The purpose of this document is to set out the privacy entitlements of Data Subjects, as defined in the General Data Protection Regulation (GDPR), of living persons. Privacy can only apply to information that is not already in the public domain and GDPR only applies to such personal data.
The General Data Protection Regulation (GDPR) is a European Union Regulation that sets out the data entitlements of data subjects and the obligations of those who process the personal data of data subjects. GDPR seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU.
We have identified our data subjects as being:
- Our Temps
- The individuals with whom we have contact at our client, prospective client and supplier businesses
- Our own employees – our own employee data processing information is set out in their employee handbook
Your privacy is important to ThreeQ Temps. This privacy statement provides information about the personal information that ThreeQ Temps collects, and the ways in which ThreeQ Temps uses that personal information. ThreeQ provide applicants with the choices that allow to opt-out or control how ThreeQ use and share data.
Please refer to our Data Protection Policy for details on, storage, deletion process and length documents are held.
Personal information collection through website
ThreeQ Temps may collect and use the following kinds of personal information:
Information about using ThreeQ website (including how it was found, the time spent on the website, the pages viewed on the website, the country of origin and the internet browser or other devices used to view the website)
Please note that, by submitting comments (CV & Application), applicants will accept and approve the retention of such data to be stored on ThreeQ cloud-based password protected Database for the purpose of the ThreeQ Temps process.
Should these comments (CV or Application) also contain personal data, and applicants do not object to the retention of such data, ThreeQ will hold it for no longer than 12 months after which it will be deleted: If applicants, who become TEMP Workers, hired by client companies or directly employed by the agency, the data in this case is retained in line with statutory guidelines. If applicants do not wish for comments (CV or Application) or any personal data to be stored please send a request to the below email stating the following in the subject line; I/we hereby wish to be deleted from your database. email@example.com
Using personal information online
ThreeQ Temps may use personal information to:
- Administer the website
- Personalize the website for applicants or clients
- Enabling access to and use of the website services
- Supply services that are purchased (clients only)
- Send statements and invoices (clients only)
- Send marketing communications.
Where ThreeQ Temps discloses any personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, ThreeQ Temps may disclose any personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights. ThreeQ Temps takes all due care in ensuring the security of the information that is provided, we recognise that no data transmission over the Internet can be guaranteed to be 100% secure. The possibility exists that this information could be unlawfully observed by a third party while in transit over the Internet or while stored on ThreeQ Temps systems. ThreeQ Temps accepts no liability should this occur.
ThreeQ use data and content about ThreeQ Temps for invitations and communications promoting opportunities, growth, engagement and Services. We of course ask for consent and give candidates the opportunity to opt out before sending any marketing material.
We currently do not share personal data with third parties for their direct marketing purposes without your permission.
Legal basis for processing any personal data
We rely upon the following legal bases for data collection:
Candidates: Information is required in order to perform the contract of “Employment agent” on behalf of our candidates with potential employers. The basis of data gathering in that instance is contractual requirement. This will include identification information such as but not limited to name, address, date of birth, information regarding education/qualifications and reference checks.
Clients/Suppliers: We will process data pursuant to business to business transactions, but where so required, we will rely on the lawful basis of necessary for the performance of the contract for the processing of personal data within this relationship.
- Statutory/Legal Obligation: Information is required in order to perform our statutory obligations such as tax returns and compliance with employment permit legislation. This information will include PPS numbers and, where relevant, evidence of entitlement to work.
- Legitimate Interest:
Clients: We will utilise personal data in the form of email addresses and contact telephone numbers in order to keep our clients and potential clients informed in relation to the careers and market related information. We consider that this is in the legitimate interest of our business to maintain our market presence.
Candidates: Information is processed in the legitimate interests of the business of the employment agency, and where so processed it will be in accordance with and subject to your data subject rights and entitlements. We process your data when it is in the legitimate interests of our company to do so and we do this balancing your data protection rights. We consider that our legitimate interest is that you have registered with us because you are interested in gaining access to the information we provide in relation to salary surveys, marketplace analysis, regulatory changes etc., and/or information in relation to the career opportunities with our clients and prospective clients.
In balancing your data protection rights against this legitimate interest of our company, we have considered:
- The frequency of notifications to you in order to ensure that no nuisance is caused to you;
- The security and integrity of the data you have provided to us;
- Your rights and entitlements to stop the processing of your data with ease and to this end we put you in control of the data that is accessible in our website
- Consent: On occasion we may rely on consent in the collection and processing of some data. Given the nature of the relationship of agent to Candidate and agent to Client we consider that consent is not an appropriate ground on which to rely and therefore it will only be utilised in rare occasions.
IP Addresses and Cookies
We may collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration, statistical purposes. This is statistical data about our users’ browsing actions & patterns and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting the Website our computer server will recognise the cookie, giving us information about your last visit. They help us to improve the Website and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern;
- To store information about your preferences, and so allow us to customise the Website according to your individual interests and make your usage of the Website more enjoyable; and to speed up your searches.
LINKS TO OTHER WEBSITES
We will process personal data during the duration of any contract and will continue to store only the personal data needed for periods after the contract has expired to meet any legal obligations as set out in the table below. After these periods any personal data not needed will be deleted.
|Source of Obligation||Retention Period|
|Revenue Commissioners, Collector General, Companies Acts legislative provisions||6 years rolling retention of records|
|Personal Injuries related records||Records are retained for a period of 3 years past the date of the cause of action, unless it involves a minor, in which case the retention period will be up until 3 years after the minor reaches the age of 18.|
|Breach of Contract related records||Records are retained 6 years from the date of the breach|
|Employment Agency Candidate for Interviews/Placements Records||Candidates who are unsuccessful at the screening or interview stage and who may hold a different skill set than that required by our clients, will have their data held for a period of 1 year past the initial contact with the agency by the candidate, unless the candidate exercises their entitlement to a termination of processing.|
Candidates who have been successful at the screening stage may have their data retained indefinitely or until such time as they request to be removed from our database. This is for the purposes of upholding contractual and statutory obligations.
|Employment contract/terms of employment related information||Duration of the employment – this includes everything from the application form, interview notes, contract related, performance appraisals, references|
|Organisation of Working Time – time sheets/holiday and public holiday records|
National Minimum Wages
Protection of Employment – Temporary Agency Workers, Part Time Workers, Fixed Term Workers
Protection of Young Persons
|3 years post the termination of the employment. Records kept are sufficient to show compliance with legal obligations in accordance with the statutory provisions.|
|Parental Leave Related||8 years – records kept show the dates when a qualifying employee availed of the parental leave and force majeure leave provisions|
|Employment Equality||All records, including interviews and applications are kept for a period of one year.|
|Health and Safety Records||All records relating to health and safety will be kept for a period of 10 years|
|Data Law Compliance||Records in relation to our compliance with Data Law and GDPR will be kept for a five year period.|
DATA SUBJECT RIGHTS UNDER GDPR
- Right of access – you have the right to request a copy of the information that we hold about you in accordance with Section 86 of the Data Protection Act 2018; this is not an absolute right and is subject to the privacy rights and entitlements of others also;
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete in accordance with Section 87 and Section 89 of the Data Protection Act 2018;
- Right to erasure – in certain circumstances, you can ask for the data we hold about you to be erased from our records in accordance with Section 87 and Section 89 of the Data Protection Act 2018; this is not an absolute right and is subject to the obligations of data retention imposed on us by statute;
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing in accordance with Section 87 and Section 89 of the Data Protection Act 2018
- Right of portability – subject to certain restrictions, you have the right to have the data we hold about you transferred to another organisation where we hold it in electronic form. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
These rights may on occasion need to be modified/curtailed by statutory or competing obligations, for example, you may request that we delete your data, however if we have been your employer will can only do so after the statutory period of record retention has expired. In the event that we are obliged to refuse your request in accordance with your data subject rights, or if we are obliged to place conditions on our assent to your request, we will provide you with a reason as to why, which you have the right to legally challenge.
At any time following a request from you we can confirm what information we hold about you, as well as how and why it is being processed.
YOU CAN REQUEST THE FOLLOWING INFORMATION:
- Identity and the contact details of the person or organisation that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of our company or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (Data Protection Regulator).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
TO ACCESS WHAT PERSONAL DATA IS HELD, IDENTIFICATION WILL BE REQUIRED
We will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If we are dissatisfied with the quality, further information may be sought before personal data can be released.
In the event that you wish to make a compliant about how your personal data is being processed by us or by our partners, you have the right to complain to firstname.lastname@example.org.
If you do not get a response within 30 days you can complain to the OFFICE OF THE DATA COMMISSIONER, Supervising Authority of Ireland.
Data Protection Commissioner
R32 AP23 Co. Laois
Telephone +353 57 8684800
Lo Call Number 1890 252 231
CHANGES TO THIS PRIVACY STATEMENT