The purpose of this document is to set out the privacy entitlements of Data Subjects, as defined in the General Data Protection Regulation (GDPR), of living persons. Privacy can only apply to information that is not already in the public domain and GDPR only applies to such personal data.
The General Data Protection Regulation (GDPR) is a European Union Regulation that sets out the data entitlements of data subjects and the obligations of those who process the personal data of data subjects. GDPR seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU.
We have identified our data subjects as being:
- Our candidates – permanent, temporary agency workers, contractors
- The individuals with whom we have contact at our client, prospective client and supplier businesses
- Our own employees
2. The Legal Basis for Processing any Personal Data
This company relies upon the following legal bases for data collection:
Contract: Information is required in order to perform the contract of employment agent on behalf of you the candidate, to potential employers. The basis of data gathering in that instance is contractual requirements. This will include identification information such as but not limited to name, address, date of birth, information regarding education/qualifications and reference checks. We share a redacted version of the data you supply to us with prospective employers whom we have matched to your skills and competencies.
Legitimate Interest: Information is processed in the legitimate interests of the business of the employment agency, and where so processed it will be in accordance with and subject to your data subject rights and entitlements. Our legitimate interest is that we require suitable candidates to supply to clients, and clients with whom to place candidates in order to carry out the Recruitment Service. In balancing the data subject protection rights against the legitimate interest of our company, we have considered:
The frequency of notifications to you in order to ensure that no nuisance is caused to you;
The security and integrity of the data you have provided to us;
Your rights and entitlements to stop the processing of your data with ease and to this end, we have created an easy path through which you can exercise your data subject rights within this website and the contact details supplied in this privacy notice.
We will promote our services via a number of methods, including direct marketing, on the basis of this legitimate interest, using the contact details of data subjects who have a connection with this company, either by being registered candidates, contacts within our client and prospective client companies (B2B basis processing) and social media connections. At all times we will make it easy for the data subject to exercise their data subject rights via an email to firstname.lastname@example.org
Statutory Obligations: Information is required in order to perform our statutory obligations such as tax returns and compliance with employment permit legislation. This information will include PPS numbers and where relevant information to verify entitlement to work.
Information is sought on your express and explicit consent in relation to the recruitment process. Through agreeing to this privacy notice you are consenting to us processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing us at email@example.com
4. What data we collect and why we collect it
Our company collects data from you and uses that data to place you in employment with third parties which involve making telephone contact with you, emailing you with positions that may be of interest to you, and sharing your data with potential employers. When you make contact with us you are consenting to our company acting as an agent for you in your pursuit of an employment position with a third party until you either opt out (which you can do at any stage) or we decide to desist in promoting you to potential employers. Our company in their capacity as your agent operates as a Data Controller in respect of the personal data you supply to us. We share your data with third-party Clients in order to advance your prospect of obtaining your desired position and while we require that our clients are GDPR compliant we can make no guarantees or warranties in that regard.
We collect personal data about you from the application forms and questionnaires you may be asked to complete; we also gather personal data from records of our correspondence, phone calls, emails and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. This information can be used to identify visitors to our website and also to collect statistics about the behaviour of visitors to our website.
We will only collect the information we need so that we can ensure adequate information is provided to our employer/clients consistent with the requirements of the particular placement relevant to you, as the contract is being performed, it may be necessary to obtain further data from you, we will do this if and when it is necessary and only the necessary data will be obtained. We do not sell or broker your data.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
A necessity of our contractual engagement is that we share your personal data with our employer/clients. We have in place Data Sharing Agreements (in the form of actual agreements or merely additional clauses within the terms and conditions of engagement between the agency and its clients) or Data Processing Agreements with all such employer/clients and we have done our utmost to ensure that all such parties process your data in a manner that is consistent with this Privacy Notice and GDPR. Our employer/clients may themselves be subject to third-party audits either in the form of ethical audits, governmental/statutorily required audits or legal obligations, these are deemed a necessity of the contract of engagement between you and our company and on this legal basis your personal data will be shared to comply with these requirements.
We do not broker or pass on information gained from your engagement with the agency. However, we may disclose your Personal Information to meet legal obligations, regulations or valid governmental requests. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of our company, its clients and/or the wider community.
6. Data Storage
Data is held in Ireland using a single secure server and our secure CRM platform, Bullhorn. We do not store personal data outside the EEA.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
For the duration of the time that we are in possession of your data, you have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records and we will comply with this request in accordance with our own obligations to keep records for statutory purposes
Right to a restriction of processing – where certain conditions apply you have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
These rights may on occasion need to be modified/curtailed by statutory or competing obligations, for example, you may request that we delete your data, however, if we have been your employer we only do so after the statutory period of record retention has expired. In the event that we are obliged to refuse your request in accordance with your data subject rights, or if we are obliged to place conditions on our assent to your request, we will provide you with a reason as to why which you have the right to legally challenge.
To access what personal data is held, identification will be required
We will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If we are dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to firstname.lastname@example.org.