Top Staff Recruitment
14/15 Dame Lane,
1.2 This Notice (“Notice”) has been developed to ensure our users feel confident about the privacy and security of personal data and to meet our obligations under the Data Protection Acts 1988 to 2018 and the General Data Protection Regulation (the “Data Protection Law”). Under Data Protection Law, personal data is information that identifies you as an individual or is capable of doing so (“Personal Data”).
1.3 We must comply with the data protection principles set down in the Data Protection Law and this Notice applies to all personal data collected, processed and stored by us through your use of the Site.
1.4 For the purposes of Data Protection Law, we are the data controller of your Personal Data. You will find our contact details in the “Contact us” section below.
2. WHAT KINDS OF PERSONAL DATA DO WE COLLECT?
2.1 We receive and store any information you enter on the Site or give us in any other way, including [when registering for an account, uploading your CV, applying for jobs (if so available on the Site), viewing a listing, as well as provided in your comments and requests.]
2.2 The Site gives you the ability to register for an account or to create and update a user profile on the Site. By offering this functionality, we will collect the Personal Data that you or your computer/device provides to us in the course of registering for an account or creating or updating a user profile. This information will vary but typically includes Personal Data, such as:
• your first and last name
• your e-mail address
• your age
• your gender
• your password
• your mailing address (including town/city and county)
• telephone number
• your CV and CV updates
• your qualifications
• previous work experience
• the country in which you reside
• Any other data submitted with your job application or correspondence between you and Top Staff Recruitment
3. LEGAL BASIS FOR PROCESSING
3.1 Given the varied functionality of each Site we rely on the following legal basis under Data Protection Law in processing your Personal Data:
Legal Basis Example
performance of a contract If you register or create an account, subscribe to a mailing list or apply for a role via a Site we will process your Personal Data to the extent required to deliver the service requested.
compliance with legal obligations We may need to disclose your identity and other Personal Data to comply with a request from law enforcement, An Garda Síochána / PSNI, police or other government agencies or court order.
Legitimate interests We may disclose your identity and other relevant Personal Data in connection with any complaint regarding your use of a Site. This is necessary in order to protect us from any liability in relation to your use of a Site.
4. HOW WE GATHER DATA AND PERSONAL DATA
4.1 We gather Personal Data from your use of a Site (for example, creating a user profile, posting content of comments that contains Personal Data) and through your interaction with us (for example, when you contact us via email or through the Site).
5. HOW WE MAY USE YOUR PERSONAL DATA
5.1 Except as disclosed in this Privacy Notice, we will not disclose Personal Data that we collect to any parties other than those with whom we partner or are affiliated with, without your consent. Except as disclosed below, we will not sell, share, trade, rent, or give away your Personal Data.
Information you provide
5.3 If you contact us via the Site, or in any other way, we may retain the correspondence and the information it contains, such as:
• your name
• e-mail address
• the reason for contacting us
• additional information submitted to us such as a CV
We may use the information to:
• respond to your inquiry
• to notify you of related job opportunities
• for marketing purposes
When you contact us, we will request your affirmative, positive consent to use your contact information for marketing or other business purposes outside of Recruitment. In the event you do not consent to the use of your contact information for marketing or other business purposes, your data will not be used for those purposes. If you provide your consent but subsequently do not wish to receive notifications about related opportunities, or otherwise want to restrict the use of information you provide to us, please follow the instructions on any marketing correspondence or send us an e-mail at the address listed below.
5.4 The Site interfaces social media websites such as Facebook and Twitter, and may use social media plugins (e.g., the Facebook "Like" button, '"Share to Twitter"' button) to facilitate social media functions. The site also links to other websites from partners such as www.connectopp.com .
5.5 If you are a member of a social media platform or website, and log in to such social media or platform, the interfaces may allow the social media platform or website to connect your visit to the Site to your Personal Data. The social media plugins also may allow the social media website to share information about your activities on the Site with other users of their social media platform. We have no control over the information that other websites or social media websites or plugins collect, store, or use. Before you choose to access other websites from the Site or “like” or share information from the Site through any social media platform or website, please be certain that you review the privacy notice of that social media platform or website.]
Do we disclose Personal Data to anyone else?
5.6 We shall disclose your information to third parties only when you have authorised us to do so, it is necessary as part of business practices or when there is a legal or statutory obligation to do so. Whenever we disclose information to third parties, we will only disclose that amount of personal information necessary to meet such business need or legal requirement. Third parties that receive your information from the us must satisfy us as to the measures taken to protect the personal data such parties receive, in accordance with Data Protection Law and as stated in this Privacy Notice. Appropriate measures will be taken to ensure that all such disclosures or transfers of your information to third parties will be completed in a secure manner and pursuant to contractual safeguards.
5.7 We may employ other companies and individuals to perform functions on our behalf, including marketing, temporary / cover recruitment, and providing analytics assistance. From time to time, we may also share Personal Data or non-personally identifiable information with third-parties that we have engaged to perform certain services in connection with the operation of certain aspects of the Site, including to customize, deliver, measure, analyse, improve and support our services, content, advertising and layout, your interaction with those aspects, and to deliver more relevant messages and advertisements to you. These third-party service providers are authorised to use Personal Data only as needed to perform their functions on our behalf and are required to maintain the security of your personal information.
5.8 We may also change our ownership or corporate organisation while providing the Site. As a result, we may transfer your information to another company that is affiliated with us, with which we have merged, or which has acquired all or some of our assets. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Privacy Notice accordingly.
5.9 We may provide information, when obliged to do so under the Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with the Data Protection Law.
5.10 We may also provide information when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.
5.11 We may also disclose your identity or any Personal Data in connection with any complaint regarding your use of the Site.
6. HOW LONG DO WE KEEP PERSONAL DATA?
6.1 The period for which we retain information varies according to the use of that information. In some cases, there are legal requirements to keep data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain information no longer than is necessary for the purposes for which the data were collected and processed (as described above).
6.2 [Personal Data may be provided by you through registering for an account with our Site, but may also be provided without registering for an account. Personal Data provided by you when registering for an account will be held for as long as you hold an account with us. Following termination of your account, your Personal Data shall continue to be retained for a period of seven years following the date of termination of the account in accordance with Irish statutory limitation periods. Personal Data provided without registration with be retained for as long as you remain active and for a  day period of inactivity, following the expiry of which time we will contact you and, unless we hear from you, the data will continue to be retained for a period of seven years following that date in accordance with Irish statutory limitation periods. Following the expiry of this limitation period any Personal Data held by us will be destroyed.]
7. HOW DO WE PROTECT DATA ABOUT YOU WHEN IF IS TRANSFERRED OUT OF EUROPE?
7.1 Our Site is published in Ireland and is governed by Data Protection Law and Irish law.
7.2 Some websites transfer data outside of the EEA for a number of purposes (for example, for storage purposes). We do not transfer any Personal Data outside of the EEA for any purpose.
7.3 If this changes at any point in the future, this Privacy Notice will be updated to take account of this change. Note that in this event, any transfer of Personal Data outside of the EEA shall be made through transfer mechanisms approved or allowed for under Data Protection Law and we shall take all necessary steps to ensure that there is adequate protection, as required by Data Protection Law.
8. HOW YOU CAN EXERCISE YOUR RIGHTS IN RESPECT OF PERSONAL DATA WE HOLD ABOUT YOU
8.1 We shall vindicate all your rights under Data Protection Law. These rights are as follows:
• Your right to withdraw your consent to the processing of Personal Data at any time
• your right to request from us access to personal data and to have any incorrect personal data rectified
• your right to the restriction of processing concerning you or to object to processing
• your right to have your personal data transferred to another service provider
• your right to have personal data erased (where appropriate)
• information on the existence of automated decision-making, if any, as well as meaningful information about the logic involved, its significance and its envisaged consequences
Vindication of your rights shall not affect any rights which we may have under Data Protection Law.
Exercising your rights, managing information and opting out
8.2 You may update or change information related to your account by updating your profile, accessible via the home page once you are logged in, or by sending us an e-mail at [ email@example.com ] . You may always opt-out of receiving future commercial e-mail messages from us or request that your information be removed from our Site by e-mailing us at the address provided above. You may also unsubscribe from our marketing communications by sending us an e-mail.
8.3 You can update or correct your Personal Data, remove it from our system or exercise any of your rights by making a request to us at the contact information provided below. If for some reason access is denied, we will provide an explanation of why access has been denied.
8.4 We will confirm your request within 21 days of receipt, and process your request within 30 days of receipt.
9. HOW DOES THE SITE PROTECT PERSONAL INFORMATION ABOUT YOU?
9.1 We employ reasonable appropriate administrative, technical, personnel procedural and physical measures to safeguard Personal Data against loss, theft and unauthorised uses access, uses or modifications. Security and testing are performed on systems containing personal data to verify control effectiveness. Security of these systems are monitored continuously.
9.2 When you make requests or access your account information, including anywhere on the Site where we request credit card information, we offer the use of a secure server. Personal information collected on the Site is stored in secure operating environments. Secure Sockets Layer (SSL) software encrypts all information you input before it is sent to us. While we try our best to safeguard your information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.
10. HOW CAN YOU MAKE A COMPLAINT ABOUT THE USE OF PERSONAL DATA?
10.1 Complaints on the use, retention and disposal of personal data can submitted via email to firstname.lastname@example.org .
10.2 As a user of the Site you also have the right to lodge a complaint with the Data Protection Commission.
11.1 This Notice will be reviewed and updated from time to time to consider changes in the law and the experience of the Notice in practice. Any and all changes will be advised to customers and, if necessary, we will obtain your consent prior to applying any changes to any Personal Data collected from you prior to the date the change becomes effective. Your continued use of our Site after such changes will be subject to the then-current Notice. We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and disclose personal information.
12. CONTACT INFORMATION
12.1 If you have questions about this Privacy Notice or our treatment of the information provided to us, please contact us at:
Name: Top Staff Recruitment
Address: 14/15 Dame Lane, Dublin 2, Dublin
Phone: 01 7383951
1.1 We are committed to safeguarding the privacy of Top Staff Recruitment website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of [our website visitors and service users]; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, "we", "us" and "our" refer to [data controller name].[ For more information about us, see Section 13.]
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
- How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process [data about your use of our website and services] ("usage data"). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is [our analytics tracking system]. This usage data may be processed [for the purposes of analysing the use of the website and services]. The legal basis for this processing is our legitimate interests, namely [monitoring and improving our website and services.
3.3 We may process [your account data] ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.] The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
3.4 We may process [your personal data that are provided in the course of the use of our services] ("service data").[ The service data may include [specify data].][ The source of the service data is [you or your employer].] The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
3.5 We may process [information that you post for publication on our website or through our services] ("publication data"). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
3.6 We may process information contained in any enquiry you submit to us regarding our services] ("enquiry data"). The enquiry data may be processed for the purposes of offering relevant services to you.
3.7 We may process [information relating to our customer relationships, including customer contact information] ("customer relationship data").[ The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers and keeping records of those communications. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.8 We may process [information contained in or relating to any communication that you send to us] ("correspondence data"). The correspondence data may include [the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is [our legitimate interests, namely the proper administration of our website and business and communications with users.
3.9 Please do not supply any other person's personal data to us, unless we prompt you to do so.
- Providing your personal data to others
4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.[ We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.]
- International transfers of your personal data
5.1 In the event of International clients, your full consent will be required prior to any sharing of your data.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) personal data category will be retained for a maximum period of 3 years following the last point of application / communication
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email.
- Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by contacting email@example.com .
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us OR by emailing firstname.lastname@example.org .
- About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Cookies used by our service providers
- Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
- Our details
13.1 This website is owned and operated by [Alex Coffey].
13.2 We are registered in [England and Wales] under registration number [number], and our registered office is at [address].
13.3 Our principal place of business is at [14-15 Dame Lane, Dublin 2].
13.4 You can contact us:
(a) [by post, to the postal address given above;
(b) [using our website contact form];
(c) [by telephone, on [the contact number published on our website from time to time]]; or
(d) [by email, using [the email address published on our website from time to time]].
- Data protection officer
14.1 Our data protection officer's contact details are: Alex Coffey: email@example.com