seamlessCARE Recruitment GDPR Policy
Introduction
As part of any recruitment process, seamlessCARE Ltd collects and processes personal information, or personal data, relating to job applicants. This personal information may be held by the seamlessCARE Ltd on paper or in electronic format.
seamlessCARE Ltd is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information during the recruitment process. We are required under the GDPR to notify you of the information contained in this privacy notice.
This privacy notice applies to all job applicants, whether they apply for a role directly or indirectly through an employment agency. It is non-contractual.
seamlessCARE Ltd has appointed a Data Controller to oversee compliance with this privacy notice.
If you have any questions about this privacy notice or about how we handle your personal information, please contact Data Protection Officer: dpo@seamlesscare.ie
seamlessCARE Ltd is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information during the recruitment process. We are required under the GDPR to notify you of the information contained in this privacy notice.
This privacy notice applies to all job applicants, whether they apply for a role directly or indirectly through an employment agency. It is non-contractual.
seamlessCARE Ltd has appointed a Data Controller to oversee compliance with this privacy notice.
If you have any questions about this privacy notice or about how we handle your personal information, please contact Data Protection Officer: dpo@seamlesscare.ie
Data protection principles
Under the GDPR, there are six data protection principles that the Organisation must comply with. These provide that the personal information we hold about you must be:
- Processed lawfully, fairly and in a transparent manner.
- Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to those purposes.
- Accurate and, where necessary, kept up to date.
- Kept in a form which permits your identification for no longer than is necessary for those purposes.
- Processed in a way that ensures appropriate security of the data.
seamlessCARE Ltd is responsible for, and must be able to demonstrate compliance with, these principles. This is called accountability.
Recruitment process description
Red boxes contain sensitive data.
The recruitment process must be shared during three processes: application, offer and welcoming.
- Application process: at this stage you choose to apply to the job proposed and you consent to send us some personal information about you, your studies and your professional path (see in diagram above from step 1 to step 4).
- Offer process: at this stage your application is validated, and an offer may be prepared for you after some last checks, included sensitive data for example to obtain a criminal record check (see in diagram above from step 5 to step 6).
- Welcoming process: at this stage you may become a seamlessCARE employee. Some additional data can be requested and will be used in the company employee processes.
We will only use your personal information when the law allows: this is known as the ‘legal bases for processing’.
Candidate and privacy
Why do we collect your data?
When a candidate applies for a job and sends his or her personal data, they consents to share it. We need some personal data to know you better and identify which candidate will best suit the position. We process your personal information for the following reasons: To
- manage the recruitment process and assess your suitability for employment or engagement
- decide to whom to offer a job
- comply with statutory and/or regulatory requirements and obligations, e.g. checking your right to work in Ireland
- comply with the duty to make reasonable adjustments for disabled job applicants and with other disability discrimination obligations
- ensure compliance with your statutory rights
- ensure effective HR, personnel management and business administration
- monitor equal opportunities
- enable us to establish, exercise or defend possible legal claims
What data do we collect?
During the recruitment and candidate selection processes, seamlessCARE Ltd collects, uses and processes a range of personal information about you. This includes (as applicable):
- your contact details, including your name, address, telephone number and personal e-mail address
- personal information included in a CV, any application form, cover letter or interview notes
- references
- information about your right to work in Ireland and copies of proof of right to work documentation
- copies of qualification certificates
- other background check documentation
- details of your skills, qualifications, experience and work history with previous employers
- information about your current salary level, including benefits and pension entitlements
- your professional memberships
How do we collect your data?
seamlessCARE Ltd collects personal information about you during the recruitment process either directly from you or sometimes from a third party such as an employment agency. We may also collect personal information from other external third parties, such as references from current and former employers, information from background check providers, information from credit reference agencies and criminal record checks. Other than employment agencies, seamlessCARE Ltd will only seek personal information from third parties during the recruitment process once an offer of employment or engagement has been made to you and we will inform you that we are doing so.
You are under no statutory or contractual obligation to provide personal information to seamlessCARE Ltd during the recruitment process.
Your personal information may be stored in different places, including on your application record, in the seamlessCARE Ltd HR management system and in other IT systems, such as the e-mail system.
You are under no statutory or contractual obligation to provide personal information to seamlessCARE Ltd during the recruitment process.
Your personal information may be stored in different places, including on your application record, in the seamlessCARE Ltd HR management system and in other IT systems, such as the e-mail system.
How will we use your data?
Your personal information may be shared internally within seamlessCARE Ltd for the purposes of recruitment. seamlessCARE Ltd will not share your personal information with third parties during the recruitment process.
We do not envisage that any recruitment decisions will be taken about you based solely on automated decision-making, including profiling. Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.
We do not envisage that any recruitment decisions will be taken about you based solely on automated decision-making, including profiling. Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.
How will we use your data?
Your personal information may be shared internally within seamlessCARE Ltd for the purposes of the recruitment exercise.
seamlessCARE Ltd will not share your personal information with third parties during the recruitment process.
We do not envisage that any recruitment decisions will be taken about you based solely on automated decision-making, including profiling. Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.
We do not envisage that any recruitment decisions will be taken about you based solely on automated decision-making, including profiling. Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.
How do we store your data?
seamlessCARE Ltd will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected and processed, in compliance with the law.
We will only use your personal information for the purpose for which it was collected, the job application and recruitment process. If your application for employment or engagement is unsuccessful, seamlessCARE Ltd may wish to keep your personal information on file for in case we have future suitable employment opportunities. We will ask for your consent before we keep your personal information on file for this purpose. Your consent can be withdrawn at any time. With your consent, we will hold your personal information for six months after the end of the relevant recruitment exercise.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable. In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable. In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.
Offer/Hiring and privacy
Why do we collect your data?
As part of the offer process, we will verify that all the data that you gave us is correct and aligned with the internal procedure. In order to protect you and seamlessCARE, some legal and contractual element should be shared for the offer preparation.
What data do we collect?
At this stage, seamlessCARE Ltd will collect, use and process the following special categories of your personal information (as applicable):
- whether or not you have a disability for which seamlessCARE Ltd needs to make reasonable adjustments during the recruitment process
- sensitive personal data, as information about criminal convictions and offences
Where seamlessCARE Ltd processes other sensitive personal information, i.e. information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation, this is done only for the purpose of equal opportunities monitoring in recruitment and in line with our data protection policy. Personal information that seamlessCARE Ltd uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.
How do we collect your data?
We will collect most of the data from you, but we may also collect personal information from other external third parties, such as references from current and former employers, information from background check providers, information from credit reference agencies and criminal record checks.
How will we use your data?
If your job application is successful, seamlessCARE Ltd will prepare the offer and advise you with whom the company may also share your personal information; including third parties (and their designated agents) to prepare the offer and the recruitment, including:
- external organisations for the purposes of conducting pre-employment reference and employment background checks
- to obtain a criminal record check
- former employers, to obtain references
- professional advisors, such as lawyers
- outsourced provider such as payroll and HR
If you fail to provide certain personal information when requested, we may not be able to process your job application properly or at all, we may not be able to enter into a contract with you, or we may be prevented from complying with our legal obligations.
How do we store your data?
If you refuse the offer, the retention period of the candidate process will be applied, so no more 6 months if you give your consent for the storage.
If you accept the offer, you will become employee, so the retention period will be the same that for employee process below. The legal retention period is 6 years in Ireland.
Employee/Welcoming and privacy
Why do we collect your data?
As part of the employee process, we will use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests. Our legitimate interests include pursuing our business by employing employees, workers and contractors; managing the recruitment process; conducting due diligence on prospective staff and performing effective internal administration.
What data do we collect?
We will collect and use your personal information already listed in candidate process part. We also process sensitive personal information about your health and information about any criminal convictions and offences where we have your explicit written consent.
How do we collect your data?
In this case, we will first provide you with full details of the personal information we would like and the reason we need it, so that you can properly consider whether you wish to consent or not. It is entirely your choice whether to consent. Your consent can be withdrawn at any time.
How will we use your data?
The purposes for which we are processing, or will process, health information and information about any criminal convictions and offences at this stage, are to:
- assess your suitability for employment or engagement
- comply with statutory and/or regulatory requirements and obligations, e.g. carrying out criminal record checks
- comply with the duty to make reasonable adjustments for disabled job applicants and with other disability discrimination obligations
- ensure compliance with your statutory rights
- ascertain your fitness to work
- ensure effective HR, personnel management, and business administration
- monitor equal opportunities
We may also occasionally use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise, or defence of legal claims.
How do we store your data?
Your data will be stored in according with legal requirements. This is subject to: (a) any minimum statutory or other legal, tax, health and safety, reporting or accounting requirements for particular data or records, and (b) the retention of some types of personal information for up to six years to protect against legal risk, e.g. if they could be relevant to a possible legal claim in a tribunal, District Court or High Court. If you have consented to the Organisation keeping your personal information on file for in case there are future suitable employment opportunities, seamlessCARE Ltd will hold your personal information for a further six months after the end of the relevant recruitment exercise, or until you withdraw your consent if earlier.
How does the Organisation protect your personal information?
seamlessCARE Ltd has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. You can obtain further information about these measures from our Data Controller.
Where your personal information is shared with third parties, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it as subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
seamlessCARE Ltd also has in place procedures to deal with a suspected data security breach and we will notify the Data Protection Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
Where your personal information is shared with third parties, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it as subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
seamlessCARE Ltd also has in place procedures to deal with a suspected data security breach and we will notify the Data Protection Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
Your rights in connection with your personal information
SeamlessCARE would like to make sure that you are fully aware of all of your data protection rights. Every data subject is entitled to the following:
- The right to access - You have the right to ask SeamlessCARE for copies of your personal data. We may charge you a small fee for this service
- The right to rectification - You have the right to request that SeamlessCARE correct any information you believe is inaccurate. You also have the right to request SeamlessCARE to complete information you believe is incomplete
- The right to erasure - You have the right to request that SeamlessCARE erase your personal data, under certain conditions and always in compliance with legal obligations
- The right to restrict processing - You have the right to request that SeamlessCARE restrict the processing of your personal data, under certain conditions and always in compliance with legal obligations
- The right to object to processing - You have the right to object to SeamlessCARE’s processing of your personal data, under certain conditions and always in compliance with legal obligations
- The right to data portability - You have the right to request that SeamlessCARE transfer the data that we have collected to another organization, or directly to you, under certain conditions and always in compliance with legal obligations
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at:
We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
Transferring personal information outside the European Economic Area
seamlessCARE Ltd will not transfer your personal information to countries outside the European Economic Area.
Changes to this privacy notice
seamlessCARE Ltd reserves the right to update or amend this privacy policy at any time. We will issue you with a new privacy policy when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.
Contact - If you have any questions about this privacy policy or how we handle your personal information, please contact our DPO as follows: dpo@seamlesscare.ie
Contact - If you have any questions about this privacy policy or how we handle your personal information, please contact our DPO as follows: dpo@seamlesscare.ie