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Recruitment data policy

RECRUITMENT DATA STATEMENT FOR CLIENT SOLUTIONS

Last Updated: May 2021

When we refer to “Personal Data” in this Data Protection Statement we mean 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.

OUR RECRUITMENT DATA PROTECTION STATEMENT

Under the General Data Protection Regulation (the “GDPR”), we are required to explain to you why we are asking for information about you, how we intend to use the information you provide to us and whether we will share this information with anyone else. 

We must also explain your rights under the GDPR and related data protection laws in relation to our processing of your Personal Data. For your convenience we have divided our Data Protection Statement into sections. Our general Data Protection Statement is available on our website.

This recruitment data protection statement sets out specific information relating to how we process Personal Data of Job Applicants (“Applicants”) .

An Applicant is any person who engages with us engaging directly for job opportunities within Client Solutions or to fill a role on behalf of a Business Contact of Client Solutions whether on a permanent or a contract basis.  

We treat the protection of your personal data seriously and when we collect and process your Personal Data, we will do so in accordance with the GDPR and relevant local data protection laws (the “Data Protection Laws”).

ABOUT US

We are Client Solutions  
Our head office is at NSC Campus, Loughmahon Technology Park, Cork T12 XF5A, Ireland 
Our other offices are 14 Joyce way, Park West Business Park, Dublin 12 F9X8, Ireland
  Avinguda Via Augusta, 15-25, Planta 10, Sant Cugat del Vallès E-174,  Barcelona, Spain
Email enquiries@clientsolutions.com
Telephone +353 (0) 1963 1860
Our website is www.clientsolutions.com

This Recruitment Data Protection Statement applies to Client Solutions Limited and Client Solutions S.L.U. 

References to “We”, “Us” the “Company” and “Client Solutions” shall apply to the company in the group that is processing your Personal Data.   

Client Solutions is the Irish enterprise technology partner of choice. We work with large private and public sector organisations helping them to transform, refresh or extend their technology capabilities to harness the value of digital change and become more agile, lean, responsive and competitive.​ We combine original thinking, logic, technology and sector expertise to solve the most complex business technology problems and deliver pragmatic solutions via our five dedicated enterprise technology practices.​

With offices in locations across Ireland, Spain and Poland we provide the strategy, design, implementation and support services that fast-growing modern enterprises need to transform their business futures, now.​

This Data Protection Statement describes how we process Personal Data in order to :

  • recruit prospective employees to open positions in our company; and 
  • to refer prospective employees to our business contacts.

It includes detailed information about the types of Personal Data that we process, and how we use, manage and protect that Personal Data. 

DPO CONTACT DETAILS

If you have any questions about this Data Protection Statement or the way in which your Personal Data is being used by us, please contact our Data Protection Officer  

Email: dpo@clientsolutions.com

WHO THIS DATA PROTECTION STATEMENT APPLIES TO?

This Recruitment Data Protection Statement applies to the Personal Data we process about Applicants applying for positions as employees at our company or who engages with us to fill a role on behalf of a Business Contact of Client Solutions whether on a permanent or a contract basis.

LAWFULNESS OF PROCESSING

We process all Personal Data lawfully and in accordance with the requirements of the Data Protection Laws. The GDPR sets out the legal grounds for processing Personal Data. 

When Client Solutions processes Personal Data any one of the following legal grounds will generally apply.  Further detail about the lawful basis for our processing activities in included in the relevant sections of this Data Protection Statement.

CONTRACT

We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering that contract. When you apply for a job some of our processing activities will be carried out in order to take steps necessary to enter into a contract of employment with you.

CONSENT

For certain processing activities we may rely on your consent. Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.

You can withdraw consent provided by you at any time by contacting us at recruitment@clientsolutions.com 

LEGITIMATE INTEREST

At times we will need to process your Personal Data to pursue our legitimate interests, for example for administrative purposes, to provide information to you, to operate, evaluate, maintain, develop and improve our websites and recruitment portals or to maintain their security and protect intellectual property rights.  

We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweighs our legitimate interests. 

You may object to any processing we undertake on this basis. If you do not want us to process your Personal Data on the basis of our legitimate interests, contact us at recruitment@clientsolutions.com  and we will review our processing activities.

LEGAL OBLIGATION

If we have a legal obligation to process Personal Data, we will process Personal Data on this legal ground.

SOURCES OF APPLICANT DATA

We receive Personal Data about Applicants from a variety of sources. 

Usually, an Applicant provides us with certain information directly, for example, when the Applicant sends us their CV, applies directly for a position advertised on the Client Solutions website, or interacts with our communications (e.g., websites and advertisements).

We may also receive Personal Data about an Applicant when:

  • the Applicant applies to a position advertised on a third-party job’s website;
  • the Applicant  may be sourced from publicly accessible platforms such as LinkedIn;
  • the Applicant may be sourced from third party CV providers such as jobs websites that provide CV search facilities and where users have made their CV data available to registered customers of these sites; and
  • the Applicant’s nominated referees or other individuals may provide us with Personal Data relating to the Applicant.

 

CATEGORIES OF APPLICANT PERSONAL DATA

The table below sets out the general categories of Personal Data that we collect in relation to Applicants.

Personal Data Category Description
Contact Data may include a person’s email address, phone number, postal address, other communication details (e.g., Skype)
Identification Data may include a person’s name, date of birth, driver’s license, national tax identification number and passport information
Professional Data may include profession, company, department, employment history, skills/ experience, membership of professional bodies
Education Data may include degrees, certificates and diplomas awarded, languages, educational history, qualifications
Application Data

includes Personal Data provided as part of an application for a permanent or temporary position advertised by Client Solutions. 

may include Contact Data, Identification Data, Professional Data, Education Data and information about achievements and hobbies

Financial Data includes payment and bank details, tax information, social security and salary expectations
Test Data includes the Applicant tests answers and results for any job application
Health Data includes health information including information about any disability or illness. 
Position Data includes information on salary/rate of pay, working hours and job description
Emergency Contact Data may include the name and contact details provided by a Applicant in case of an emergency.
Communications Data may include Personal Data included in communications with us over email, text, phone or letter.
Marketing Data may include your Contact Data and any preferences in receiving marketing from us and your communication preferences.
Web Data may include information provided on any forms on our website and, to the extent that it includes Personal Data, information on the type of device you are using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

 

OUR PROCESSING ACTIVITIES

We can only collect your Personal Data if we have a lawful basis for doing so. 

We have set out in the table below, the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing.  

Purpose/Activity Type of Personal Data Lawful basis for processing 
Applicant Sourcing 
  • to advertise roles on the Client Solutions website
  • to create a record/file for the Applicant on our system and to associate all notes and tracking throughout the job search, interview, placement, onboarding and contracting process
  • to keep up to date information about Applicants in relation to their job search process and their requirements, in order to assess their suitability for current or future vacancies
  • to maintain our Applicant database
  • screening and identification of Applicants for available positions
  • to communicate with Applicants about jobs that might be of interest to them
  • to receive and review job applications

CV Data

Communications Data

Marketing Data

Legitimate interest

Consent

Applicant Applications
  • responding to Applicant queries
  • receiving and reviewing Applicant applications received from Applicant directly
  • communications with Applicant re application
  • setting up interviews with the Applicant

CV Data

Communications Data

Consent

Legitimate Interest

Applicant Interview 
  • to arrange and undertake Applicant Interviews
  • recording notes of Applicant Interview
  •  
  • to communicate with the Applicant following interview

CV Data

Communications Data

Media Data

Consent

Legitimate Interest

Contract

Applicant Screening
  • to identify if the Applicant is fit to work
  • to assess the Applicant working capacity

CV Data

Health Data

Test Data

Consent
Applicant Client Introductions
  • to maintain relationship with Applicant
  • to ensure database is maintained

Contact Data

Position Data

Communications Data

Marketing Data

Consent

Legitimate Interest

Applicant Finance Activities
  • to ensure salary expectations are met
  • to communicate salary/fee arrangements between Business Contact and Candidate

Contact Data

Position Data

Financial Data

Consent

Legitimate Interest

Contract

Applicant IT Activities
  • back-up and storage of Applicant data
  • to make improvements and efficiencies in the recruitment process

Contact Data

Identification Data

Professional Data

Education Data

Communications Data

Marketing Data

Consent

Legitimate Interest

Website Delivery 
  • to respond to web forms completed by Applicants;
  • to administer the Website; 
  • for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to ensure the safety and security of our website and our services.

Contact Data

Web Data

Consent

Legitimate Interest

Marketing activities
  • to respond to any requests from Applicants
  • to send newsletters and other information that maybe of interest
  • to inform you of events or webinars that might be of interest
  • to participate in recruitment conferences, seminars, events 
  • to develop the relationship with Applicants
  • to personalise marketing information
  • to segment and distribute targeted marketing

Marketing Data

Contact Data

Web Data

Consent

Legitimate Interest

 

RETENTION OF APPLICANT PERSONAL DATA

We only keep your Personal Data as long as it is necessary for the purposes of processing it or to comply with legal or regulatory requirements.

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate interests.  We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.

Our retention policy is as follows: 

Purpose of Processing Retention Period 
Applicant Sourcing As agreed with data subject  
Job Applications 1 year
Applicant Interview 18 months
Applicant Placement 7 years
Expense reimbursement 7 years

 

DISCLOSURE OF PERSONAL DATA

Personal Data is shared in certain circumstances as follows:

  • to business partners and sub-contractors for the performance of any contract relating to our recruitment activities including email, chat, ticketing, ATS, hosting service providers 
  • for the purposes of third-party screening and verification, including doctors or testing companies (for example, criminal record checks / pre-employment screening services and assessments)
  • to other companies in the Client Solutions group of companies including the affiliated companies documented in this Data Protection Statement for the purposes of administration.  
  • to any party acquiring an interest in the Client Solutions company 
  • to tax, audit, or other authorities, if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation or in order to enforce or apply any contract that we have 
  • to official authorities to protect our rights, property, or safety, or those of other persons (including you)
  • to providers of services to Client Solutions including IT consultants and hosting companies, marketing, legal and finance 
  • to analytics and search engine providers that assist us in the improvement and optimisation of our Website. This consists of information relating to the web pages visited on the Website and tracking codes from service providers like LinkedIn and Google
  • to Client Solutions’ insurance brokers and providers where required for administering claims 
  • to our email distribution partner and service providers in the case of recruitment newsletters.

 

SECURITY

We will take all steps reasonably necessary to ensure that all Personal Data is treated securely in accordance with this Data Protection Statement and the Data Protection Laws.  In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the Personal Data we process.

We monitor for and do everything we can to prevent security breaches of the Personal Data that we process.  Once we have received your Personal Data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your Personal Data can access it.

We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential.  Please do not share your password with anyone.

If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately. 

TRANSFERS OUTSIDE THE EEA

In certain circumstances your Personal Data may be transferred outside the EEA. We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.

If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission or the Privacy Shield in the case of transfers to the USA. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.

USE OF THIRD-PARTY WEBSITES

Websites that you access via a link on the Client Solutions website or recruitment websites where Client Solutions jobs may be advertised are outside our control and are not covered by this Data Protection Statement. 

If you access other websites using the links provided or apply for a role from an ad on a recruitment website, the operators of these websites may collect Personal Data from you, which will be used by them in accordance with their own Data Protection Statements, which may differ from ours. 

Please check the Data Protection Statements on those websites before you submit any Personal Data to them. 

YOUR RIGHTS

You have various rights relating to how your Personal Data is used. 

Right of access to the Personal Data we hold on you

You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to everything we have recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.

We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.

We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others. 

Right of rectification of Personal Data 

You should let us know if there is something inaccurate in your Personal Data.

We may not always be able to change or remove that Personal Data, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.  

Right of erasure of Personal Data (right to be forgotten)

In some circumstances you can ask for your Personal Data to be deleted, for example, where: 

  • your Personal Data is no longer needed for the reason that it was collected in the first place
  • you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
  • there is no lawful basis for the use of your Personal Data
  • deleting the Personal Data is a legal requirement

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.

Please note that we cannot delete your Personal Data where:

  • we are required to have it by law
  • it is used for freedom of expression 
  • it is used for public health purposes
  • it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
  • it is necessary for legal claims. 

Right to restrict what we use your Personal Data for

You have the right to ask us to restrict what we use your Personal Data for where:

  • you have identified inaccurate Personal Data, and have told us of it
  • where we have no legal reason to use the Personal Data, but you want us to restrict what we use it for rather than erase the Personal Data altogether

When Personal Data is restricted, it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.

Right to have your Personal Data moved to another provider (data portability)

You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

This right only applies if we are using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.

Right to object

You have the right to object to processing of your Personal Data which is based on public interest or legitimate interest processing.  We will no longer process the Personal Data unless we can demonstrate a compelling ground for the processing.

Right not to be subject to automated decision-making

You have the right not to be subject to a decision based solely on automated processing.  This right shall not apply where the processing is necessary for a contract with you, or the processing is undertaken with your explicit consent or the processing is authorised by law.

You can make a complaint

You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place. 

QUESTIONS OR COMPLAINTS

Thank you for reading our Data Protection Statement.  Please Contact Us if you have any questions.  

If we are unable to resolve your concerns, you have the right to contact the supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached :

The Irish Data Protection Commission (DPC) can be contacted at:

Online Form: https://forms.dataprotection.ie/contact

Address 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Tel: +353 578 684 800 or +353 761 104 800

The Agencia Española de Protección de Datos (“AEPD”), 

Address: C/Jorge Juan, 6, 28001 Madrid, Spain

Telephone: +34 901 100 099/ +34 91 266 35 17

Website www.aepd.es

AMENDMENTS TO THIS DATA PROTECTION STATEMENT

We will post any changes to this Data Protection Statement on the Website and on our job ads in recruitment portals and when doing so will change the effective date at the top of this Data Protection Statement.  

In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

Client Solutions HR May 2021