Personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information.

• We will always be clear about how we use your Personal Data.
• We will not collect information from you that we do not need.
• We will not hold on to your personal information if it’s no longer needed by us.

At Vertical Markets Group your personal data is at the core of our business. It is fundamental to our success that your personal information is safe and secure. You entrust us with your data and in return we are committed to protecting your privacy at all times.

In most cases we are the Controller of your personal data, within the context defined under privacy legislation. It is important for us, as the Data Controller, that we abide by the principles of the General Data Protection Regulations (GDPR) whilst collecting and processing this data.

This Privacy Statement applies to the processing of Personal Data by Vertical Markets Group in its role as Data Controller.

It applies to personal data we process in relation to:

• Candidates and prospective candidates
• Clients
• Website Users

In order to provide recruitment services to candidates & clients we collect certain information relating to you. The information that you provide us with is personally identifiable, i.e. it identifies you as an individual such as:

• Name, address, date of birth, contact details, email addresses and telephone numbers
• Skills and qualifications, work history, pastimes and hobbies/interests, interview notes
• References from previous employment
• Email exchanges with the candidate regarding work opportunities
• Notes in our CRM database of telephone conversations with the candidate
• Financial information regarding proposed roles and placements related to the candidate
• Links to your professional profiles available in the public domain such as LinkedIn and Twitter.

We do not need to hold sensitive or special category personal data (i.e. information relating to your race, ethnicity, religious beliefs, medical health, etc.). We will only ask for sensitive personal data when it is needed to comply with a statutory obligation or to ensure that any employment rights are respected.

As Data Controller, the GDPR requires Vertical Markets Group to process personal data in accordance with the principles of the GDPR. These require that data shall be:

• Processed lawfully, fairly and in a transparent manner
• Collected for specified, explicit and legitimate purposes and not further processed that is incompatible with those purposes
• Processed to the minimum that is necessary in relation to the purposes for which they are acquired
• Kept accurate, and where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard for the purposes for which they are processed, are erased or rectified without delay
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
• Processed in a manner that ensures appropriate organisational and technological security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage

Our Candidate data comes from many different sources. We will only ever hold your data to provide recruitment services to you.

Some of our sources are as follows:

• The Candidate may forward their CV directly to us at Vertical Markets Group
• The Candidate may apply for a position advertised by us at Vertical Markets Group on one of our websites or sites where we may have advertised
• The Candidate may apply for a position advertised on a third-party website
• The Candidate data may be sourced from a publicly accessible platform or jobs websites who provide search facilities for recruiters. The Candidate uploads their CV and recruiters can contact them if they have a suitable job (Example: LinkedIn) which matches the Candidate’s skills and experience
• We may receive personal data about a Candidate from an associated contact of the Candidate
• The Candidate may be referred to us from another recruitment agency
• The Candidate might be referred to us from a Client

We will only use your personal data for the purposes that you would expect us to, namely to provide you with the best recruitment service and ultimately to place you in the right role. Your personal data will be used by us solely in the course of the provision of our recruitment services, in order to ensure that we can maintain our high level of service to you and to place you in the right role.

Our aim is to place the right candidate in the right role. To do this we may need to use your personal data to provide these services to you. We will use your data for the following purposes in providing these services:

• To inform the candidate of any suitable job opportunities
• To keep the candidate informed and up to date with all aspects of the recruitment process

We only disclose your personal information outside our business in limited circumstances. Where we do, we will put in place a Data Processor contract that requires recipients to protect your personal information, unless we are legally required to share that information with them. Any contractors or recipients that work for us will be obliged to follow our contractual instructions. We do not sell your personal information to third parties. We may disclose your information to our third-party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf, including but not limited to the operation and maintenance of our site.

We may share your data with other organisations as follows:

• Clients and potential Clients
• Third party representative of our Clients
• Between companies within Vertical Markets Group in order to provide recruitment services to candidates and clients.
• Sub-contractors and service providers for the purposes of our being able to provide our candidates and clients with our services. For example, our Customer Relationship Management (CRM) system provider, consultants, lawyers, auditors, etc.
• Where we have a legal or regulatory obligation to do so.

This is known as a Data Subject Access Request or a DSAR in short. In order to furnish you with a copy of your personal data that we hold, we may need to verify your identify.

You have the right to access a copy of any personal information that Vertical Markets processes about you and to request information about:

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any profiling or automated decision-making we may use when processing your data.

You have a right to ask for your personal data to be erased in certain circumstances. However, this right does not apply where we have to comply with a legal obligation or where we need personal data for the establishment, exercise or defence of legal claims.

Where you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. Where we are satisfied that the personal data is inaccurate, we will make the necessary changes.

Where we are relying on legitimate interests as a legal basis to process your data, you have a right to object to such processing on grounds relating to your particular situation.

You have a right to request that processing of personal data is restricted in certain circumstances. However, we shall still continue to process the personal data for storage purposes, for the establishment, exercise or defence of legal claims or with your consent.

We may use and process your personal information where you have consented for us to do so. You may withdraw your consent for us to use your information at any time.

You have the right to lodge a complaint with the Office of the Data Protection Commission. For more information or to exercise your data protection rights, please contact:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 8
+353 (0)761 104800
+353 (0)57 868 4800

We go to great lengths to ensure your data is protected and treated securely in accordance with this Privacy Statement. We take the appropriate legal, organisational, and technical measures to protect your personal information. When we use a third-party service provider, that provider will be contractually required to also use appropriate measures to protect the confidentiality and security of your personal information. We use a variety of security technologies and organisational procedures to protect your information.

To help with recruitment process we may at times need to transfer your information to locations outside of the EEA. We can’t guarantee that these locations have the same data protection laws as we do when it comes to personal data. If we do so in the future, we’ll let you know and we will take measures to protect your personal information both in transit and when it is at its destination.

All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).

If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our data hosting services provider changes) we will amend this policy and notify you of the changes. We will also ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA. If we transfer your personal information to the United States of America, we will only send the personal information to companies that participate in the Privacy Shield framework (or such other framework that may replace it from time to time) or for which we have an alternative safeguard in place in accordance with applicable law. Where they apply to our data transfer activities, we may rely on adequacy decisions by the European Commission in relation to certain countries for data transfers outside the EEA.

We are obliged to retain certain information to ensure accuracy, to help maintain the quality of our services and for legal, regulatory, fraud prevention and legitimate business purposes.

Other information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes.

We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it.

Within the context of the GDPR, we are using the legal basis of “Legitimate Interest” to acquire, hold and process your personal information. Where possible and practical, we will also seek your consent for certain processing, such as the disclosure of your details to a prospective employer.

We will hold your information for no longer than 4 years for recruitment purposes only. Your data is an integral part of our business. We want to ensure a lifelong relationship with you throughout your working career. During this time, we will endeavour to keep a relationship with you and will be in contact with you to retain and update your information with us. We will also keep you informed of any changes that may affect you or your data or any updates to our Privacy Policy.

We are committed to hiring the best candidates possible. We use profiling as a semi-automated process to assess if a candidate’s skills, experience and qualifications are suited for a specific role that we are looking to fill. However, it is a very small part of our process.

Our highly-trained, specialised staff will undertake structured interviews to ultimately determine if a candidate is suitable to be put forward for a particular role.

Please check this page regularly for changes to this policy.

You can contact us with your queries in relation to this policy or for any other reason by post, email or by phone.

Please email us at dataprotection@verticalmarkets.ie or call us on 01 5242455

You can also contact our Data Protection Officer:

Data Protection Team
Vertical Markets Group
13 Lad Lane
Dublin 2
Dublin

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