CS Recruitment – Data Protection Policy

Title:

Privacy Policy

Document Type:

Policy

Reference/version no:

2

Status:

Approved

Last Updated:

04.01.2021

Background:

Data protection policy – to be furnished to all clients, candidates, and employees.

IDENTITY

WHO ARE WE?

CS Recruitment provides third party recruitment agency services. We work in the area of Finance and Legal recruitment and work with the major Law firms, Accountancy practices, Financial Services Institutions and PLC’s in Ireland and Internationally. We work from a Junior, Mid and Senior level roles with these businesses.

We use certain expressions throughout this document such as Personal data and Special Categories of Personal Data.

Personal Data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special categories of Personal Data includes information about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Special categories of Personal Data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.

Data Controller means the entity which, by itself or jointly with others, determines the purpose and means of processing Personal Data.

For the purpose of the Data Protection Acts 1988, 2003, 2018 and the General Data Protection Regulation (the GDPR), the data controller is CS Recruitment.

This notice sets out the basis on which any personal data we collect from clients, candidates or employees that is provided to us, will be processed by us.  Please read the following carefully to understand our practices regarding how we will treat personal data provided to us.

OUR POLICY

THIS DATA PROTECTION POLICY

This policy sets out details of how CS Recruitment manages personal data generally. This includes Personal Data relating to clients, candidates, potential candidates, employees, contractors, or those working on a temporary or permanent basis (“staff”).

WHAT INFORMATION DO WE COLLECT FROM YOU?

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

You may give us personal data where you are a current client, current, former, or prospective candidate, or employee on a permanent or temporary basis.

You may give us information by:

  • using our recruitment services as a client in Ireland. The type of information we may collect includes your company point of contact name; address; email address; phone number; and invoice details.
  • interacting with us when you are a potential candidate. The type of information we may collect includes your name; phone number; address; email address, current role, current company, current salary and notice period, referee details, academic and professional qualifications, nationality and work permit status and the role that you are interested in.
  • applying to work with us as an employee or contractor or wishing to be added to our candidate database. The type of information you may provide includes your CV, your name, address, e-mail address, phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal information (e.g., gender, height, weight, medical information, religion, philosophical or political beliefs, financial data).
  • corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary for the purpose of your interaction with us.

WHY?

WHY DO WE COLLECT THIS PERSONAL DATA?

We collect the Personal Data, and where necessary Special Categories of Personal Data, in order to provide you with our recruitment services, to transact business, to market our services, to recruit staff and to improve our website.

We will use this information:

  • to carry out our obligations arising from any agreements entered into between you and us;
  • to communicate with you as part of our relationship with you or as per our contract with you;
  • for statistical analysis purposes, to monitor our performance and delivery of service;
  • to create a candidate profile for you if you are a prospective employee which is a step we need to take prior to entering into a contract with you;
  • to communicate any upcoming CS Recruitment events events where you have ‘opted in’ to receive such material;
  • to administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • as part of our efforts to keep our website safe and secure.

The legal bases for the processing of your personal data are:

  1. the processing is necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract;
  2. processing necessary for the purposes of the legitimate interests which we pursue prior to contract (for example, in providing you with information about our services) and post contract (for further details, see the section entitled ‘Who Might We Share Your Personal Data With?’) where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information;
  3. the processing is necessary for compliance with a legal obligation to which we are subject; and/orthat you have provided consent for the processing for one or more specific purposes;

THIRD PARTY ACCESS TO YOUR PERSONAL DATA

WHO MIGHT WE SHARE THIS PERSONAL DATA WITH?

We may share your Personal Data, and if necessary and in accordance with legal requirements, Special Categories of Personal Data, with selected third parties, including business partners, suppliers and sub-contractors, for example to provide you with our services and for the performance of our contract with you. Further details of the sharing of Personal Data (including, if necessary and in accordance with legal requirements, Special Categories of Personal Data) are set out below.

In addition, we may disclose your Personal Data to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data and Special Categories of Personal Data to the proposed seller or buyer of such business or assets at an appropriate time;
  • If we, or substantially all of our assets, are acquired by a third party, in which case Personal Data and Special Categories of Personal Data held by us will be one of the transferred assets;
  • If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety of others. This includes, without limitation, exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We have set out below a list of third parties with whom we share your Personal Data:

Third party description

  1. HR software
  2. Cloud Service Providers
  3. Sub-contractors
  4. Email and IT service providers
  5. Auditors
  6. Accounting software
  7. Security software
  8. IT Back-up Providers
  9. Cookie analytics service provider

MINIMISATION

HOW LONG DO WE KEEP HOLD OF YOUR PERSONAL DATA?

We only collect the amount of personal data that is necessary for us to fulfil our obligations as your client, employer or contractor. We will only keep that data for certain periods. The time periods for which we retain your data depends on the type of personal data and the purposes for which we use it. We will keep your personal data for no longer than is required or permitted.

TRANSFERS

DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EUROPEAN UNION OR EUROPEAN ECONOMIC AREA?

NO

The data that we collect from you is not transferred to, or stored, outside the European Economic Area (“EEA”).

YOUR RIGHTS

WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?

You have the following rights:

  • The right to access the personal data we hold about you.
  • The right to require us to rectify any inaccurate personal data about you without undue delay.
  • The right to have us erase any personal data we hold about you in circumstances such as where it is no longer necessary for us to hold the personal data or, in some circumstances, if you have withdrawn your consent to the processing.
  • The right to object to us processing personal data about you such as processing for profiling or direct marketing.
  • The right to ask us to provide your personal data to you in a portable format or, where technically feasible, for us to port that personal data to another provider provided it does not result in a disclosure of personal data relating to other people.
  • The right to request a restriction of the processing of your personal data.

Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

You may exercise any of the above rights by contacting the Data Protection Officer on [email protected]

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commissioner. The website is www.dataprotection.ie.

CHANGES TO THIS POLICY

WHAT WILL HAPPEN IF WE CHANGE OUR PRIVACY POLICY?

This Policy may change from time to time, and any changes will be notified to you and posted on our website. Please review this notice each time you use our site or our services. This notice was last updated on 4th January 2021.

CONTACT

HOW CAN YOU CONTACT US?

You can contact us:

By phone: +353 86 3301792.

Our website is: www.csrecruitment.ie

Our Data Protection Officer can be contacted by emailing [email protected]