Company Name:

Executive Connections Ltd.  (‘the Company’)

Company Contact details:

Ann Marie Brennan, Data Protection Lead, gdpr@executiveconnections.ie
Topic:

 

Data protection
Date:

 

03/12/2018
Version: 1.1

The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.

Contents

  1. Collection and use of personal data
    1. Purpose of processing and legal basis
    2. Legitimate interest
    3. Statutory/contractual requirement
    4. Recipients of data
  2. Categories of data
    1. Sources of data
  3. Data retention
  4. Your rights
  5. Automated decision making
  6. Cookies
  7. Log files
  8. Links to external sites
  9. Sale of the business
  10. Data security
  11. Changes to this privacy statement
  12. Complaints or queries

 

  1. Collection and use of personal data
  1. Purpose of processing and legal basis

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

We may also send you marketing information, research or news via email/ text.  You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

  • Your consent
  • Where we have a legitimate interest
  • To comply with a legal obligation that we have
  • To fulfil a contractual obligation that we have with you
  1. Legitimate interest

 This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  • Managing our database and keeping work-seeker records up to date;
  • Providing work-finding services to you and our clients;
  • Contacting you to seek your consent where we need it;
  • Giving you information about similar products or services that you have used from us recently;
  1. Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with Employment Permits Regulations 2017 or Organisation of Working Time Act, 1997).  Our clients may also require this personal data, and/or we may need your data to enter into a contract with you.

If you do not give us the personal data, we need to collect we may not be able to continue to provide work-finding services to you.

  1. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Clients (whom we may introduce or supply you to)
  • Former employers whom we may seek references from
  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
  • Other recruitment partners in the supply chain e.g. Managed Service Providers or Recruitment Process Outsourcers contracted by the Client to fulfil recruitment activities on their behalf.

 

  1. Categories of data
  • Identity Data: name, an online username, title, date of birth, photograph and gender.
  • Contact Data: address, email address and telephone numbers, social media links.
  • Financial & Revenue Data: bank account details; PPS number; company registration details and any other tax-related information.
  • Employment Data: This includes data that was provided to us through application for a role and/or assignment or employment; current remuneration, pensions and benefits entitlements; information on your interests and needs regarding future employment; Education details; immigration status (whether you need a work permit);
  • Sensitive Personal Data: while we may not actively solicit it, on occasion you may share data with us on your racial or ethnic origin, biometric data, religious or philosophical beliefs, criminal convictions or the alleged commission of an offence or trade union membership;
  • Client Data: Contact information; job titles; email correspondence; notes from meetings; signed copies of terms of business.
  • Supplier Data: Contact information; email correspondence; notes from meetings; signed copies of terms of business; job titles.
  • Referees and Emergency Contacts: Contact information supplied to us by candidates or internal Executive Connections staff.

Failure to collect such data may prevent the Company from being able to provide work-seeking services.

  1. Sources of the personal data:
  • From Irishjobs.ie CV database
  • LinkedIn Profile
  • A direct submission of information by email, website enquiry, social media, phone or post
  • Response to job advertisement on:
  • A former employer
  • A referee whose details you previously provided to us
  • Cookies listed in section 7
  • Revenue Commissioners, Credit Agencies, Background checking partners 
  1. Data retention 

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, Organisation of Working Time Act 1997, employers are required to keep records of holidays, public holidays, special leave, rest breaks, start and finish times of each employee for each day and sick leave for a period of 3 years.

Where the Company has obtained your consent to process your personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you or remove this data. Where consent is not granted the Company will cease to process your personal data.

  1. Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on a public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting our Data Protection Lead by email – gdpr@executiveconnections.ie. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal, contractual or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. 

You can also contact us using the above details if you want us to restrict the type or amount of data, we process for you, access your personal data or exercise any of the other rights listed above. Restriction of type or data we process for you may prevent the Company from being able to provide work-seeking services.

  1. Automated decision-making

Executive Connections does not currently employ profiling or fully automated decision making in the delivery of our recruitment services. Should this change in the future we will seek your explicit consent to this processing where appropriate.

  1. Cookies 

We may obtain data about you from cookies.  These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content. The types of Cookies we collect are as follows:

(i) Session Cookies

As you move through the site, various pieces of information need to be stored in order for the site to function properly. For example, if you perform a search for jobs, the search terms you use will be remembered so that you can change them later. If you log in, we will remember which account you logged in with.

This information is stored in a database and is referred to as a session. We set one cookie to keep track of which session you are using. Old session data is automatically deleted from our databases multiple times a day, so we do not store this information long-term.

In addition to the session cookie, we sometimes set a cookie to check if we can set cookies on your computer. This is done for diagnostic purposes when you use our contact form. We use this information to help solve any problems you may have encountered.

Please be aware that cookies are critical to the working of the site. If you choose to disable cookies from this site, you will not be able to log in and the functionality of the site will be greatly reduced.

(ii) Preference Cookies

Currently, we only set two types of preference cookie. One is set if you manually switch between mobile or desktop versions (e.g. view the desktop version of the site when on a mobile phone). Your choice will be stored in a cookie. The other is set when you click OK to signify that you have accepted cookies. If this cookie is set, we will not display the banner at the top of the page.

How do I control preference cookies?

These cookies are set as a direct result of your choice, and function solely as indicators of what that choice was. We do not believe they pose any risk to your privacy. However, you can always use your browser settings to control whether or not our site can set cookies on your computer.

Please be aware that cookies are critical to the working of the site. If you choose to disable cookies from this site, you will not be able to log in and the functionality of the site will be greatly reduced.

(ii) Analytics Cookies

In order to monitor how our sites are performing, we collect data about page visits. This information is completely anonymous — we cannot determine who it came from. When we use this data, we look at numbers of visitors overall rather than individual visits.

Analytics information is used in reports and to improve our site. For example, we have used analytics data to add, remove or change features of the site based on how popular they are with users.

We track, for example:

  • the numbers of visitors to individual pages;
  • when pages were visited;
  • how long users stayed on the page;
  • the page they came from;
  • technical data about the device being used to browse the site (such as browser and operating system version, and display size) — we use this data to ensure that the technology our site uses is appropriate for the majority of our users, and how best to display the site for users who have less capable browsers.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

  1. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

  1. Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites.  When you leave our site, we encourage you to read the privacy statements of each and every website that collects personally identifiable information.  This privacy statement applies solely to information collected by the Company’s website.

  1. Sale of business 

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

  1. Data Security

The Company takes every precaution to protect our users’ information.

Our data security includes the use of firewalls, limited access, using only security compliant software providers (e.g. Microsoft Office, RDB Access), use of secure passwords, secure paper shredding, physical building security, virus/malware protection, device management controls and network security.

Only employees who need the information to perform a specific job (for example, consultants, our finance team or a marketing assistant) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email our Data Protection Lead – gdpr@executiveconnections.ie. 

  • Changes to this privacy statement

We will update this privacy statement from time to time.  We will post any changes on the statement with revision dates.  If we make any material changes, we will notify you.

  • Complaints or queries

Questions, comments and the exercise of your rights regarding this Privacy Policy and your information are welcomed and should be addressed to the Data Protection Officer by email at gdpr@executiveconnections.ie with subject “FAO Data Protection Officer” or by post at Data Protection Lead, Executive Connections Ltd., 95 Lower Baggot Street, Dublin 2, Ireland.

If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Lead, Ann Marie Brennan. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the supervisory authority in Ireland responsible for the implementation and enforcement data protection law: The Data Protection Commissioners Office. You have the right to complain to the DPC about our collection and use of your information. You can contact the DPC via their website – https://www.dataprotection.ie/docs/Home/4.htm or +353 57 8684800.

What are cookies?

Cookies are very small text files which store very small amounts of information. They are used to remember settings and preferences between visits to the site, as well as information between different pages on the same site.

For security reasons, cookies can only be read by the site that set them. We have no access to cookies set on your computer by, for example, Google, Yahoo, Microsoft or any other website on the internet. However, through the use of third-party cookies, it is possible for sites to collect information about visitors to other sites. For example, online advertisers may use third party cookies to anonymously track an individual’s visits to sites on the web.

How do we use cookies?

Currently, there are three types of cookies that may be generated as you browse our site: session cookies, preference cookies, analytics cookies.

  1. Session Cookies

As you move through the site, various pieces of information need to be stored in order for the site to function properly. For example, if you perform a search for jobs, the search terms you use will be remembered so that you can change them later. If you log in, we will remember which account you logged in with.

This information is stored in a database and is referred to as a session. We set one cookie to keep track of which session you are using. Old session data is automatically deleted from our databases multiple times a day, so we do not store this information long-term.

In addition to the session cookie, we sometimes set a cookie to check if we can set cookies on your computer. This is done for diagnostic purposes when you use our contact form. We use this information to help solve any problems you may have encountered.

Please be aware that cookies are critical to the working of the site. If you choose to disable cookies from this site, you will not be able to log in and the functionality of the site will be greatly reduced.

  1. Preference Cookies

Currently, we only set two types of preference cookie. One is set if you manually switch between mobile or desktop versions (e.g. view the desktop version of the site when on a mobile phone). Your choice will be stored in a cookie. The other is set when you click OK to signify that you have accepted cookies. If this cookie is set, we will not display the banner at the top of the page.

How do I control preference cookies?

These cookies are set as a direct result of your choice, and function solely as indicators of what that choice was. We do not believe they pose any risk to your privacy. However, you can always use your browser settings to control whether or not our site can set cookies on your computer.

Please be aware that cookies are critical to the working of the site. If you choose to disable cookies from this site, you will not be able to log in and the functionality of the site will be greatly reduced.

  1. Analytics Cookies

In order to monitor how our sites are performing, we collect data about page visits. This information is completely anonymous — we cannot determine who it came from. When we use this data, we look at numbers of visitors overall rather than individual visits.

Analytics information is used in reports and to improve our site. For example, we have used analytics data to add, remove or change features of the site based on how popular they are with users.

We track, for example:

  • the numbers of visitors to individual pages;
  • when pages were visited;
  • how long users stayed on the page;
  • the page they came from;
  • technical data about the device being used to browse the site (such as browser and operating system version, and display size) — we use this data to ensure that the technology our site uses is appropriate for the majority of our users, and how best to display the site for users who have less capable browsers.

More information about analytics cookies

We use Google to provide our analytics data. You can read more about how Google Analytics treats your data at Google: Safeguarding your data.

You can also read Google’s full privacy policy.

How do I control analytics cookies?

Google provides a tool to opt-out of Google Analytics. This is available for all modern browsers in the form of a browser plugin.

Controlling cookies within your browser

A browser is a program you use to view web pages. Your browser allows you to control what cookies are set on your computer, and how long they are stored. You may have more than one browser installed on your computer. In this case, you will need to change the settings for each browser you use.

Browser help pages relating to cookie settings

Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.

  • Internet Explorer
  • Google Chrome
  • Mozilla Firefox
  • Safari (Desktop)
  • Safari (Mobile)
  • Android Browser
  • Opera
  • Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.