The purpose of this policy is to set out the privacy entitlements of Data Subjects, as defined in the General Data Protection Regulation (GDPR), of 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:
The individuals with whom we have contact at our client, prospective client and supplier businesses Our own employees – our own employee data processing information is set out in their employee handbook Legal basis for processing any personal data We rely upon the following legal bases for data collection:
Contract
Candidates: Information is required in order to perform the contract of “Employment agent” on behalf of our candidates with potential employers. The basis of data gathering in that instance is a contractual requirement. This will include identification information such as but not limited to name, address, date of birth, information regarding education/qualifications and reference checks.
Clients/Suppliers: We will process data pursuant to business to business transactions, but where so required, we will rely on the lawful basis as necessary for the performance of the contract for the processing of personal data within this relationship.
Statutory/Legal Obligation: Information is required in order to perform our statutory obligations such as tax returns and compliance with employment permit legislation. This information will include PPS numbers and, where relevant, evidence of entitlement to work.
Legitimate Interest: Clients: We will utilise personal data in the form of email addresses and contact telephone numbers in order to keep our clients and potential clients informed in relation to the careers and market related information. We consider that this is in the legitimate interest of our business to maintain our market presence.
Candidates: Information is processed in the legitimate interests of the business of the employment agency, and where so processed it will be in accordance with and subject to your data subject rights and entitlements. We process your data when it is in the legitimate interests of our company to do so and we do this balancing your data protection rights. We consider that our legitimate interest is that you have registered with us because you are interested in gaining access to the information we provide in relation to salary surveys, marketplace analysis, regulatory changes etc., and/or information in relation to the career opportunities with our clients and prospective clients.
In balancing your data protection rights against this legitimate interest of our company, we have considered:
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; 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
Consent: On occasion we may rely on consent in the collection and processing of some data. Given the nature of the relationship of agent to Candidate and agent to Client we consider that consent is not an appropriate ground on which to rely and therefore it will only be utilised in rare occasions.
Personal Data
This Privacy Statement sets out how Brennan Recruitment and Staffing Ltd uses and processes any information that you give 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 and sets out our security practices.
Candidates
We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual. This PII may include your:
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 company. 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 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 our company acting as an agent for you in your pursuit of an employment position with a third party until you either opt out (which you can do at any stage). Our company in their 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 to be sensitive data that is required for legal compliance purposes, such as for security or HIQA audit purposes, we will inform you fully if and when this circumstance arises.
We collect personal data about you from the application forms and questionnaires 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 can be used to identify visitors to our website and also to collect statistics about the behaviour of visitors to our website.
Clients/Suppliers
We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual. We collect PII about Client and Supplier contacts from a number of sources, as follows:
Candidates
Brennan Recruitment and Staffing Ltd collects and uses all PII that you volunteer to deliver the job-seeking or related services you have requested. Your information will only be used for matching your skills with potential job opportunities and will be only disclosed to prospective employers at your expressed direction. By providing your PII, and where you have agreed to receiving communications from us, we may use the information:
Clients/Suppliers
Brennan Recruitment and Staffing Ltd collects and uses all PII in accordance with the provision and furtherance of our recruitment business. Your information will only be used to contact you in the following circumstances:
On occasion, Brennan Recruitment and Staffing Ltd may include links to third parties on this website. Where we provide a link, it does not mean that we endorse or approve that site’s policy towards visitor privacy.
You should review their privacy policy before sending them any personal data.
Our website uses cookies to distinguish you from other users of our website. Cookies provide information regarding the computer used by a visitor.
We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website.
We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.
Data Retention
We will process personal data during the duration of any contract and will continue to store only the personal data needed for periods after the contract has expired to meet any legal obligations as set out in the table below. After these periods any personal data not needed will be deleted.
Source of Obligation
Revenue Commissioners, Collector General, Companies Acts legislative provisions
Retention Period
6 years rolling retention of records
Personal Injuries related records
Records are retained for a period of 3 years past the date of the cause of action, unless it involves a minor, in which case the retention period will be up until 3 years after the minor reaches the age of 18.
Breach of Contract related records
Records are retained 6 years from the date of the breach.
Employment Agency Candidate for Interviews/Placements Records
Candidates who are unsuccessful at the screening or interview stage and who may hold a different skill set than that required by our clients, will have their data held for a period of 1 year past the initial contact with the agency by the candidate, unless the candidate exercises their entitlement to a termination of processing.
Candidates who have been successful at the screening stage may have their data retained indefinitely or until such time as they request to be removed from our database. This is for the purposes of upholding contractual and statutory obligations.
Employment contract/terms of employment related information Duration of the employment – this includes everything from the application form, interview notes, contract related, performance appraisals, references.
Parental Leave Related
8 years – records kept show the dates when a qualifying employee availed of the parental leave and force majeure leave provisions.
Employment Equality
All records, including interviews and applications are kept for a period of one year.
Health and Safety Records
All records relating to health and safety will be kept for a period of 10 years.
Data Law Compliance
Records in relation to our compliance with Data Law and GDPR will be kept for a five-year period.
ACCESS TO INFORMATION AND UPDATING, VERIFYING, DELETING AND RETENTION OF PERSONAL DATA
Subject to other applicable legal requirements, this retention period is based on our experience that, having engaged with us on employment options, individuals are open to considering new opportunities within that timeframe. Each individual has the right to withdraw their consent and have their personal information erased at any time.
Your Rights
Right of access – you have the right to request a copy of the information that we hold about you in accordance with Section 86 of the Data Protection Act 2018; this is not an absolute right and is subject to the privacy rights and entitlements of others also;
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete in accordance with Section 87 and Section 89 of the Data Protection Act 2018
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 have been your employer we can only do so after the statutory period of record retention has expired. In the event that we are obliged to refuse your request in accordance with your data subject rights, or if we are obliged to place conditions on our agreement to your request, we will provide you with a reason as to why, which you have the right to legally challenge.
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.
We will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID 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 of the above requests can be directed, in writing, to Brennan Recruitment, Baggot Hall, 41 Lower Baggot Street, Dublin 2.
They will be forwarded on should there be a third party involved in the processing of your personal data.
In the event that you wish to make a compliant about how your personal data is being processed by us or by our partners, you have the right to complain to martin@brennanrecruitment.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
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. If you do not agree to these changes, please do not continue to use this Website to submit personal information.
Contact Information
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