company that has made a proposal to acquire, merge, reorganize, transfer, wind up, or liquidate all or part of the OMNES Education Group, provided that we inform the interested third party that it must use your personal data only for the purposes set out in the present Confidentiality Policy;
- Any other person to whom we have given the authorization to disclose our personal data.
Your rights
In application of the Monegasque law on the protection of personal data and of the GDPR, you have the right to:
- access your personal data and obtain a copy of it;
- update or rectify the inaccuracy of this data;
- request the removal of your personal data;
- request that personal data processing be limited;
- object to the processing of your personal data, except when processing is required to execute your contract, or which is imposed on us by a regulatory constraint;
- request the portability of your personal data
- when processing is based on your consent, withdraw it at any time;
- to object to the communication of your data to third parties for prospecting purposes;
- file a complaint with the local supervisory authority – in France, the CNIL and in Monaco, the CCIN.
In order to exercise all your rights, you may write to our Data Protection Officer at the company’s registered office:
OMNES Education – Service du DPO – Immeuble Grenelle – 43 quai de Grenelle – 75015 Paris
or by email: dpo@omneseducation.com.
If we have any reasonable doubt as to your identity, and in order to protect your private life and ensure the security of your data, we may undertake to check it.
Personal data security
We attach great importance to the protection of your personal data and private life. Which is why we have implemented the technical and organizational measures required (physical, logical and personal security, as well as regular audits and reviews) to protect your personal data against illegal or unauthorized destruction, loss, alteration, access, disclosure and accidental use.
Personal data storage
We store your personal data when we have a legitimate and ongoing requirement for it in compliance with Ministerial Order no. 2016-501 of 5 August 2016 on automated processing relating to the administrative management of employees. In short, information is kept mainly during the employee’s period of employment, with specific time limits for certain data and strict rules for archiving and post-employment retention.
Should your application for a position not be successful your resume will be kept for a period of two (2) years to enhance our resume library and enable us to contact you again should a new position matching your profile arise.
Log files and other journals are stored for a period of three (3) years.
Documents on the rights and liberties of the person concerned are stored for one (1) year as regards access and rectification, and six (6) years as regards the right to object. If we have reasonable doubt, identity documents requested are stored no longer than the time required to verify them.
International transfer of personal data
We host your data in Monaco or in the European Union. When we entrust the hosting of your data to service providers, in particular when it is backed up in the cloud or we use SaaS applications, we ensure that the data is hosted in the European Union and that it is not transferred outside the European Union without prior authorization.
If we have to transfer your personal data to third parties, we supervise and ensure the security of transfers with:
- European Commission adequacy decisions, which recognize that certain countries outside EEA have national laws that protect personal data in accordance with substantially similar standards to the standards required by European Union Law:
- European Commission standard contractual clauses, which require that the personal data of recipients outside the EEA continue to protect the personal data they receive, in accordance with the standards required by European Union law;
- other legal data transfer mechanisms or legal exemptions from restrictions relating to data transfer.
You may obtain further details by making a request to:
OMNES Education – Service du DPO – Immeuble Grenelle – 43 quai de Grenelle – 75015 Paris
Updated 18 July 2024