PRIVACY NOTICE

With a reputation for excellence and a passion for innovation and creativity in the recruitment sector, DAPF Jobs is a leading recruitment agency driven by a culture of high quality, high performance and high commitment and where trust, honesty, collaboration, professionalism, accountability and diligence is at the very heart of all we do. At DAPF Jobs, we pride ourselves in building lasting relationships and our vast network of jobseekers and employers is the cornerstone of our business.

DAPF Jobs fully complies with relevant and applicable data protection legislation to keep your data safe and secure. Our goal as always is to increase the standards of the recruitment industry. We therefore apply due diligence to our recruitment process and procedures as well as to the Data Protection and GDPR policies in order to ensure that jobseekers and prospective/potential employers are correctly matched to the right roles, jobs and employments.

The purpose of this document is to set out the privacy entitlements of data subjects, which are defined in the General Data Protection Regulation (GDPR) as 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:

• data subjects who are jobseekers looking for temporary or permanent employment
• data subjects who are seeking employment and are introduced to or connected with potential employers as appropriateThe contact details of clients, which includes their personal details, such as email addresses and telephone numbers

There are different categories of data required between the differing data subject categories, but only the information necessary to provide the services requested by each data subject is collected.

PROCESSING PERSONAL DATA OF JOBSEEKERS AND EMPLOYERS

The following is our basis for processing the data we collect:
Information that is required to perform the service of “Employment agent” on behalf of our jobseekers with potential employers. 

The basis of data gathering in that instance is a requirement. This will include identification information such as but not limited to name, address, date of birth, and information regarding education/qualifications.

We process information in the legitimate interests of the business of our employment agency, and where so processed, it will be in accordance with and subject to the data subject’s rights and/or entitlements.

We also process the subject’s data when it is in the legitimate interests of our business to do so and we do this by balancing the data subject’s data protection rights.

We consider that our legitimate interest is that the data subject has registered with us because they are interested in gaining access to the information we provide in relation to employment offers, job vacancies, prospective employers and/or information relating to career opportunities with potential and prospective employers.

In order to balance data protection rights of the data subject against the legitimate interest of our business, we also take the following into consideration: 

• 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; and
• Your rights and entitlements to stop the processing of your data with ease and to this end, we put you in control of the data that is accessible in our website (subject to our own statutory and contractual 
•  obligations).

 

We process data pursuant to business-to-business transactions, but where so required, we also apply the basis of necessity to the performance of our services in respect of the processing of personal data within this relationship. These are:

• The utilisation of information required to perform our statutory obligations such as tax returns and compliance with employment legislation. The information includes PPS numbers and, where relevant, appropriate
•  and/or applicable, evidence of entitlement to work; and
• The utilisation of personal data in the form of email addresses and contact telephone numbers in order to keep our clients informed in relation to careers and/or market related information as we consider it to be in the legitimate interest of our business to maintain a market presence.

CONSENT 

On occasion, we may rely on consent in the collection and processing of certain categories of data; given the nature of our relationship of agent to jobseekers as well as agent to employers, we consider that consent is often not an appropriate ground on which to rely and therefore it will be utilised only in necessary and appropriate circumstances.

PERSONAL DATA

This Privacy Statement sets out how we  use and process any information that is given to us. We respect your privacy and are committed to protecting your personal information. This Privacy Statement explains how we collect, transfer, process, use and disclose your data as well as sets out our security practices.

PERSONAL DATA COLLECTION OF JOBSEEKERS AND EMPLOYERS

We collect personally identifiable information (PII) provide by jobseekers to us, which is information that identifies them as individuals. This PII may include: 

• name
  · address
  ·         email address(s)
  ·         phone number(s)
  ·         education,
  ·         employment history,
  ·         CV and any other information required to provide you with job placement services
  ·         We may source contact details through social media and reach out to you there

 

We collect data from you and process it in the provision of our services as a recruitment agency.  This involves receiving your data, highlighting your skills and competencies, making telephone contact with you, emailing you with positions that may be of interest to you, emailing you about market trends, emailing and telephoning potential employers to advance your career prospects with those companies and sharing your data with those potential employers.  

When you register with us, you are agreeing to us acting as an agent for you in your pursuit of an employment position with a third party until you request that your details are removed or that you require us to cease processing your data (which you can do at any stage). Our agency in its 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.

For some positions, we are obliged to collect data that could be considered as special categories of data (as defined in the GDPR) that is required for legal compliance purposes such as for security or HIQA audit purposes and we will inform you fully if, and when such a circumstance arises.

We will only process special categories of data with your specific and explicit consent or where one of the following conditions apply:

• The processing is a necessity arising from contractual obligations
• The processing relates to personal data which has already been made public by the data subject
• The processing is necessary for establishing, exercising and/or defending a legal claim
• The processing is expressly and specifically authorised and/or required by law
• The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving their consent
• There are further conditions, including limitations, based upon national law, related to the processing of genetic data, biometric data and/or data concerning health

 We may also collect personal data about you from the application forms and/or questionnaires that 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 is used to identify visitors to our website as well as to collect statistics about the behaviour of visitors whilst on our website. 

If your personal data changes, please make us aware so that we can ensure your personal data is kept up to date and accurate. 

We collect personally identifiable information (PII) that employers provide to us; that is, information which is used to identify an individual jobseeker or employer.

We collect PII about employers from a variety of sources, such as where: 

• The PII is provided directly by the employers
  · The PII is provided from another source within the employers’ resources or organisation
  ·         The information is collected from public sources including social media and we may reach out to employers on social media 

USE OF YOUR PERSONAL INFORMATION

We collect and use all PII provided, to deliver job seeking, recruitment, and/or other related services that have been requested from us; Such information will only be used for matching skills with potential job opportunities and will be only disclosed to prospective employers. We may also use the information:
·         to consider a jobseeker’s application for employment
·         to notify a jobseeker of our new employment opportunities
·         to respond to a jobseeker’s request(s)
·         to improve our level of service
·         to notify a prospective employer of a jobseeker’s interest in applying for a job vacancy they have
·         to increase a jobseeker’s chances of securing a job they have applied for or are interested in applying for
·         to provide market knowledge and career information 

We collect and use all PII in accordance with the provisions of this policy and in furtherance of our recruitment business. 

All information will only be used to contact data subjects in the following circumstances: 

• discussing potential requirements for our services
• developing an understanding of the employers’ organisation and the jobseeker’s profile requirement
• discussing potential jobseekers for vacancies employers have requested us to assist with in recruiting for
• scheduling a jobseeker’s interview
• updating employers with regards to jobseekers whose data have been shared with them and for progressing the processing and on-boarding of successful jobseekers
• sharing interview contact information with candidate(s) who are actively seeking work and have been selected or shortlisted for interview with an employer
• sharing market knowledge and career information with employers

We use employers’ personal data for the purposes of making and receiving payments in the ordinary course of our business.

 Any contact information that is provided through our system will not be sold, leased and/or distributed to any third party for any purpose whatsoever without your express written consent.

SECURITY OF PERSONAL INFORMATION

We will do our utmost to protect user privacy through the appropriate use of security technology. We will ensure that we have appropriate physical and technological security measures to protect all information held by us.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect all personal data we hold, we cannot guarantee the security of data transmitted to our site; any transmission is at the transmitter’s own risk.  

Once we have received information transmitted to us, we will use strict procedures and security features to try and prevent unauthorised access.

LINKS TO OTHER WEBSITES

On occasion, we may include links to third parties on our website. Where we provide a link, it does not mean that we endorse or approve that site’s policy towards visitor privacy or that we accept any liability in relation to their use of data. The privacy policy of the third party should therefore be reviewed before any personal data is sent to or shared with them.
 
HOW WE USE COOKIES

Our website uses cookies to distinguish users of our website.  Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about a visitor’s computer in order to assist us in improving our services and website.

We may also gather information about the general internet use of visitors to our website by using cookies. 

Where cookies are used, they are downloaded to the visitor’s computer and stored on the computer’s hard drive. Such information will not identify the visitor personally as it is only statistical data. This statistical data does not identify any personal details whatsoever.

The cookies settings on the visitor’s computer can be adjusted to decline any cookies, if they so wish. This can easily be done by activating the reject cookies setting on the visitor’s computer.

 DISCLOSURE

A necessity of our contractual engagement is that we share jobseekers’ personal data with our potential and prospective employers.  We may therefore have in place Data Sharing Agreements or Data Processing Agreements with all such employers (in the form of actual agreements or merely additional clauses within the terms and conditions of engagement); we will do our utmost to ensure that all such parties process jobseekers’ data in a manner that is consistent with our Privacy Notice and GDPR, though we do not give any guarantee of compliance on behalf of such parties.

Employers who engage us, may themselves be subject to third party audits either in the form of statutory and/or ethical audits, governmental/statutorily required audits or legal obligations; these are deemed a necessity of the contract of engagement and on this legal basis personal data will be shared by them to comply with these requirements.

We do not broker or pass on information gained from jobseekers’ engagement with us without their express written consent. However, we may disclose your Personal Information to meet legal obligations, regulations, and/or valid governmental requests. 

We 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 agency, its clients and/or the wider community.

DATA RETENTION 

Subject to the rights of data subjects as prescribed by the GDPR, we will at all times process personal data for the duration of any contract and will continue to store personal data in accordance with our data retention obligations and types.

JOBSEEKERS CURRICULUM VITAE

We will retain the CVs of jobseekers on our file to keep them updated with regards to relevant job opportunities, market information, trend analysis, salary information and market updates. It is important to us that the data which we hold is accurate and up to date and accordingly, we may contact you from time to time to request updated information.

We will also give jobseekers the opportunity to seek erasure of their data at that stage, and should they require their data to be erased, we will immediately do so (subject to our statutory and contractual obligations). 

DATA STORAGE

Data is held in the United Kingdom and in the Republic of Ireland using different (multiple) servers. We do not store personal data outside the EEA.

DATA SUBJECT RIGHTS UNDER GDPR AND ACCESS TO INFORMATION AND UPDATING, VERIFYING, DELETING AND RETENTION OF PERSONAL DATA

Subject to other relevant and applicable legal requirements, we will hold your personal data in accordance with the retention guidance set out above.

Every individual has the right to withdraw their consent and have their personal information erased at any time (subject to our statutory and legal obligations as set out). 

For the entirety 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 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 may sometimes only be only do so after the statutory period of record retention has expired.  

Should we be 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.

When the data of a data subject has been erased from our system, their name and email address are recorded in a separate document by our DPO and saved securely. It is necessary to record these details of contacts who have been removed from our database because some contacts may on occasion have different email addresses which can lead to multiple entries on our database.

At any time following a request from you we can confirm what information we hold about you, as well as how and why it is being processed.

YOU CAN REQUEST THE FOLLOWING INFORMATION: 

• Identity and the contact details of the person or organisation that has determined how and why to process your data
  · Contact details of the data protection officer, where applicable
  ·         The purpose of the processing as well as the legal basis for processing
  ·         If the processing is based on the legitimate interests of our agency or a third party such as one of its clients, information about those interests
  ·         The categories of personal data collected, stored, and/or processed
  ·         Recipient(s) or categories of recipients that the data is/will be disclosed to
  ·         How long the data will be stored
  ·         Details of your rights to correct, erase, restrict or object to such processing
  ·         Information about your right to withdraw consent at any time
  ·         How to lodge a complaint with the supervisory authority (Data Protection Regulator)
  ·         Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary for entry into a contract, as well as whether you are obliged to provide the personal data and the 

       possible consequences of failing to provide such data
·         The source of personal data if it was not collected directly from you
·         Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing 

IDENTIFICATION REQUIRED TO ACCESS PERSONAL DATA HELD

We will accept the following forms of identification when information on your personal data is requested: a copy of your national ID card, driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic identification of the type 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 the above requests can be directed in writing to the Data Protection Officer, 35 Fairview Close, Richmond Avenue, Dublin 3.  They will be forwarded on, should there be a third party involved in the processing of the personal data requested.

COMPLAINTS

Should a complaint want to be made about how personal data is being processed by us or by our partners, you have the right to complain to customerservices@dapfJobs.com.                                                                                                                                                                                               
 If you do not get a response within 30 days you can complain to the OFFICE OF THE DATA COMMISSIONER, Supervising Authority of Ireland.
Data Protection Commissioner
Canal House
Station Road
Portarlington
R32 AP23 Co. Laois
Telephone:  +353 57 8684800
Lo Call Number 1890 252 231
E-mail   info@dataprotection.ie

CHANGES TO THIS PRIVACY STATEMENT

Our Privacy Statement may change from time to time and changes to the statement will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy and if you do not agree to these changes, please do not continue to use this Website to submit personal information.