Who we are

Hartley People Ltd. (‘we’ or ‘us’ or ‘our’) refers to Hartley People Recruitment and Training, Clannad Care, HP Konnect and Selectica HR Ltd. We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant General Data Protection Regulations (GDPR) and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

This privacy policy applies to the personal data of our Candidates, Clients, Suppliers, Website users and other people we may contact in order to find out more about candidates or whom they nominate as an emergency contact where appropriate. It also applies to the emergency contacts of our staff.

We reserve the right to amend our privacy policy at any time.

If you have any queries regarding the personal information we hold or how we store and process it, please contact our designated Data Protection Officer:

Fiona Hartley

29 Manor Street

Waterford

T: 051 878 813

Information that we collect

Hartley People Ltd. processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

Candidates

The personal data that we collect from you may include: –

• Name
• Age / date of birth
• Contact details – email, telephone number and address
• Sex / gender
• A copy of your CV / employment history
• Education details / qualifications
• Photograph
• Interview notes
• Right to work documents
• Referee and reference details
• Details of driving license / passport / identity card
• Details of any criminal convictions
• Emergency contact details
• Professional memberships
• Salary and additional benefits information
• Placement details
• Positions you have previously applied for
• Results from any interview related assessments
• Information on interests and needs regarding future employment, from both written and verbal communication
• Extra information that candidates choose to furnish
• Additional information from referees provided by you
• The dates, times and frequency with which candidates use our services e.g. CV submittal, email exchanges and verbal communication

We may be required to process extra information for candidates who are employed by us on a temporary basis as agency workers, this could include:

• Bank details
• PPS number
• Tax details
• Sick leave details
• Disciplinary and grievance information
• Performance details

We collect information in the below ways: –

• Personal data that Candidates give to us directly; and
• Personal data that we receive from other sources e.g. referees.

You can share your details with us in a number of ways including:

• Entering your details on the Hartley People Ltd. website or through an application form, as part of the registration process;
• Leaving a hard copy CV at a recruitment event, job fair or our office;
• Emailing your CV to Hartley People Ltd. or being interviewed by a staff member of Hartley People Ltd.;
• Applying for jobs through a jobs board website, which then redirects you to Hartley People Ltd.;
• Communicating with us through a social media channel such as LinkedIn;
• Where you contact us proactively, usually by phone, email, fax or post; and
• Where we contact you, either by phone, email, fax or post.

We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:

• Your referees may disclose personal information about you; and
• We may obtain information about you from searching for potential Candidates from third party sources, such as LinkedIn and other job sites.

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

Clients

We need to collect and use information about clients, or individuals at an organisation, in the course of providing our services.

Suppliers

We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide.

Referees and emergency contacts

In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.

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, and the times that our website is most popular.

How we use your personal data

Hartley People Ltd. takes your privacy very seriously and will never disclose or share your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.  The purposes and reasons for processing your personal data are detailed below: –

• To deliver the recruitment services you have requested. Your information will only be used for the purpose of matching your profile with potential job opportunities and will only be disclosed to prospective employers with your expressed consent;
• To provide you with information that you request from us relating to our products or services;
• To carry out any obligations which arise from any contracts entered into between yourselves and us to allow us to provide information or services;
• To provide you with information relating to other products or services which may be of interest to you (only with your expressed consent);
• To inform you of any changes to our products, services and website;
• We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers;
• We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them; and
• We use the personal details of a Candidates or Staff member’s emergency contacts in the case of an accident or emergency affecting that Candidate or member of Staff.

Sharing and disclosing your personal information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.

Primarily we will share your information with your explicit consent to prospective employers. We will only make your personal information visible to companies we are working with when you are put forward for an opportunity or where required for the fulfilment and ongoing management of a contract where we have placed or hired you.

Safeguarding measures

Hartley People Ltd. takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We have established security controls in place to prevent, detect and respond to vulnerabilities and data breaches. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

• A protective monitoring regime to oversee how ICT systems are used;
• Locks and security systems;
• Computer passwords and limited access to shared network drives to authorised staff;
• Virus checking;
• Timely patching applied against known vulnerabilities;
• Systems protected from malicious and mobile code;
• Boundary protection in place on all systems with a connection to an untrusted network;
• Network security boundaries defined and enforced to group users, services and information that require different levels of protection
• Software and hardware locked down to restrict unnecessary services;
• Auditing procedures and data integrity checks; and
• Security classification to identify data needing special protection.

The security of our ICT systems has been evaluated through external penetration testing. We employ an IT Support and Security Company to ensure our Servers, Desktops and Electronic Correspondence are fully secure and maintained to the highest standards. Our systems software and virus protection is regularly updated in line with current updates and threats.

Transfers outside the EU

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data.

In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:-

• between and within Hartley People Ltd entities;
• to overseas Clients;
• to Clients within your country who may, in turn, transfer your data internationally for the purposes of recruitment; and
• to a cloud-based storage provider.

Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by Hartley People Ltd. to protect your data and comply with the relevant data protection laws.

Consequences of not providing your data

You are not obligated to provide your personal information to Hartley People Ltd., however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it.

Consent

Hartley People Ltd. takes your privacy seriously and will only process your personal data with your consent and in accordance with the terms stated in our Privacy Notice.

Legitimate interests

We process your personal information under the legitimate interests’ legal basis. We have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests, ensuring that they are proportionate and appropriate.

We use the legitimate interests’ legal basis for processing data and have identified that our interests are:

Candidate data

If you are looking for employment and are already working with us, we think that it is reasonable to expect that you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers with your consent and assess your skills against open roles. Your prospective employer may also want to double check any information you have given to us or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws.

• We want to provide you with tailored job recommendations and relevant articles to read to help you on your job search. We therefore think it’s reasonable for us to process your data to make sure that we sent you the most appropriate content
• We need to do these things so that we can function effectively as a business, provide the best possible employment opportunities to candidates and facilitate our payroll and invoicing processes.

Client data

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

Supplier data

We use and store the personal data of individuals within a supplier organisation in order to facilitate the receipt of services. We also hold supplier financial details, so that we can pay for services provided. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of supplier services.

Referees and emergency contacts

If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

How long we keep your data

Hartley People Ltd. only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.

We will keep your details on file for a period of 5 years before seeking confirmation that you are happy for us to continue to hold your data. After which time your data will be deleted from our systems unless we have had meaningful contact to say otherwise or if a law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).

Meaningful contact refers to communication between us (either verbal or written). We will consider there to be meaningful contact with you if you submit your updated CV through our website. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or responding to any of our marketing communications.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Cookie notice

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org

Your rights

You have the right to access any personal information that Hartley People Ltd. processes about you and to request information about: –

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request the deletion of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us; to exercise your data portability rights, and to be informed about any automated decision-making we may use.

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us.

We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Lodging a complaint

Hartley People Ltd. only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

Fiona Hartley

Hartley People Ltd.

29 Manor Street

Waterford

T: 051 878 813

Under Article 77 of the GDPR, you have the right to lodge a complaint with the Data Protection Commission if you consider that processing of your personal data is contrary to the GDPR. Under Article 78 of the GDPR, you have a right to an effective judicial remedy where the Data Protection Commission does not handle your complaint, or does not inform you within three months on the progress or outcome of your complaint. Under Article 80, you may authorise certain third parties to make a complaint on your behalf. Complaints to the Data Protection Commission should be made in writing and addressed to:

info@dataprotection.ie

or

The Data Protection Commissioner,

Canal House

Station Road

Portarlington

Co. Laois

The Data Protection Commissioner also operates a helpdesk function, which is contactable at

0761 104 800 or LoCall 1890 252231.