Privacy Statement for www.abrivia.ie and for Abrivia Candidates(Version 2-August 14th 2018)
|Why we collect Personal Data|
|Purpose of Processing Personal Data and Legal Basis
Principles we follow in order to comply with GDPR
|Types of Data Abrivia collects from our website- www.abrivia.ie|
|Statistical and Analytical Information|
|Main third-party sources of Data|
|Other third-party sources of Data|
|Transfer of information outside the EEA|
|Legal Basis for processing your data|
|Where your data is stored|
|Right to erasure|
|Mode and place of processing the Data|
|System Logs and Maintenance|
|Information not contained in this policy|
|The Rights of Users|
|The right to lodge a complaint|
Abrivia is committed to full compliance with the requirements of the General Data Protection Regulation 2016/679 which replaces the current Data Protection Directive 95/46/EC We have therefore introduced and will follow procedures which aim to ensure that all employees, partners or other servants or agents of Abrivia (collectively known as data users/ data subjects) who have access to any personal data held by or on behalf of the company are fully aware of and abide by their duties under the General Data Protection Regulation.
“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”) who can be identified directly or indirectly in particular by reference to an identifier such as a name, location data or other means.
“Data Subject” means an individual who is the subject of personal data that is held by a Data Controller and processed by a Data Processor
“Data Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purpose and means of which your personal data is processed.
“Processor” means a natural or legal person , public authority, agency or other organisation that processes that personal data on behalf of the controller.
“ Sensitive data or Special Categories of Personal Data” means personal data revealing racial or ethnic origin, political opinions , religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural persons sex life or sexual orientation.
When you click agree to our policy, we receive a record containing your email and full name as supplied by you. We retain this as a record of who has agreed to our policy.
Your rights are as per the General Data Protection Regulations 2018, namely:
- right to be informed
- right of access – you have the right to access the information we hold about you. This is called a subject access request and must be made to using the e-mail address set out below.
- right of rectification – should you feel that we hold incorrect or incomplete information about you, please contact your Abrivia contact person to get any data rectified. Should you not have a Abrivia contact person, please use the contact details below.
- right or erasure (right to be forgotten) – please see the section on data retention.
- right of data portability
- right to restrict processing – we will always respect a request by you to stop contact by any or all methods of communication or for any specific purpose.
- right to object – we are registered with the Information Commissioner’s Office and it is your right to lodge a complaint with them.
Correspondence should be directed to the contact details below.
4.Why we collect personal data:
We collect data so that we may provide you with a reliable and efficient recruitment service in assisting you in your job search and to enable us to contact you accordingly. This may be used for the following purposes:
- To apply for jobs on your behalf – we should add in This will never be done without your consent
- To notify you of relevant job opportunities as part of our recruitment services
- Your data may used to compile short-lists of relevant candidates for certain vacancies and will be shared within Abrivia. We do not make use of any automated decision-making process as to who is short-listed for a particular vacancy.
- To provide your details (including your CV and other information provided to us) to Employers where you have submitted such information in response to job Vacancies displayed on the Website. This will never be done without your consent.
- To notify you about changes to our service.
- To carry out our obligations arising from any contracts entered between you and us.
- To apply for jobs on your behalf
- To market our recruitment services to you
- To improve our customer service through market research
5. Purposes of processing personal data and legal basis
Abrivia Recruitment Specialists aims to provide excellent recruitment and solutions services to our customers and candidates. It aims to create the best match between open vacancies and candidates seeking employment. Or in the case of our solutions business, to create the best possible solution to meet the requirements of our customer. To do this, Abrivia will need to retain data about you.
We only collect, use and retain information about you only if we reasonably believe it is justified, required and useful to conduct our business effectively and to provide you with information about products and services we believe will be of interest to you.
The Legal basis on which we collect, process and transfer your information in the above manner are based on the following:
A.To fulfil contractual obligations (Article 6 (1 b) GDPR)
Data is processed in order to provide recruitment services to our customers or in order to take instructions at the request of you prior entering into an Agreement.
B.As part of balancing interests (Article 6 (1 f) GDPR)
If necessary, we will not only process your data for the actual fulfilment of the contract but also for the pursuance of a legitimate interest, examples of which could include, but also to protect our own legitimate interests and those of third parties, especially when:
- Advertising or market and opinion research, if you have not objected to your data being used.
- Guaranteeing IT security and safeguarding IT operations at our company.
- Business management measures and measures to develop products and services.
C.Based on your consent (Article 6 (1 a) GDPR)
If you have given us your consent to process personal data for certain specific purposes it will be lawful to do this processing based on the consent you have given. Consent can be withdrawn at any time and should you wish to withdraw your consent please contact our Data Protection Manager at [email protected]
D.Based on statutory provisions (Article 6 (1 c) GDPR) or public interest (Article 6 (1 e) GDPR)
Furthermore, we are required to meet various legal and statutory requirements.
Reasons for processing data includes to confirm identity and age, to prevent fraud and money laundering, to fulfil checking and notification requirements set by tax law, Anti Money Laundering legislation and to assess and manage risks.
We will only collect the personal data that is required for the carrying out our obligations to you as per our terms of engagement and in order to comply with the relevant regulations and legislative provisions.
All information provided to us by you will be treated with the utmost confidentiality and in accordance with all applicable legislative and regulatory standards.
Abrivia collects your data in pursuit of its legitimate interest in providing benefits and services to our candidates and customers. Consent is central to the rules on direct marketing and we will require your explicit consent with regards some aspects of our direct marketing activities. We will also require your consent to pass your details onto clients for suitable roles.
Once Abrivia places a candidate with one of its customer, the data held as part of the contractual and legal obligation that Abrivia has as a certified recruitment company.
When you click agree to our policy, we receive a record containing your email and full name as supplied by you. We retain this as a record of who has agreed to our policy. This is then stored on our system
6.Principles we follow in order to comply with GDPR
– we do not collect more information than is necessary
– we do not use your data for purposes other than those specified
– we do not keep your data if it is no longer needed
– we do not share your data with third parties
-we use the appropriate technical measures to ensure that your data is securely stored on our system
7.Types of Data Abrivia collects from our website- www.abrivia.ie
We may collect Non-personal and Personal data.
- Information that you provide by filling in forms on our sites www.abrivia.ie and www.abrivia.com (Website). This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further information or services. We may also ask you for information when you report a problem with our site.
- Personal data relates to a specific individual who may be identifiable from that data. This can include:
- Contact information such as name, email address and phone number
- Job title, employment history, qualifications, a copy of your CV, past and current remuneration (Note: information submitted by you relating to your education, employment history, other work-related information (include rate or salary information) and any other information provided to us on a CV in the context of using our Jobseeker services will be stored.)
- Abrivia uses Google Analytics and Cookies in order to improve our service, and analyse how the website is used. Other than the approximate location (IP address), the information collected by Google Analytics is mostly anonymous traffic data including browser information, device information and language.
- The collected information is used to provide an overview of how people are accessing and using our website and is not used for any additional purpose, such as to profile those who access our website.
- Demographic information such as address and preferences
- Notes from meetings/interviews/phone calls with you
- Assessment test results e.g. psychometric tests
- 3rd party references
- User IP addresses
- Any other employment related data
- If you contact us or we contact you, we may keep a record of that contact and information you may share with us
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Social Media Plug-Ins
- Our website features six plug-ins for easy sharing and to follow our social media pages: Facebook, Twitter, LinkedIN, You Tube, RSS feeds and Google Plus. Being on our website does not automatically result in sharing data on these social media networks. These plugins remain inactive (idle) until clicked upon. Once clicked upon, you will be taken to the said social media networks with their own specific privacy policies.
Non-Personal Data cannot be used to identify or contact you. It can include:
- Statistical information about visitors to our website
- Browser types
- Demographic information
All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.
9.Statistical and Analytical Information
The statistical and analytical information provides general and not individually specific information about the number of people who visit this website; the number of people who return to this site; the pages that they visit; where they were before they came to this site and the page in the site at which they exited. This information helps us monitor traffic on our website so that we can manage the site’s capacity and efficiency. It also helps us to understand which parts of this site are most popular and generally to assess user behaviour and characteristics in order to measure interest in and use of the various areas of the site.
15Main third-party sources of Data
We may source information using third parties, which include, but are not restricted by, the following:
– Job boards with which we have a contract
– Data aggregating providers e.g. Broadbean
16.Other third-party sources of data:
We also collect personal data from 3rd parties. If collecting information from a 3rd party we will seek your consent in advance or otherwise make you aware of the collection and the reasons for it. This information may include:
- Professional references
- Results of competency tests
- Subjective feedback on performance
- Information from or about you in relation to workplace complaints, accidents
- Any inquiry in which you are involved – insurance, litigation, registration, disciplinary, criminal, etc.
17.Transfer of information outside the EEA
If we need to transfer your data outside the EEA, we will alert you and explain clearly why we’re doing it. This will only occur in relation to recruitment or related services provided by Abrivia Recruitment Specialists. Generally, we operate within the EEA but we do sometimes deal with non-EEA companies.
Your data will be stored within our recruitment CRM(Bullhorn). This system is cloud based, but we ensure that all necessary data protection protocols are in place.
We do not store any sensitive personal data (as defined in the General Data Protection Regulation 2016 Article 9), unless it has been provided by you as a part of the application or screening process if required for a job. In this case it will only be stored with your specific consent.
If you exercise your right to erasure, we will retain all information we are legal obligated to do so (such as employment contract data or financial payment), for the period that is set out by that legal obligation. We may also keep your name and e-mail address so that we do not contact you or re-enter your details inadvertently in the future.
21.Mode and place of processing the Data
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
- Place of processing
The Data is processed at the Data Controller’s(Abrivia’s) operating offices (17 Upper Mount Street) and in any other places where the parties involved with the processing are located. For further information, please contact [email protected]
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.
For information submitted to Abrivia post May 25th, 2018, the retention period is 4 years from this date. This 4 year period is based on your legitimate interest as approximately 10% of placements have been on our database for 4 years or more.
Please contact [email protected] in this regard.
Additional information about Data collection and processing:
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
24Additional information about User’s Personal Data
25.System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).
26.Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller(Abrivia) at any time or by contacting [email protected]
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Under Article 77 of GDPR, as a data subject, you have the Right to lodge a complaint with a supervisory authority. In Ireland the supervisory authority is the Office of the Data Commissioner.