Welcome to the CSA Personnel Consultants privacy and cookies policy. We respect your privacy and are committed to protecting your personal data.
CSA Personnel Consultants acts as an employment agency and employment business. CSA must process personal data (including sensitive personal data) so that it can provide these services and run our business. In doing so, CSA acts as a data controller.
This policy will inform you how we look after your personal data when you interact with us as one of our customers or suppliers (or as an employee or representative of same), visit our premises, visit and use our website (regardless of where you visit them from), currently www.csapersonnel.com (our website), as a customer, supplier, or otherwise, or we otherwise process your personal data, including information you provide on an application or registration form, or which we may collect from another source such as a jobs board.
1. IMPORTANT INFORMATION/WHO WE ARE
CSA Personnel ConsultantsLimited is registered in Ireland under company number 33786
CSA Personnel Consultants
Alan Nicholson (Managing Director)
Email address: firstname.lastname@example.org
Postal address: 65 St Patrick Street, Cork City, T12 K265
The above lists the Owner, Operator and Data Controller (within the meaning of data protection laws applicable) of this website. References in this notice to “we” or “us” are to the above.
Change to Data Protection & GDPR
The law in relation to data protection is changing with effect from 25th May 2018. This Privacy Notice has been updated for new guests registering with effect from August 2018 to reflect your new rights and for existing customers to update how we process your personal data.
Read through this to fully understand the basis upon which we collect, use and store your personal data and to whom it is disclosed.
CSA will always keep your data safe and comply with applicable data protection legislation.
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country (within the Republic of Ireland, visit the Office of the Data Protection Commissioner).
Rights & Explanation
- to be informed
- You have the right to know what personal data is being collected, our identity and your data protection rights (as per this Privacy Notice).
- subject access
- You have the right to request and obtain access to your personal data
- to have inaccuracies corrected
- If your personal data is inaccurate or incomplete, you have the right to have the data rectified, by the controller, without undue delay.
- to have information erased
- This is also known as the ‘right to be forgotten’, you have the right to have your data erased, without undue delay.
- data portability
- This right only applies where processing of personal data is carried out by automated means. You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
- to object to direct marketing
- You have the right to object to direct marketing processing (which we do only with your consent) of your personal data where the processing relates to direct marketing.
- to restrict the processing of your information, including automated decision-making
- You have a limited right of restriction of processing of your personal data by a data controller. You have the right to not to be subject to a decision based solely on automated processing.
What Personal Data Do We Collect
We collect the personal data that you provide us during the registration & recruitment process, as well as any further personal data you provide to update your details from time to time.
- Identity Data: name, an online username, title, date of birth and gender.
- Contact Data: address, email address and telephone numbers, social media links.
- Financial & Revenue Data: bank account details; PPS number; company registration details and any other tax-related information.
- Employment Data: This includes data that was provided to us through application for a role and/or assignment or employment: Details about your current remuneration, pensions and benefits entitlements; information on your interests and needs regarding future employment; Education details; immigration status (whether you need a work permit);
- Sensitive Personal Data: while we may not actively solicit it, on occasion you may share data with us on your racial or ethnic origin, biometric data, religious or philosophical beliefs, criminal convictions or the alleged commission of an offence or trade union membership;
- Website Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access or website; information about how you use our website and services.
- Other: Additional information that you, the candidate, provide us with; additional information that referees provide us with; additional information that clients provide us with or that we collect from third party sources such as job sites; CCTV footage when you visit our premises.
- Client Data: Contact information; job titles; email correspondence; notes from meetings; signed copies of terms of business.
- Supplier Data: Contact information; email correspondence; notes from meetings; signed copies of terms of business; job titles.
- Referees and Emergency Contacts: Contact information supplied to us by candidates or internal Sigmar staff.
Ensure Data is Accurate
It is vital that you inform CSA if your personal data changes so that we can ensure all the data we hold on you is accurate and up to date.
Other Information Collected
Like most websites, we also gather statistical and other analytical information collected on an aggregate basis from website visitors to our website. This data comprises information that cannot be used to identify or contact you, such as for example, user browser types and other anonymous statistical data involving the use of our website. We use this data in an aggregate form to get a better understanding of where our visitors come from and to help us better design, organise and market our website. Should you have any queries regarding this data, please contact us at email@example.com
How We Collect Personal Data
- During Recruitment Process: We may collect your personal data by speaking to you, by post, via email, via social media, when you leave a hard copy CV at our office; when you apply for a job on a job site and via CCTV capturing when you visit our offices.
- From 3rd Parties: We may receive your personal data from 3rd parties including but not limited to, employers, referees, Revenue, credit agencies, MSP’s and clients. When you ‘like’ CSA’s Facebook page or ‘follow’ CSA on Linkedin or other social media platforms we will receive your personal information from these sites.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than as set out below in relation to marketing.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process you personal data.
Our Standard Business Operations:
- To provide the services that we contract to do so with you;
- To provide you with information that you request from us;
- To confirm your identity as a natural living person; and
- As part of our billing, payments and recovery processes.
We may also use contact information to notify you of any office closure, and how you may contact us should an emergency arise during the closure period.
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in over the phone, by email, or online.
We strive to provide you with choices regarding personal data uses for marketing and advertising and currently use to manage our email correspondence. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering or terrorist related activities.
Children Under Sixteen
Our website and services are not intended to be used by children under 16 years old. We will never knowingly collect data from children below 16 years old. If you become aware of such a child (or another person) supplying data to us, please contact us.
We will take care when processing such data and only do so where one of the legal grounds set out above applies.
3. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in in paragraph 3 above or otherwise below:
- with the Irish Revenue Commissioners, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or Ireland who require reporting of processing activities in certain circumstances;
- with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
- with third party purchasers, if our assets are acquired by a third-party, and data is transferred as part of the purchased assets;
- with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union or United Kingdom who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above;
- where you have appointed a third-party umbrella company to provide invoicing services (or other services on your behalf) we may disclose your information to them in connection with such services;
- with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable);
– with email marketing services i.e. Mailchimp to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails;
– with our customer relationship management software provider, which stores all customer details (these are held on a secure server only accessible with an authorised username and password);
– with analytical service providers in order to analyse our website’s traffic to improve services; and
– with processors offering software tools, or EU or UK based external servers (including externally provided original and backup servers), that are used to store personal information provided by you on our behalf
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process the minimal personal data required for the specified purposes and in accordance with our instructions.
We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing purposes.
4. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
5. DATA RETENTION
CSA will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
We must also keep your payroll records for as long as is legally required by the Irish Revenue Commissioners (as applicable) and under associated legislation.
Where CSA has obtained your consent to process your personal data we will do so in line with our retention policy. Upon expiry of that period, CSA will seek further consent from you. Where consent is not granted, CSA will cease to process your personal data.
6. YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.