FLAGSHIP MANAGEMENT DATA PRIVACY POLICY
A) INTRODUCTION
In the course of our recruitment services, Flagship Management will have to collect and use information about its clients and candidates. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).
This policy applies to the processing of personal data in manual and electronic records kept by us in connection with recruitment activities as described below. It also covers our response to any data breach and other rights under the GDPR.
This policy applies to the personal data of job applicants, candidates, clients and suppliers.
B) DEFINITIONS
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Data processing” is 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.
C) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
D) TYPES OF DATA HELD
We keep several categories of personal data in order to carry out effective and efficient processes. We keep this data in a centralised computer database to which only Flagship employees have access.
Specifically, we may hold the following types of data:
Candidates:
Clients:
We will collect data that will help us ensure that the relationship between our organisations runs as smoothly as possible. This will normally be restricted to name, telephone number and email address of individual contacts plus relevant company information.
All of the above information is required for our data processing activities.
E) CANDIDATE/CLIENT RIGHTS
You have the following rights in relation to the personal data we hold on you:
F) LAWFUL BASES OF PROCESSING
Legitimate Interest:
We believe that we have a legitimate interest in processing your data for the purpose of providing recruitment services to both our clients and candidates.
Candidates:
Clients:
To ensure that we can provide you and your organisation with the best possible service, we store details of the company and its contacts including notes of conversations, emails, meetings and previous jobs and recruitment activity. We believe that this falls within our legitimate interest in providing efficient recruitment services to you.
Consent:
In certain cases, such as processing sensitive data, we will need to obtain your consent. In this instance:
Establishing, exercising or defending legal claims:
Occasionally we may need to process your data when it is necessary for the establishment, exercising or defending of legal claims or whenever the courts are acting in their judicial capacity.
G) ACCESS TO DATA
As stated above, candidates have a right to access the personal data that we hold on them. To exercise this right, candidates should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.
Further information on making a subject access request is contained in our Subject Access Request note below.
H) DATA COLLECTION
How we collect your personal data:
Candidates:
Clients:
I) DATA USE
Candidates:
Recruitment Activities:
We provide recruitment services to candidates. We want to connect you to relevant opportunities as they arise. We may use your data in the following ways if we deem it necessary to do so for our legitimate interest. The ways in which we might use and process your data is as follows.
Marketing Activities:
Where you have previously contacted us (such as registering on our website, submitting a CV, applying for a job) we may send you details of recruitment-related services that may be beneficial in your job search, particularly where we inform you of vacancies similar to the one you specifically applied for. We may also ask you to participate in salary surveys and job-related questionnaires to provide us with benchmarking data to better advise in your job search. For other marketing purposes we will seek your consent.
If you do not wish to receive any marketing communications from us, you can withdraw your consent by unsubscribing at any time.
Sensitive Personal Data:
We may need to collect sensitive personal data such as medical information and criminal convictions if required for a specific role. We will only do this with your explicit consent. You may withdraw your consent at any time.
To help establish, exercise or defend a legal claim:
Occasionally we may need to use your data to establish, exercise or defend a legal claim.
Clients:
Recruitment Services:
Our primary function is to provide your company with efficient recruitment services including presenting you with candidates, providing market intelligence such as salary surveys, and the provision of recruitment process outsourcing services. To enable us to provide these services we will process your data in the following ways:
Marketing Activities:
As a matter of course we shall not seek your consent when sending marketing materials such as our salary surveys to corporate email addresses. If you wish to opt out of receiving marketing information you can unsubscribe from receiving them at any time.
To help establish, exercise or defend a legal claim:
Occasionally we may need to use your data to establish, exercise or defend a legal claim.
J) DATA DISCLOSURE
We share your data with a variety of third parties during the course of conducting our business. They are as follows:
Candidates:
Clients:
K) DATA SECURITY
We take all reasonable steps to ensure that your data is safe and protected from misuse, loss or unauthorised access. We ensure this by implementing a range of technical safeguards and operational processes. We also have processes to deal with any suspected data breach.
If you suspect that your data has been misused, or has been compromised please contact us immediately at emeajobs@flagshipmgt.com.
L) THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain Flagship Management’s commitment to protecting data.
M) INTERNATIONAL DATA TRANSFER
As an international business, Flagship Management may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place to provide the relevant job application information to overseas companies. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises of the EU member states plus Norway, Iceland and Liechtenstein.
N) RETENTION POLICY
In order to provide you with the best job seeking opportunities, we will retain your data in our secure database until such a time you require us to delete it. In certain cases we are required to hold your data to comply with tax, legal or regulatory issues. Should you wish to be removed from our database at any time, please follow the steps set out below in OPT-OUT PROCEDURES.
O) GDPR RIGHTS
Please be aware that you have the following data protection rights:
Where you have consented to us processing your personal data and sensitive personal data you have the right to withdraw that consent at any time. (Please refer to OPT-OUT PROCEDURE below)
P) REQUIREMENT TO NOTIFY BREACHES
Where legally required, we will report a breach to the Data Protection Commission within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
Q) SUBJECT ACCESS REQUEST
At any time, you are entitled to request to see the data that we hold on you. This request should be sent via an email containing your name, email address and contact number with SUBJECT ACCESS REQUEST as the subject heading to emeajobs@flagshipmgt.com.
R) OPT-OUT PROCEDURE
Should you wish to opt out of our service at any time, you should send an email containing your name, email address and contact number with OPT OUT as the subject heading to emeajobs@flagshipmgt.com.
Once your details have been erased, we will no longer be able to keep you updated with new job opportunities and market information. However, should your circumstances change you can resend your CV to us at any time.