Recruitment Privacy Notice
As part of any recruitment process, Blue Face Limited (“Company”, “we”, “us”, “our”) collects and processes personal data relating to job applicants.
What information do we collect?
The Company collects a range of information about you. This includes:
- Personal details and contact information: your name, address and contact details, including email address and telephone number; nationality (where required), age, date of birth, place of birth, national ID; gender, marital status, dependents, photograph (e.g. staff photo), next of kin and emergency contact details. If voluntarily disclosed, we may also collect information about your disability status and information relating to accommodations that you may request during the recruiting process based upon your explicit consent.
- Recruitment information: details of your qualifications, skills, experience and employment history; names and contact information for references, transcripts, date of hire, right to work and work permit or visa information, technical skills, language capabilities and other relevant skills and whether you are subject to the restrictive covenant or other prior employer obligations, information about your current level of remuneration, including benefit entitlements, and information about your entitlement to work in the country you are applying to work in.
- Publicly available information such as contact information, your education and work experience, including information that is publicly available via online professional media, so far as it is relevant to consider you for career opportunities.
- Assessment details: If we ask you to attend for an interview, either in person or by phone or video, we may generate information about you such as assessments or interview notes.
- Results of screening checks: If we make a conditional offer of employment, it may be subject to certain background checks or references. We will consider the results of these checks in accordance with the law.
- Offer related information: If we prepare an offer to you, we process information such as your civil status, nationality, photograph, PPS number or other unique citizen reference number ID card or passport details, declaration of employment status, work permit details, gender, terms of employment, tax details, payment details, insurance details, location and organizations.
How do we collect information?
The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
We may also collect personal data about you from third parties, such as recruitment agencies, or other public sources like online professional media such as LinkedIn. Once a job offer has been made, we will seek references from former employers. Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems.
Why does the Company process personal data?
The Company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we may need to check that you are entitled to work in the relevant place of employment.
We need to process data to take steps regarding your acceptance of a job offer, prior to entering into a contract with you and, if applicable, to enter into a contract with you.
We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, the Company may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we retain your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. If you applied for the job through a recruiter, we will update the recruiter about the success or otherwise of your application through the recruitment process. We may also provide feedback about your application to the recruiter.
We may also share your personal information with regulatory bodies and law enforcement bodies (where we are required to do so to comply with relevant legal and regulatory obligations).
When you use third-party apps, websites or other products integrated with our systems to apply for a role, such third parties may collect information about you subject to their own terms and privacy policies, which are not controlled by us.
We may also share your personal information with third party service providers. These include, for example, service providers who provide pre-employment screening services to us and other third party service providers who provide services on our behalf such as recruitment agencies, vendors facilitating interview travel booking and expenses, immigration and employment lawyers and consultants, pre-employment screening services and our applicant tracking system provider. We may also share your data with former employers to obtain references for you.
Transfer of your information
As we operate internationally, your personal information may also be disclosed and transferred to a person or company that is part of or outside of the Blueface group and located in a country outside the European Economic Area (“EEA”) for any of the purposes set out in this notice. Some of these countries may not have the same levels of data protection or similar rules in relation to processing your personal information as are present in the EEA. However, these transfers are necessary for the management of the Company. We will typically transfer and disclose your data in compliance with the Standard Contractual Clauses approved by the European Commission, or may rely on other legal bases to export your data to a country outside the EEA including where the importer is certified under the Privacy Shield framework, where the importer is in a Commission approved country. If you would like to get more information about the measures we put in place to protect your information when it is transferred outside of the EEA (including a copy of the Standard Contractual Clauses), please contact privacy@blueface.com.
How does the Company protect data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or unlawfully disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does the Company keep data?
If your application for employment is unsuccessful, the Company will hold your data on file for up to 6 (six) months after the end of the relevant recruitment process. This is so that we can comply with our legal obligations and resolve disputes or, unless you object now or later, so we can contact you about current and future open positions with us. At the end of that period, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
Your rights
As a data subject, you have a number of rights. These include:
- Access – you are entitled to obtain a copy of the personal information which we hold about you and certain additional details regarding how we process your personal information.
- Rectification – you can require the Company to change incorrect or incomplete data.
- Restriction – you can restrict our use of your personal information.
- Deletion – you can require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing.
- Objection – you can object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing.
- Portability – you have the right, in certain cases, to obtain a commonly used machine-readable copy of the electronic information you provided to us.
These rights are not absolute and may be restricted in certain circumstances such as, for instance, where they may be needed to comply with our legal obligations or for the establishment, defence or exercise of legal claims.
If you would like to exercise any of these rights, please contact privacy@blueface.com.
If you believe that the Company has not complied with your data protection rights, you can lodge a complaint with the Office of the Data Protection Commission. Please see dataprotection.ie for more information.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Company during the recruitment process (up to the point of employment, if applicable). However, if you do not provide the information, we may not be able to process your application properly or at all.
Who we are
We are Blue Face Limited, a company registered in Ireland with number 385721 and registered at 10/11 Exchange Place, IFSC, Dublin 1.
Notice updates
This notice may be updated from time to time. If we make changes that are material we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.
