Introduction

Cregg Labour Solutions Ltd (trading as Cregg Recruitment) fully respects your right to privacy and takes its responsibility regarding the security of your information very seriously.

  • This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates or you are visiting our website.

 

  • It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

 

  • This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact. It also applies to the emergency contacts of our Staff.

 

Data Controller

Cregg Labour Solutions Ltd (referred to as “Cregg Recruitment”, “we” in this policy) is the “data controller” of all personal information that is collected.

 

What kind of personal data do we collect?

Candidate Data

In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you.

We only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks), and social security number (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, proof of identity, details of any criminal convictions where relevant to the roles applied for, extra information that you choose to tell us; extra information collected through the use of psychometric assessments, extra information that your referees chooses to tell us about you; extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites; IP address; the dates, times and frequency with which you access our services; and CCTV footage if you attend our premises.

To the extent that you access our website we will also collect certain data from you.

 

Client Data

If you are a Cregg Recruitment customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: (i) finding Candidates who are the right fit for you or your organisation; (ii) providing you with a Managed Service Provider (“MSP”) programme (or assisting another organisation to do so); (iii) providing you with Recruitment Process Outsourcing (“RPO”) services (or assisting another organisation to do so); and/or (iv) notifying you of content published by Cregg Recruitment which is likely to be relevant and useful to you.

The data we collect about Clients is very limited. Typically, we collect your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly and to facilitate other material published by Cregg Recruitment, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us.

 

Supplier Data

We’ll only collect enough information to support the effective running of our relationship – such as the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

 

Website Users

We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website we will collect any information that you provide to us, for example your name and contact details.

 

How do we use your personal data?

Candidate Data

The main reason we use your personal details is to help you find employment or other work roles that might be suitable for you and in support of associated activities resulting therefrom. The more information we have about you, your skillset and your ambitions, the more targeted we can be in meeting both your and our customers requirements. Where appropriate we may also use your personal data for marketing activities. Where appropriate, we will seek your consent to undertake some of these activities.  We may also use your personal data to establish or defend legal claims or to generate aggregated data on our workforce or job applicants.

 

Recruitment Activities

We’ve listed below various ways in which we may use and process your personal data for this purpose. Please note that this list is not exhaustive

  • Collecting your data from you and other sources, such as LinkedIn;
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
  • Keeping records of our conversations and meetings, so that we can provide targeted services to you;
  • Providing you with our recruitment services and to facilitate the recruitment process;
  • Assessing data about you against vacancies which we think may be suitable for you;
  • Sending your information to Clients in order to apply for jobs or to assess your eligibility for jobs;
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
  • Allowing you to participate in online training;
  • Allowing you to participate in the interactive features of our services, when you choose to do so;
  • Carrying out our obligations arising from any contracts entered into between us;
  • Carrying out our obligations arising from any contracts entered into between Cregg Recruitment and third parties in relation to your recruitment;
  • Facilitating our payroll and invoicing processes;
  • Carrying out customer satisfaction surveys;
  • Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

 

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object. We may also process your personal data

  • To comply with a legal obligation
  • You have consented to us using your personal data (e.g. marketing related purposes including those related to our full range of recruitment services (permanent, contract, MSP & RPO services, etc)
  • To protect your vital interests or those of another person (e.g. medical emergency)

 

Marketing Activities

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.

 

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time.

All our marketing is based on what we think will serve our Clients and Candidates best.

 

Equal opportunities monitoring and other sensitive personal data

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may collect about you e,g, gender, we’ll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.

 

Where we collect ‘sensitive’ personal information slightly stricter data protection rules apply to it. We, therefore, need to obtain your explicit consent before we can use it.

 

We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.

 

If you are not happy about this, you have the right to withdraw your consent at any time.

 

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

 

Client Data

The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve: (i) identifying Candidates who we think will be the right fit for you or your organisation; (ii) providing you with an MSP programme (or assisting another organisation to do so); and/or (iii) providing you with RPO services (or assisting another organisation to do so). The more information we have, the more bespoke we can make our service.

 

Supplier Data

The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.

We will use your information:

  • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
  • To offer services to you or to obtain support and services from you;
  • To perform certain legal obligations;
  • To help us to target appropriate marketing campaigns; and
  • In more unusual circumstances, to help us to establish, exercise or defend legal claims.
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

 

We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.

 

If you are not happy about this, in certain circumstances you have the right to object.

 

 

People whose data we receive from candidates and staff, such as referees and emergency contacts

We use referees’ personal data to help our Candidates to find employment which is suited to them. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member’s emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

If you are not happy about this, you have the right to object.

 

Website users

We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. If you are also a Candidate or Client of Cregg Recruitment, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.

Please note that communications to and from Cregg Recruitment Staff including emails may be reviewed as part of internal or external investigations or litigation.

 

Who do we share your personal data with?

Candidate Data

We may share your personal data with various parties. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service. A non-exhaustive list would include:

  • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data;
  • Third party service providers who may perform functions on our behalf (including external consultants, payroll bureaus, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • Marketing technology platforms and suppliers;
  • In the case of Candidates: potential employers and other recruitment agencies/organisations (including MSP/RPO partners), job boards ,aggregators etc to increase your chances of finding employment;
  • Third parties who we may engage to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
  • If Cregg Recruitment merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

 

Client Data

We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates; (ii) to provide you with an MSP programme (or assist another organisation to do so); and/or (iii) to provide you with RPO services (or assist another organisation to do so

 

Supplier Data

Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

 

How Do We Safeguard Your Personal Data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

 

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

 

Unfortunately, the transmission of information via the Internet or a mobile phone network connection is not completely secure. Although we will do our best to protect your personal information (PI), we cannot guarantee the security of the PI you transmit to our website. Any transmission is at your own risk. While we cannot guarantee that loss, misuse or alteration to data will not occur during transmission, once we have received your information, we will employ appropriate technical security measures to protect your data.

 

How Long Do We Keep Your Personal Data For?

We will delete your personal data from our systems if we have not had any meaningful contact with you for five years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected

Where services are provided via a third party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services.

 

Data Processing Rights

Under certain circumstances, by law you have the right to;

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it

Request erasure of your personal information. This enables you in certain circumstances to ask us to delete or remove personal information where there is no longer a valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Right to restriction of processing – where certain conditions apply to have a right to restrict the processing in accordance with Section 87 and Section 89 of the Data Protection Act 2018

Right to rectification: You also have the right to Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Right of data portability – subject to certain restrictions, you have the right to have the data we hold about you transferred to another organisation where we hold it in electronic form. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

 

Complaints

We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. If you have any questions about this policy or how we handle your personal information, please contact the DPO at dpo@cregg.ie.

In the event that you wish to make a complaint about how your personal data is being processed by us or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority:

Data Protection Commissioner: Office of the Data Protection Commissioner. Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland. Phone +353 (0761) 104 800 | LoCall 1890 25 22 31 | Fax +353 57 868 4757 | email info@dataprotection.ie

 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

 

 

Cookies

Our websites and mobile applications may use technology called “cookies.” A cookie is a small text file that is placed on your hard disk by a server. Cookies allow our websites and mobile applications to respond to you as an individual. The website or mobile application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or receive a warning before a cookie is stored if you prefer. Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences.

If you choose to decline cookies, you may not be able to fully experience the interactive features of our website.

We may use cookies to do two things:

  • to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
  • to help us advertise jobs to you that we think you’ll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.

 

Changes

We may occasionally update this Privacy Statement. If the changes we make are material, we also may post a notice regarding the changes on our website. We encourage you to periodically review this Privacy Statement to stay informed about how we are helping to protect the personally identifiable information we collect.

 

Annex 1 – How to Contact Us

How you can get in touch with us:

  • to access, amend or take back the personal data that you have given to us;
  • if you suspect any misuse or loss of or unauthorised access to your personal information;
  • to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
  • with any comments or suggestions concerning this Privacy Policy

 

You can write to us at the following address:

Unit 13C Briarhill Business Park

Ballybrit

Galway

 

 Updated: 15/01/2020