GDPR privacy notice – Corporate Access Limited

PRIVACY NOTICE

This Privacy Notice (this Notice) is intended to ensure that you are aware of what personal data Corporate Access Limited (we, us, our) with registered addresses at 3^rd Floor, Block 6, Cleaboy Business Park, Waterford and Suite 241, The Capel Building, Mary’s Abbey, Dublin 7 holds in relation to you, and how we use that data as data controller.

Please read the following carefully to understand our use of your personal data.

Scope

This Notice applies to you, whether you are a current (or former) employee, partner, worker, intern, agency worker, consultant, individual contractor or director. It also applies to third parties whose information you provide to us in connection with our relationship with you (for example, in respect of emergency contact information). Please ensure that you provide a copy of this Notice to any third parties whose personal data you provide to us.

Where we refer to ’employee personal data’ or ‘employment’ in this Notice, we do so for convenience only, and this should in no way be interpreted as purporting to confer employment status on non-employees to whom this notice also applies. This Notice does not form part of any contract of employment and does not confer any contractual right on you or place any contractual obligation on us.

It applies to all personal data collected, maintained, transmitted, stored, retained, or otherwise used (i.e. processed) by us regardless of the media on which that personal data is stored. We may update this Notice at any time and will notify you in writing of any changes.

What is Personal Data?

‘Personal Data’ is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information. We hold some or all of the types of personal data set out in Appendix 1, in relation to you.

Purpose and Basis for Processing 

We will hold, process and may disclose personal data provided by you for the following purposes:

Special Categories of Personal Data

Certain categories of your personal data are regarded as ‘special’ including information relating to an individual’s:

• Physical or mental health
• Religious, philosophical or political beliefs
• Trade union membership
• Ethnic or racial origin
• Biometric or genetic data and
• Sexual orientation

We only process such data where necessary for the purpose of carrying out the obligations, and exercising specific rights, of Corporate Access Limited or of an employee under employment law or for the assessment of your working capacity. See Appendix 1. 

We will only process data relating to your criminal convictions or involvement in criminal proceedings when permitted by law, or where provided voluntarily by you.

Consent

In principle, we do not rely on your consent for data use. We may, however, from time to time, (i) ask for your consent to use your personal data for a specific purpose; and/or (ii) process your personal data (including “special data”) in order to protect your vital interests or the interests of another. If we do so, we will provide you with full details of the data that we would like and the reason we need it. We will also inform you about the fact that you can revoke your consent at any time and how you should do that. You should be aware that withholding your consent will never have an impact on your employment with us or otherwise negatively affect you.

Where you do not provide us with your Personal Data

If you do not provide us with your personal data we may not be able to process your job application, suitability for a particular role, your pay or other benefits, comply with our legal obligations or manage our business. We will tell you when we ask for information which is a statutory or contractual requirement or needed to comply with our legal obligations.

Security and Storage of Personal Data

We securely store your personal data in a centralised database, with controlled access to such database. Access to personal data (including special data) in both electronic and paper form is restricted to members of Management and employees who have a legitimate and justifiable reason to view such data.

Recipients of Your Personal Data

We may disclose your personal data to a Group Company including, without limitation, for the following reasons: in order to run inter- company processes, carry out group wide reporting, or take decisions about hiring or promotion.

It may be necessary from time to time for us to disclose personal data to third parties or agents, including without limitation to the following: 

• Third parties to assist in the administration, processing and management of certain activities pertaining to past, current and prospective employees
• Individuals or companies employed by Corporate Access Limited to carry out specific services, functions or consultancy work including external reference agencies and other financial institutions
• Relatives or legal representatives of past, current and prospective employees
• Regulatory bodies to whom we are obliged or required to disclose information including Workplace Relations Commission, Courts and Court-appointed persons
• Insurance or assurance companies and health insurance providers or trade union
• Legal and medical practitioners
• Pension providers
• Potential purchasers or bidders
• Relevant Government departments and agencies and
• Other support service providers necessary to assist Corporate Access Limited with the above

We will inform you in advance if we intend to further process or disclose your personal data for a purpose other than the purposes set out above. We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied.

Transfer of Personal Data outside the EEA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA), for the purposes described above. It may also be processed by personnel operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure suitable safeguards are in place to protect the privacy and integrity of your personal data in such circumstances. You can obtain information and a copy of documentation pertaining to these safeguards from Management, where applicable.

Data Retention

Data will be stored for as long as required to satisfy the purpose for which the data was collected and used, unless a longer period is necessary for our legal obligations or for the exercise or defence of legal claims. Usually, we retain your data for the duration of your employment with us.

Statutory retention periods apply to certain records (for example, per legislation, employers are obliged to keep records of their employees’ working time for a period of three years). As statutory retention periods can vary depending on the type of data, please refer to our data retention policy which is available at the site office to find out more. Our retention practices are reviewed and updated from time to time in line with legal requirements and best practice. Further information can be obtained from Management.

Your Data Rights

You have several rights in relation to your personal data. You have a right to

• access a copy of your personal data held by Corporate Access Limited
• request rectification of your personal data if it is inaccurate or incomplete
• request erasure of your personal data in certain circumstances
• restrict our use of your personal data in certain circumstances
• move (or port) personal data which is automated in certain circumstances
• object to the processing of your data where our legal basis for processing your data is our legitimate interests
• not to be subject to a decision based on automated processing, including profiling which has legal or similar significant affects
• withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal and
• lodge a complaint with the Office of the Data Protection Commissioner (if you are unhappy with how your personal data is being handled)

However, these rights may not be exercised in certain circumstances, such as when the processing of your data is necessary to comply with a legal obligation or for the exercise or defence of legal claims. If you wish to exercise any of your rights in this regard please contact Management. We will respond to your request as soon as practicable. We may request proof of identification to verify your request.

Further Information

If you require any further clarification regarding this Notice, please contact the General Manager.

Appendix 1

General Personal Data

• Personal – contact/identifying details including name, address, email address, date of birth, photograph, civil status, gender, nationality, domestic partners, dependents
• Emergency contact – name and contact details of emergency contacts (as set out above, you must provide a copy of this Notice to any third parties whose personal data you provide to us)
• Professional – Curriculum Vitae and/or application form, previous employment background, references from previous employers, record of interview/interview notes, selection and verification records, educational details, professional and/or academic transcripts, professional certifications, special skills including (driver) licenses, language skills, memberships of committees or other bodies
• Financial – salary and benefit details including bank details, PPS number, tax information
• Employment – work contact details (email address and telephone number), identification number, photograph, details regarding the job function, primary work location, working hours, employment status, your terms and conditions of employment or engagement, contract of employment, signed confidentiality agreement, immigration status, work permit details, job description, history and details of current position
• Premises and IT access – information required to access company systems and applications such as email account and system passwords, login and access records, download and print records, call recordings, records of email and internet usage in accordance with our email and internet policy, CCTV images captured through the legitimate use of CCTV within Corporate Access Limited
• Fees, remuneration and benefits – fees/payment and benefits package, base salary, bonus, compensation type, pension scheme, health insurance scheme (and any third party beneficiaries), company credit card data, salary reviews
• Leave – including documentation which may be provided in connection with any statutory leave, sick leave, holiday and family related leave records, garden leave, and any other type of leave such as unpaid leave 
• Performance management – performance assessments/meetings (including probationary assessments), colleague and manager feedback, appraisals and formal and informal performance management processes
• Training and development – such as data relating to training and development needs or training received
• Disciplinary – such as any personal data contained in records of allegations, investigation and proceeding records and outcomes
• General correspondence/meetings – relating to grievance and/or disciplinary processes, misconduct or performance issues, data arising in connection with litigation and complaints, involvement in incident reporting and disclosures
• Termination – for example, dates and reason for leaving, termination agreements and payments, exit interviews and references
• Incapacity – any accommodations or adjustments in connection with any incapacity

Special Categories of Personal Data

• Physical or mental health data – such as information about your physical or mental health or condition; for example, we record your days of sickness, or workplace adjustments due to health reasons.
• Other special categories of personal data – such as racial or ethnic origin; religious or similar beliefs; membership of a trade union; the commission or alleged commission of any offence; and any proceedings for any offence committed or alleged to have been committed, the disposal of those proceedings or the sentence of any court in those proceedings.

Special categories of personal data will only be collected and used in so far as such is necessary for the purposes of carrying out an obligation in the field of employment/social security/social protection law or exercising specific rights or when the use is authorised by law or for the assessment of working capacity.

Acknowledgment of Receipt of Privacy Protection Notice

I acknowledge that I have received a copy of the Corporate Access Limited Privacy Notice.

I acknowledge that the Corporate Access Limited Privacy Notice is not a contract, express or implied and that it does not set terms or conditions of employment.

I understand that the Corporate Access Limited Privacy Notice may be updated at any time and that

Corporate Access Limited will notify me in writing of any such changes.