This policy outlines how First Place Recruitment Ltd. is processing your personal data.
By accessing and/ or using our service you confirm that you have read, understood and accepted this policy. Please, read it carefully to make sure you are aware of our approach to your personal data and comfortable with it. Please, revisit this page from time to time for the most updated version of this policy.
Candidates – any individual who registers with First Place Recruitment Ltd. for the purposes of obtaining employment.
Clients – private or public sector companies and/ or organisations and/ or institutions that First Place Recruitment Ltd. is providing recruitment services to.
Personal data/ information – any information relating to an identified or identifiable natural person.
Processing - any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Recruitment process – end-to-end recruitment cycle, which includes, e.g. initial contact, agency interviews, client interviews, placement and after-placement support.
Recruitment services/ solutions – all the services that First Place Recruitment Ltd. offers to candidates and clients with regards to recruitment and staffing, and all the activities necessary to provide such services.
Meaningful contact – any communication verbal or written including, e.g. new job application sent directly or through job bards, profile update, etc.
First Place Recruitment Ltd. is Data Controller for the purposes of the General Data Protection Regulation (EU) 2016/679 (GDPR) and any other related legislation.
We understand and accept our obligation to process your personal data fairly, lawfully and in secure manner, and we are committed to protecting your privacy and will only use your data in accordance with this policy.
Should we collect any information about you, we will only do so in good faith, from reliable sources and exclusively for the purpose of providing the recruitment services to our candidates and clients.
We may collect the information about you from:
- You directly – if you send us job application or contact us via email, website, phone, etc.;
- Job boards and social media – where we advertise and source candidates’ profiles;
- Our business partners – should we use third parties to perform tests and/ or references and/ or background checks, applicable for the particular recruitment process;
- Our clients – if you interviewed with them and/ or was hired by them;
- Publicly available sources – such as your LinkedIn profile, social media profiles;
Regardless of the source, should we register your profile on our database, you will receive an email confirming us having done so. Should you not wish us to retain your data or should you want to limit the data that we keep about you, you may manage the processing of your data at any time (please, see the details below about your rights with regards to your personal data).
As a rule, at any stage of your engagement with us we will only collect the minimum of personal data necessary to provide the recruitment services in an effective and timely manner.
The personal data that we collect may include:
- Contact information (home address, phone numbers, email addresses, Skype name, etc.);
- CV (incl. education and professional history);
- Confirmation of the eligibility to work in the countries of interest (incl. your nationality/ citizenship, Visa/ work permit details, etc.);
- Registration and application forms;
- Relevant tests that are a part of recruitment process (e.g. language-, skills-, competency- related);
- Referees details;
- Necessary hiring information (incl. proof of identity such as National ID or passport, date of birth, bank account number);
- Social security number/ Tax number or similar (depending on the country of employment) and other tax related information where necessary;
- Details of criminal convictions, if necessary for the position;
- Information necessary to perform background checks where applicable;
- Other information shared by clients, referees or you (e.g. interview feedback, information regarding your employment);
- Any correspondence, both electronic and paper;
- Information that is publicly available, e.g. on your LinkedIn or social media profiles.
The above list of categories of personal data is non-exhaustive and we may seek to obtain additional personal data, always with your explicit consent.
Please, be aware that should we collect any data about you, this is solely for the purpose of facilitating the recruitment services. If you refuse to provide your personal details, we may not be able to provide you with our services.
Our business, as Multilingual Recruitment Agency, is based on providing recruitment solutions to candidates and clients, and this is the sole reason why we collect and process any personal data.
Within our business activities we may use your data to:
- Facilitate the recruitment process, e.g. match your profile with suitable job opportunities, manage recruitment process, provide employment support where applicable, etc.
- Keep you informed – we may also send you emails with information about the services and opportunities that we believe may be of use to you.
- Improve our services – we may send you a market research email from time to time, requesting, e.g. your feedback on our services.
Please, be aware that you may opt out from receiving such emails at any time.
In addition to the business purposes, we may process your personal data in the following situations, as required by current legislation:
- Where we are obliged to do so by law, in the public interest and/or by official authority;
- Where we need to fulfil the contract that we entered in with you;
- Where we are obliged to protect your interests or those of another person.
Please note that the above list is non-exhaustive, and we may need to process your details for another purpose that we are currently unable to anticipate. Should this be the case, we shall inform you of this prior to processing and seek for your consent.
Special category data is personal data which is particularly sensitive and requires stronger protection, e.g. information regarding racial or ethnical background, political, religious, philosophical views, health, sexual life, genetic and biometric data.
Should this be necessary for us to collect such data about you in order to provide you with our services, we shall only process it in one or more of the following circumstances:
- With your written consent for particular and limited use of such data.
- To assess your suitability for employment or facilitate the recruitment process, e.g. ethnical background data which sometimes is inseparably connected to the language skills required, health information related to the requirements of the position, etc.
- In any legal proceedings and to comply with any legal responsibilities that we are bound by.
- To protect your interests or those of another person (if you are unable to give your consent).
- If required by public interest.
- If those special categories data have already been publicly disclosed by you.
In order to deliver the recruitment services, we may need to share your information internally and with some third parties, including but not limited to:
- Employees of First Place Recruitment Ltd.: Your information will be shared among our recruitment, marketing, administrative and management teams in order to provide you with recruitment services and to process your details properly. All our employees are bound by very strict data security procedures and confidentiality agreements.
- Clients: In order to support your job application for the vacancies that we have available, we will disclose your information to our clients (prospective employers). Please note that for each application made on your behalf we will look for your consent. Moreover, should you be employed by our client(s) we will continue sharing your information with them, as required and necessary to continue providing recruitment services to them and to you.
- Trusted contractors who we may outsource some services to, e.g. CRM services, external skills and competency testing, references and background checks (depending on the requirements for particular position), accountants, IT specialists, lawyers, etc. Please note that we will take all the reasonable steps to ensure that the third parties that your information will be shared with are GDPR-compliant and provide suitable security guarantees when processing your data on our behalf.
- Any statutory or regulatory bodies that we are legally required to share the information with: This includes, e.g. sharing your data for tax purposes and disclosing your information if we are under any legal obligation to do so.
We do not share your personal data with any third parties for the purpose of selling or marketing to you.
There is a number of means we use to ensure the security of your information. These include: physical means (our premises security systems), technical means (security software and servers), as well as our internal security procedures.
We recognise however that - despite our best efforts - no data transmission via Internet can be guaranteed 100% secure. The possibility exists of unlawful access of a third party to your data transmitted to our site and/ or stored on our systems.
We will only retain your personal data for as long as necessary to be able to provide our services, as well as comply with any statutory and legal requirements that we are required to obey.
As a general rule, if we have not had meaningful contact with you for a period of two years, we will delete your personal data from our systems.
However, we may need to keep some of your personal data for longer periods either due to business needs (e.g. to keep track of the services provided to candidates and clients, applications made, etc.), or as per legal and/ or other statutory requirements that we are obliged to obey (e.g. for tax purposes). Should this be the case, we will only retain the parts of your information that are absolutely necessary for those purposes and strictly for the required periods.
- Right to rectification: You have the right to ask us for modifications of your personal data if you believe that the data that we process is not up to date or otherwise inaccurate.
- Right to withdraw consent: Should we be seeking for your consent for processing some of your personal data (e.g. the special categories of data, as outlined above), you have the right to withdraw that consent at any time. We will then immediately cease processing of this data, unless we believe in good faith that there is a reason for us to continue processing your data, in which case we will inform you about such circumstances.
- Right to object: You have the right to object to the processing of your data on the grounds of legitimate interest (based on your personal circumstances), public interest or for direct marketing purposes.
- Right to erasure: You have the right to request us to delete your personal data, should any of the following circumstances occur: 1) the purpose for which your data was obtained is not applicable anymore, or 2) you have withdrawn your consent (if the processing of your data was based on consent), or 3) you have successfully objected to processing your data by us, or 4) the erasure of your data is required by law, or 5) your personal data was processed unlawfully. However, we may need to continue processing your personal data (or a part of it) if we are under legal and/ or statutory obligation to do so, in which case we will inform you about such circumstances. Please, be aware that should we completely erase your personal data and forget you on our systems, it is possible that we re-obtain your data in the future from any of the sources described previously where you share your personal data (e.g. your profile on job boards or in social media); this may result in the contact from our side.
- Right to restrict processing: In the situations when: 1) you contest the accuracy of your personal data that we are processing or the grounds for processing, or 2) when the processing is suspected to be unlawful, or 3) your personal data need to be retained beyond the retention period due to an on-going legal claim; the processing of your data will be restricted, i.e. we will keep the data, but will not be using it beyond the scope of the above circumstances.
- Right to data portability: In the instances where the processing of your data is based on consent, contract or is carried out by automated means, you have the right to request a copy of the data that you provided us with and we are obliged to issue it in the commonly-used data format.
- Right not to be subject to automated individual-decision making: You have the right not to be subject to a decision based solely on automated processing, which results in legal or other significant consequences to you. Please, be aware that First Place Recruitment Ltd. do not use automated profiling nor automated decision-making tools and processes.
Should you wish to exercise any of your rights regarding the processing of your personal data, or if you have any questions with regards to our privacy policies or any other data protection related inquiry, please do not hesitate to contact us:
First Place Recruitment Ltd.
1 New Row, Naas, Co. Kildare, Ireland.
Phone: +353 (0) 45 89 73 29
For the purpose of GDPR, Alicja Rynda, Managing Director, is acting Data Protection Officer.
We will generally respond to your inquiry within one month from the date of receipt thereof. In case of more complex requests or high volume of requests, this period may be extended to two months.
We shall deal with your inquiries free of charge, although repetitive and/ or manifestly unfounded or excessive requests may be refused, or an administrative fee may be applied to processing them.
Should you be unsatisfied with the outcome of your contact with us, you can raise your concerns with the office of Data Protection Commissioner:
Data Protection Commissioner
Portarlinton, Co. Laois.
LoCall: 1890 252231
Phone: 057 868 4800
Fax: 057 868 47 57
This policy is effective as of 18th April 2018.
First Place Recruitment Ltd. may change this policy if necessary and such modifications will be immediately updated on this page.