Information clause
How We Process Personal Data During Recruitment for European Companies of the Orange Group
This document provides information on how we process your personal data and what rights you have in this regard.
If we mention:
• us – we mean Orange SA, Orange Polska S.A., and the company from the Orange Group you are applying to,
• you – we mean the person participating in recruitment for a European company of the Orange Group,
• Orange Group – we mean the companies within the Orange SA capital group.
1. Who is the Data Controller?
The data controllers are jointly: Orange SA, Orange Polska S.A., and the company you are applying to. As joint controllers, we determine the purposes and means of data processing in accordance with legal regulations.
Below, we specify each controller’s role in the recruitment process:
• Orange SA designs the joint recruitment process within the Orange Group and analyzes its operation.
• Orange Polska S.A. builds the joint recruitment process, accepts, and manages applications.
• The company you are applying to searches for candidates and prepares the recruitment. This includes Orange Polska S.A., Orange Belgium SA, Orange Moldova SA, Orange Romania SA, Orange Services SRL (Romania), and Orange Slovensko a.s.
2. Purpose and Duration of Data Processing
Below are the purposes, processing periods, and legal bases:
a) Conducting recruitment
• Data is processed for one year from the date we received your application. If you give consent, we may use it for an additional year.
• Legal basis under GDPR: for the company you are applying to, it is the conclusion of a contract or compliance with a legal obligation (art. 6(1)(b) and (c) GDPR).
• For Orange SA and Orange Polska S.A., the legal basis is legitimate interest (art. 6(1)(f) GDPR).
b) Defending against claims or pursuing claims
• Data is processed for up to two years from receipt of your application.
• Legal basis: legitimate interest (art. 6(1)(f) GDPR).
c) Proving lawful processing
• Data is processed for up to two years from receipt of your application.
• Legal basis: legitimate interest (art. 6(1)(f) GDPR).
3. Do You Have to Provide Your Data?
Providing your data during recruitment is voluntary – it is not mandatory.
However, national laws may specify that some data are necessary for the recruitment process. Without them, we may not consider your application.
If you agree to additional data processing (beyond legal requirements), include it in your application. The legal basis will be your consent.
Remember, you are not obliged to provide additional data – participation remains unaffected.
4. What Happens if You Withdraw Consent?
When data processing is based on consent, withdrawing it will stop the processing. You can do this at any time. This applies to future processing; it does not affect the legality of processing before withdrawal.
5. Data Transfer Outside the EEA
Moldova is outside the EEA. If you apply for a position in Moldova, we need your explicit consent to transfer your data there.
6. Additional Recruitment Actions
a) Additional recruitment activities
We may propose additional recruitment activities, such as:
• participating in tests,
• recording a video via HireFlix or scheduling an interview (if you send an email to recruitment.hub@orange.com),
• using other methods to verify skills and competencies.
Participation is voluntary. If you participate, it will be considered your consent (legal basis). Results will be used to assess your skills.
b) Satisfaction survey
We may ask you to participate in an anonymous survey evaluating the recruitment process. Results are processed for 12 months based on your consent.
7. Use of Artificial Intelligence (AI)
Your data may be processed in AI systems if:
a) it is necessary for the purposes described,
b) we ensure all legal protections of your rights.
8. Profiling
We do not use your data to build profiles or make fully automated decisions about you.
9. Data Recipients
As joint controllers, we may share data among ourselves and with:
• service providers or subcontractors acting under our instructions,
• authorities if required by law.
The company you are applying to will receive your data and conduct its own recruitment process.
10. Your Rights
If you submit a request to us:
• we will correct your data (rectification of data)
• we will delete data that we process without a legal basis or that we have published on our online services (erasure of data)
• we will suspend the processing or deletion of your data (restriction of processing)
• we will explain how we process your data and provide you with a copy (access to data)
• we will transfer your data to you or to another person you indicate (data portability).
11. Right to Object
If data is processed based on legitimate interest, you can object. We will stop processing unless we demonstrate overriding legal grounds.
12. How to Exercise Your Rights
Contact Orange Polska S.A.:
• by mail: Orange Polska S.A., Al. Jerozolimskie 160, 02-326 Warsaw
• by email: inspektorochronydanych@orange.com
We may request additional information to verify your identity.
13. Filing a Complaint
If you believe your data is processed unlawfully, you can file a complaint with the relevant authority:
• Orange SA: CNIL, https://www.cnil.fr/en
• Orange Polska S.A.: UODO, https://uodo.gov.pl/pl
• Orange Belgium: APD / GBA, https://www.dataprotectionauthority.be/citizen
• Orange Moldova: NCPDP, https://datepersonale.md/en/
• Orange Romania & Orange Services: ANSPDCP, https://dataprotection.ro
• Orange Slovensko: Úrad na ochranu osobných údajov, https://dataprotection.gov.sk/en/
14. Data of Joint Controllers
Contact details of the controllers:
• Orange Polska S.A.: Aleje Jerozolimskie 160, Warsaw
Email: inspektorochronydanych@orange.com
• Orange SA: Issy-les-Moulineaux, 111 quai du Président Roosevelt, France
Email: group-dpo.personal-data@orange.com
• Orange Belgium: Avenue du Bourget 3, Brussels
Email: officer@orange.be
• Orange Moldova: Alba-Iulia 75, Chisinau
Email: datepersonale@orange.md
• Orange Romania: Lascar Cargariu 47-53, Bucharest
Email: dpo@orange.ro
• Orange Services: Gara Herastrau nr 4, Bucharest
Email: ose@orange.com
• Orange Slovensko: Metodova 8, Bratislava
Email: dpo@orange.sk
How We Process Personal Data During Recruitment for European Companies of the Orange Group
This document provides information on how we process your personal data and what rights you have in this regard.
If we mention:
• us – we mean Orange SA, Orange Polska S.A., and the company from the Orange Group you are applying to,
• you – we mean the person participating in recruitment for a European company of the Orange Group,
• Orange Group – we mean the companies within the Orange SA capital group.
1. Who is the Data Controller?
The data controllers are jointly: Orange SA, Orange Polska S.A., and the company you are applying to. As joint controllers, we determine the purposes and means of data processing in accordance with legal regulations.
Below, we specify each controller’s role in the recruitment process:
• Orange SA designs the joint recruitment process within the Orange Group and analyzes its operation.
• Orange Polska S.A. builds the joint recruitment process, accepts, and manages applications.
• The company you are applying to searches for candidates and prepares the recruitment. This includes Orange Polska S.A., Orange Belgium SA, Orange Moldova SA, Orange Romania SA, Orange Services SRL (Romania), and Orange Slovensko a.s.
2. Purpose and Duration of Data Processing
Below are the purposes, processing periods, and legal bases:
a) Conducting recruitment
• Data is processed for one year from the date we received your application. If you give consent, we may use it for an additional year.
• Legal basis under GDPR: for the company you are applying to, it is the conclusion of a contract or compliance with a legal obligation (art. 6(1)(b) and (c) GDPR).
• For Orange SA and Orange Polska S.A., the legal basis is legitimate interest (art. 6(1)(f) GDPR).
b) Defending against claims or pursuing claims
• Data is processed for up to two years from receipt of your application.
• Legal basis: legitimate interest (art. 6(1)(f) GDPR).
c) Proving lawful processing
• Data is processed for up to two years from receipt of your application.
• Legal basis: legitimate interest (art. 6(1)(f) GDPR).
3. Do You Have to Provide Your Data?
Providing your data during recruitment is voluntary – it is not mandatory.
However, national laws may specify that some data are necessary for the recruitment process. Without them, we may not consider your application.
If you agree to additional data processing (beyond legal requirements), include it in your application. The legal basis will be your consent.
Remember, you are not obliged to provide additional data – participation remains unaffected.
4. What Happens if You Withdraw Consent?
When data processing is based on consent, withdrawing it will stop the processing. You can do this at any time. This applies to future processing; it does not affect the legality of processing before withdrawal.
5. Data Transfer Outside the EEA
Moldova is outside the EEA. If you apply for a position in Moldova, we need your explicit consent to transfer your data there.
6. Additional Recruitment Actions
a) Additional recruitment activities
We may propose additional recruitment activities, such as:
• participating in tests,
• recording a video via HireFlix or scheduling an interview (if you send an email to recruitment.hub@orange.com),
• using other methods to verify skills and competencies.
Participation is voluntary. If you participate, it will be considered your consent (legal basis). Results will be used to assess your skills.
b) Satisfaction survey
We may ask you to participate in an anonymous survey evaluating the recruitment process. Results are processed for 12 months based on your consent.
7. Use of Artificial Intelligence (AI)
Your data may be processed in AI systems if:
a) it is necessary for the purposes described,
b) we ensure all legal protections of your rights.
8. Profiling
We do not use your data to build profiles or make fully automated decisions about you.
9. Data Recipients
As joint controllers, we may share data among ourselves and with:
• service providers or subcontractors acting under our instructions,
• authorities if required by law.
The company you are applying to will receive your data and conduct its own recruitment process.
10. Your Rights
If you submit a request to us:
• we will correct your data (rectification of data)
• we will delete data that we process without a legal basis or that we have published on our online services (erasure of data)
• we will suspend the processing or deletion of your data (restriction of processing)
• we will explain how we process your data and provide you with a copy (access to data)
• we will transfer your data to you or to another person you indicate (data portability).
11. Right to Object
If data is processed based on legitimate interest, you can object. We will stop processing unless we demonstrate overriding legal grounds.
12. How to Exercise Your Rights
Contact Orange Polska S.A.:
• by mail: Orange Polska S.A., Al. Jerozolimskie 160, 02-326 Warsaw
• by email: inspektorochronydanych@orange.com
We may request additional information to verify your identity.
13. Filing a Complaint
If you believe your data is processed unlawfully, you can file a complaint with the relevant authority:
• Orange SA: CNIL, https://www.cnil.fr/en
• Orange Polska S.A.: UODO, https://uodo.gov.pl/pl
• Orange Belgium: APD / GBA, https://www.dataprotectionauthority.be/citizen
• Orange Moldova: NCPDP, https://datepersonale.md/en/
• Orange Romania & Orange Services: ANSPDCP, https://dataprotection.ro
• Orange Slovensko: Úrad na ochranu osobných údajov, https://dataprotection.gov.sk/en/
14. Data of Joint Controllers
Contact details of the controllers:
• Orange Polska S.A.: Aleje Jerozolimskie 160, Warsaw
Email: inspektorochronydanych@orange.com
• Orange SA: Issy-les-Moulineaux, 111 quai du Président Roosevelt, France
Email: group-dpo.personal-data@orange.com
• Orange Belgium: Avenue du Bourget 3, Brussels
Email: officer@orange.be
• Orange Moldova: Alba-Iulia 75, Chisinau
Email: datepersonale@orange.md
• Orange Romania: Lascar Cargariu 47-53, Bucharest
Email: dpo@orange.ro
• Orange Services: Gara Herastrau nr 4, Bucharest
Email: ose@orange.com
• Orange Slovensko: Metodova 8, Bratislava
Email: dpo@orange.sk