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 purposes of the processing of your data, the lawful basis that permits us to process it and ensures that you have been meaningfully informed in relation to the processing, 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:

• processing is fair, lawful and transparent
• data is collected for specific, explicit, and legitimate purposes
• data collected is adequate, relevant and limited to what is necessary for the purposes of processing
• data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
• data is not kept for longer than is necessary for its given purpose
• 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
• 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 and contact 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. AML and verification information used to verify your identity and assess for criminal convictions, as detailed in Section H below
8. financial and accounting data including your bank account details, employment history, details of investments, etc.
9. employment data pertaining to performance and disciplinary matters
10. details on your education and employment history etc.
11. 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 as well as through publicly available databases such as the electoral register. 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– either to enable our entry into an employment contract with you or to pursue legitimate interests in ensuring prudent management of our business (including the legal, personnel, administrative and financial management requirements of engaging employees. The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Purpose Data Collection Activity	Categories of Data	Lawful basis
Carrying out checks in relation to your right to work in the Republic of Ireland, UK or EU	Identity data	Legal obligation
Making reasonable adjustments for applicants with disabilities	Health data	Legal obligation
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion	Identity data KYC and Compliance data	Our legitimate interests
Making decisions about salary and other benefits and ensuring efficient administration of contractual benefits to you	Identity data Financial and accounting data	Our legitimate interests
Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary	Employment data	Our legitimate interests
Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained	Identity data Contact data	Our legitimate interests
Implementing grievance procedures	Performance data	Our legitimate interests Legal Obligation
Gaining expert medical opinion when making decisions about your fitness for work	Health data	Our legitimate interests
Managing statutory leave and pay systems such as maternity leave and pay etc.	Health data Identity data	Our legitimate interests
Business planning and restructuring exercises	Performance data	Our legitimate interests
Dealing with legal claims made against us	Identity data Performance data KYC and Compliance data	Our legitimate interests
Preventing fraud	KYC and Compliance data Financial and accounting data	Our legitimate interests
Ensuring our administrative and IT systems are secure and robust against unauthorised access	Identity data	Our legitimate interests

 

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 and for ensuring and monitoring that adequate adjustments are made for individuals with disabilities. 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. Criminal conviction searches are limited to a 5-7 year history, subject to jurisdictional specific law.  

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 and collating AML and verification data 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 below listed rights in relation to the personal data we hold on you. You can make a request to us if you would like to exercise your rights and we will respond to any valid request within one month unless it is particularly complex or you have made multiple requests, in which case we will respond within three months at the latest. We will inform you of any such extension within one month of receipt of your complaint.

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 you. 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 circumstances. This is also known as 'erasure' and will be facilitated in circumstances where the data is no longer needed, consent is withdrawn, no legitimate grounds for processing override your objection, processing has been unlawful or removal is required to comply with a legal obligation
5. the right to restrict the processing of the data
6. the right to transfer the data we hold on you to another party. This is also known as 'portability'
7. the right to object to the inclusion of any information where processing takes place on the bases of reliance on legitimate interest grounds
8. the right to regulate any automated decision-making and profiling of personal data
9. the right to complain to Origina or the Data Protection Commissioner, as detailed in section O.

Further details on your rights as an applicant whose data will be processed are available in Origina's GDPR and Data Processing policy.  

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 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]