Origina Privacy Notice for EU and UK Job Applicants

A) PRIVACY NOTICE – INTRODUCTION

In accordance with the General Data Protection Regulation (GDPR), Origina have implemented this privacy notice to inform EU and UK job applicants of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

This notice applies to job applicants who are not successful in their application and/or have not been employed by Origina.

B) 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:

1. processing is fair, lawful and transparent
2. data is collected for specific, explicit, and legitimate purposes
3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
5. data is not kept for longer than is necessary for its given purpose
6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
7. we comply with the relevant GDPR procedures for international transferring of personal data

C) TYPES OF DATA HELD

We keep several categories of personal data on our job applicants in order to carry out effective and efficient processes. We keep this data in a recruitment system for each applicant and we also hold the data within our computer systems, for example, emails.

We collect various types of data, such as:

1. personal details such as name, address, phone number, email address
2. your photograph (If submitted as part of your CV/application)
3. your gender, civil status, information of any disability you have or other medical information
4. right to work documentation
5. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter
6. references from former employers
7. details on your education and employment history
8. information relating to your potential employment with us, including:
   • job title and job descriptions
   • existing salary or salary requirements
   • interview notes
   • information regarding terms and conditions of employment for the role which you are applying

D) COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Personal data is kept in personnel files or within the organisation’s HR and IT systems.

E) LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the recruitment process.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

F) SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

1. health
2. sex life
3. sexual orientation
4. race
5. ethnic origin
6. political opinion
7. religion
8. trade union membership
9. genetic and biometric data

We carry out processing activities using relevant special category data:

Job Applicants & Existing Employees for the purposes of equal opportunities monitoring

Most commonly, we will process special categories of data when the following applies:

1. you have given explicit consent to the processing
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
4. you have already made the data public

G) FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

H) CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of the relevant items in Section D above to process this data.

I) WHO WE SHARE YOUR DATA WITH

Employees within the organisation who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. Job applicant data is only shared with third parties for the purposes of recruitment for roles within Origina.

As part of the recruitment process Origina may utilise the services of third-party organisations for the purpose of performing background checks when it is appropriate given the nature of the role you are applying for and where the law permits us.

J) PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

Origina take appropriate technical and organizational measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction.

These measures include:

1. Using passwords, firewalls, antivirus software, and other security tools to protect our systems and networks
2. Limiting access to your personal data to those who need it for the purposes that we have disclosed to you
3. Training our staff on confidentiality policies and procedures
4. Conducting regular technical reviews of our data protection practices and systems
5. Origina maintain an Information Security Management System via our ISO27001 certification which is subject to external audit by an independent third party
6. Conducting regular reviews of our third parties’ data protection practices and systems including location to ensure that the country where data is hosted has been deemed to provide an adequate level of protection by the European Commission

K) RETENTION PERIODS

We only keep your data for as long as we need it for. Job application information (Application forms and interview notes) of unsuccessful applicants will be deleted within 18 months of the open position being filled, other than for good reason, e.g., pending litigation.

L) AUTOMATED DECISION MAKING

Automated decision-making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement).

M) JOB APPLICANTS’ RIGHTS

You have the following rights in relation to the personal data we hold on you:

1. the right to be informed about the data we hold on you and what we do with it
2. the right of access to the data we hold on More information on this can be found in the section headed “DATA PROTECTION COMPLIANCE” below and in our separate policy on “Subject Access Requests”
3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’
4. the right to have data deleted in certain This is also known as ‘erasure’
5. the right to restrict the processing of the data
6. the right to transfer the data we hold on you to another This is also known as ‘portability’
7. the right to object to the inclusion of any information
8. the right to regulate any automated decision-making and profiling of personal data

N) CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

O) MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Office of the Data If you think your data rights have been breached, you are able to raise a complaint with Origina’s Data Protection Officer. [email protected]

Alternatively, you may contact the Ireland Data Protection Commission, known as the ‘DPC’ using the details at the following link: Your Data | Data Protection Commissioner.

P) DATA PROTECTION COMPLIANCE

Our appointed compliance officer in respect of our data protection activities is: [email protected]