Kate Cowhig International Healthcare Recruitment (KCR) – Data Protection Notice

1 General

Kate Cowhig International Healthcare Recruitment (‘Kate Cowhig Recruitment’) is committed to protecting all personal categories of data held on you.

As such, Kate Cowhig Recruitment wants you, the ‘data subject’, to understand how Kate Cowhig Recruitment collects, uses, stores, and shares your personal data. Kate Cowhig Recruitment also wants you understand what rights you can invoke to help you to protect your privacy. In this regard, it is important that you read this Privacy Notice and understand how Kate Cowhig Recruitment uses your personal data. Please note Kate Cowhig Recruitment reserves the right to update this Privacy Notice as required. The most recent version of this document can be found on Kate Cowhig Recruitment’s website through the following link: https://kcr.ie/privacy-policy/

1.1 Kate Cowhig Recruitment Information

Kate Cowhig Recruitment is a leading healthcare direct placement company which has been in operation since 1990. Kate Cowhig Recruitment specialises in the recruitment of registered nurses, midwives and allied health professionals, for many of the largest teaching hospitals in Ireland, and the UK. If you wish to locate further information on Kate Cowhig Recruitment, you can find this on the Kate Cowhig Recruitment website through the following link: https://kcr.ie/about-us/

1.2 Legislation

All personal data processed by Kate Cowhig Recruitment is done so in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

1.3 Queries and Complaints

If you are unhappy with the way Kate Cowhig Recruitment handles your personal data and wish to complain, or if you simply want further information about the way your personal data will be used, please contact Kate Cowhig Recruitment at the below:

Data Protection Officer

Kate Cowhig Recruitment

Gray Office Park, Galway Retail Park

Headford Road, Galway

Ireland

Telephone: +353 1 671 5557

Email: dataprivacy@cpl.com

You have the right to lodge a complaint with the Data Protection Commission. To contact the Data Protection Commission, please use the following details:

Data Protection Commission

21 Fitzwilliam Square South

Dublin 2

D02 RD28

Ireland

Telephone: +353 (0)761 104 800

Telephone: +353 (0)57 868 4800

Email: info@dataprotection.ie

 

1.4 Breaches

Kate Cowhig Recruitment will take all appropriate technical and organisational steps to safeguard your personal data. In the unlikely event of a data breach, Kate Cowhig Recruitment will contact you in line with Kate Cowhig Recruitment’s legal obligations.

2 How Does Kate Cowhig Recruitment Collect Information?

Kate Cowhig Recruitment collects personal data to enable the provision of services to support Kate Cowhig Recruitment’s purpose. The following non-exhaustive methods of data collection are an indication of ways in which Kate Cowhig Recruitment may obtain your information:

  • Obtain personal data directly from you;
  • Personal data that Kate Cowhig Recruitment receives from other sources; and
  • When entering Kate Cowhig Recruitment’s premises, you will be recorded in the Visitor Sign In tablet/book for security purposes.

It is important that the personal data you provide Kate Cowhig Recruitment is up to date and accurate. As outlined in Section 7.4 of this notice, if personal data Kate Cowhig Recruitment holds on you is inaccurate or incomplete, please contact Kate Cowhig Recruitment and Kate Cowhig Recruitment will update the information.

 

 

3 What Does Kate Cowhig Recruitment Use Information For?

3.1 Process, Purpose, and Lawful Basis

Kate Cowhig Recruitment uses personal data collected to fulfil Kate Cowhig Recruitment’s obligations to provide Training & Consultancy services and to enable the provision of services to support Kate Cowhig Recruitment’s purpose.

Kate Cowhig Recruitment uses personal data for any of the following purposes:

 

Process Purpose Lawful Basis
Pre-Recruitment To register a prospective data subject’s interest in recruitment for employment. Processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

The processing is necessary for the exercise of rights and obligations under employment law.

Background Checks To verify if the data subject is qualified and eligible for certain positions within Kate Cowhig Recruitment. Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.
Recruitment

and Selection

To complete the recruitment process and assess data subject suitability. Processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

Processing relates to Kate Cowhig Recruitment’s obligations in employment and for assessing data subject’s work capacity.

 

Pension To administer data subjects pension entitlements and to comply with pension rules. To comply with various pension laws.

Processing is necessary for the performance of a contract to which the data subject is party.

Payroll To enable Kate Cowhig Recruitment to effect payment to its data subjects. Processing is necessary for the performance of a contract to which the data subject is party.

 

Personnel File To comply with employment and revenue laws and to ensure that terms and conditions of employment are adhered to. Processing is necessary for the performance of a contract to which the data subject is party.

To comply with various employment and revenue laws.

To protect the vital interests of the data subject in the event of an accident or emergency.

 

Entitlement to Work To enable Kate Cowhig Recruitment to achieve compliance with its obligations pursuant to any local legislation governing the entitlement to work.

 

Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.
Time and Attendance Records To enable the data subject to avail of their rights and entitlement pursuant to the Organisation of Working Time Act 1997.

 

The processing is necessary for the performance of contract to which the data subject is party.
Statutory Entitlement To enable Kate Cowhig Recruitment to achieve compliance with:

·     Its obligation to the data subject;

·     Record keeping obligations pursuant to a variety of employment law statutes.

 

The processing is necessary for compliance with legal obligation to which Kate Cowhig Recruitment is subject.
Training Records To ensure that Kate Cowhig Recruitment is in a position to assess the data subject’s training needs and to capture proof of training.

 

The processing is necessary for the performance of contract to which the data subject is party.
Performance Details To manage the data subject’s performance in accordance with relevant Kate Cowhig Recruitment policies.

 

The processing is necessary for the performance of contract to which the data subject is party.
Grievance

and Disciplinary

To ensure the data subject’s complaints are fairly investigated in accordance with Kate Cowhig Recruitment policies. To comply with Kate Cowhig Recruitment legal obligation to apply fair procedures to any data subject’s investigation.

The processing is necessary for the performance of contract to which the data subject is party.

Medical Information To manage the data subject’s absences, to manage sick pay in accordance with the contract of employment, and to manage the fitness to work of data subjects. Processing is necessary to assess, subject to data subject safeguards, the working capacity of the data subject.

To carry out obligations and exercise rights under employment law.

 

Making or Receiving Payments To make or receive any payments in the discharge of normal business functions, dispute settlement, or to carry out any other payment requirements. Processing is necessary for compliance with various employment and revenue laws.

 

The processing is necessary for the performance of contract to which the data subject is party.

 

Attracting Talent To provide support and assistance on recruitment services to data subjects via third party sources, such as LinkedIn and other job sites, from which Kate Cowhig Recruitment obtain personal data.

 

Processing is based on legitimate interest.
Supporting Talent To support data subjects in their career guidance and communicate with them directly with useful information, advice, and support materials through email, messaging, or mobile/web notification.

 

Processing is based on legitimate interests and contractual obligations.
Regulatory Compliance To comply with financial regulations and any other relevant laws and regulations. Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

 

Third Party

Data Sharing

To allow Kate Cowhig Recruitment to conduct and carry out functions with third party service providers that enable Kate Cowhig Recruitment to deliver services. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

 

Back-ups To store personal data and make back-ups of that data in case of emergencies and for disaster recovery purposes. Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.
Evidence Submissions To gather information for dispute resolution services and legal proceedings. Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.

 

Transfer of

Information for

Parties Legal

Proceedings

To allow parties to commence legal proceedings. Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.

 

Visitor Log For the security, health, and safety of individuals on Kate Cowhig Recruitment premises. Processing is based on legitimate interest and is necessary for compliance with a legal obligation to which the Kate Cowhig Recruitment is subject.

 

Accidents and

Incidents

To enable Kate Cowhig Recruitment to comply with data subject record keeping obligation pursuant to the Safety, Health, and Welfare Act 2005. Processing is necessary for compliance with a legal obligation to which Kate Cowhig Recruitment is subject.

 

 

4 Who Does Kate Cowhig Recruitment Share Information With?

Kate Cowhig Recruitment may share personal data with other parties in the course of Kate Cowhig Recruitment’s duties. When this is done, Kate Cowhig Recruitment adheres to the following principles:

  • The transfer is based on a legal obligation, the performance of a contract, or explicit consent.
  • Where data is transferred to another party, Kate Cowhig Recruitment ensures appropriate technical and organisational safeguards are used to protect your personal data.
  • Where Kate Cowhig Recruitment engages a third party to provide a service to Kate Cowhig Recruitment, Kate Cowhig Recruitment ensures the provider has taken appropriate technical and organisational measures to process, store, and safeguard your personal data.
  • Kate Cowhig Recruitment, as a Data Controller, will not sell your data to any third party and will take all appropriate steps to ensure the security of your data in dealings with third parties.

While the parties Kate Cowhig Recruitment engage may change occasionally, Kate Cowhig Recruitment believe it is important you are aware of the types of parties Kate Cowhig Recruitment shares data with. The categories and types of third parties outlined below is a non-exhaustive list but provides an indication of the parties Kate Cowhig Recruitment shares data with.

4.1 Other Third Parties

Third parties for the purposes of internal and external audits, carrying out research, general practitioners, and or third parties who may improve Kate Cowhig Recruitment’s processes and services (such as consultants).

4.2 Government Departments, Bodies or Agencies

Kate Cowhig Recruitment is legally obligated to share personal data with state actors which is outlined in the Data Protection Act 2018.

Recipients of this data include Government departments, agencies, bodies, investigatory bodies, local authorities, and the Gardaí.

4.3 International Transfers

Where personal data is transferred outside the European Economic Area, Kate Cowhig Recruitment use safeguards known as Standard Contractual Clauses (SCCs).

5 What Type of Information is Collected?

To fulfil Kate Cowhig Recruitment’s mandate and perform tasks as outlined in this statement, Kate Cowhig Recruitment needs to collect various types of personal data.

While the type of personal data may change occasionally, Kate Cowhig Recruitment believes it is important you are aware of the types of data Kate Cowhig Recruitment gathers and uses. The following table is a non-exhaustive list and provides an indication of the categories and types of data Kate Cowhig Recruitment uses to perform Kate Cowhig Recruitment’s tasks.

Please note that information listed under one category may be used for the performance of a task or in relation to activities under another heading or as outlined under Section 3.

Category Type of Data
Candidates
  • First name, last name, email address, home address, work address, work and personal phone number, work and personal email address, proof of address, date of birth, qualifications, employment history, resume and cover letter, driver’s license, interview notes, interview feedback.
  • Special data such as Passport and Nationality card.
Employees
  • First name, last name, personal details, email addresses and phone numbers, photos, qualifications and certificates, past employment details, resume, annual leave details, performance documents and progress reports, training records.
  • Special data such as fitness to work certificate, proof of right to work in Ireland, work VISA, GNIB card and sick leave details.
  • Criminal data such as Garda Vetting disclosures.
Other Stakeholders
  • Contact details, first name last name, email address, bank details and payment details.

6 How Long Does Kate Cowhig Recruitment Retain Information?

Kate Cowhig Recruitment has developed a record retention schedule for all the personal data Kate Cowhig Recruitment holds. Each retention period varies dependent on the nature and the purpose of the processing.

The main factors which determine retention periods are as follows:

  1. How long it is required to perform the task;
  2. Any legal requirements to hold onto the data;
  3. Any pending legal actions.

If you would like to see a copy of the Retention Policy, please contact the DPO at dataprivacy@cpl.com

7 What Are Your Rights?

As a data subject, you will have the following rights as outlined in this section 7. However, restrictions may apply in certain situations.

7.1 Where do I send requests?

Please send all your requests to the contact details provided in Section 1, with as much detail as possible about your requirements to allow Kate Cowhig Recruitment to deal with your request efficiently. To answer your request, Kate Cowhig Recruitment may ask you to provide identification for verification purposes.

7.2 How long will a request take?

Upon receipt of a request, Kate Cowhig Recruitment will have 30 days to provide an answer with an extension of two further months if required. If Kate Cowhig Recruitment requires more time to deal with your request, Kate Cowhig Recruitment will notify you of the delay and the reasons behind it within 30 days of the receipt of the request. If Kate Cowhig Recruitment refuses your request, Kate Cowhig Recruitment will also notify you within 30 days of the receipt of the request accompanied by the reasons for the refusal.

Kate Cowhig Recruitment will not charge a fee for any requests, provided Kate Cowhig Recruitment does not consider them to be unjustified or excessive. If Kate Cowhig Recruitment considers these to be unjustified or excessive, Kate Cowhig Recruitment may charge a reasonable fee (also applicable for multiple copies) or refuse the request.

You are entitled to contact the Data Protection Commission if Kate Cowhig Recruitment refuses your request.

7.3 Right of Access

You have a right to know what personal data Kate Cowhig Recruitment hold on you, why Kate Cowhig Recruitment holds the data, and how Kate Cowhig Recruitment is processing your personal data.

When submitting your request, please provide Kate Cowhig Recruitment with information to help verify your identity and as much detail as possible to help Kate Cowhig Recruitment understand the information you wish to access (i.e. date range, subject of the request) and email dataprivacy@cpl.com

Please note that an access request is free of charge, however, where Kate Cowhig Recruitment determines a request to be unjustified or excessive, Kate Cowhig Recruitment may charge you a reasonable fee.

7.4 Right to Rectification

You have a right to request that Kate Cowhig Recruitment information held on you is up to date and accurate.

Where information is inaccurate or incomplete, Kate Cowhig Recruitment encourage you to contact Kate Cowhig Recruitment to have this information rectified. Upon receipt of request, Kate Cowhig Recruitment will ensure that the personal data is rectified and as up to date as is reasonably possible.

7.5 Right to be Forgotten

You have the right to seek the erasure of your personal data in the following circumstances:

  • The personal data is no longer required for the purposes for which is was obtained;
  • Where data is being processed on the basis of consent, you withdraw consent to the processing and no other lawful basis exists;
  • The personal data is being unlawfully processed;
  • You object to the processing of personal data and there are no overriding legitimate grounds for the processing;
  • Your personal data requires deletion in line with legal requirements.

However, Kate Cowhig Recruitment will be unable to fulfil an erasure request if the processing of personal data is necessary for the following:

  • Exercising the right of freedom of expression and information;
  • Compliance with a legal obligation or for the performance of a task carried out in public interest;
  • Reasons of public interest in the area of public health;
  • Archiving or statistical purposes in the public interest;
  • The establishment, exercise, or defence of legal claims;

Please note that the where the legal basis for Kate Cowhig Recruitment’s processing of personal data is on the basis of a legal obligation, some processing in relation to your data may not be subject to the right to erasure.

To determine your request for erasure, Kate Cowhig Recruitment will carry out an assessment of the justification for the retaining your personal data where a legal requirement applies and contact you if Kate Cowhig Recruitment is unable to fulfil your request.

Please be aware that in some circumstances Kate Cowhig Recruitment may need to retain some information to ensure all your preferences are properly respected. For example, Kate Cowhig Recruitment cannot erase all information about you where you have also asked Kate Cowhig Recruitment not to send you marketing material. Otherwise, Kate Cowhig Recruitment would delete your preference not to receive marketing material.

7.6 Right to Restriction

You have the right to restrict the extent of personal data processed by Kate Cowhig Recruitment in circumstances where:

  • You believe the personal data is not accurate (restriction period will exist until Kate Cowhig Recruitment updates your information);
  • The processing of the personal data is unlawful, but you wish to restrict the processing of data rather than erase it;
  • Where the personal data is no longer required by Kate Cowhig Recruitment, but you require retention of the information for the establishment, exercise, or defence of a legal claim;
  • You have a pending objection to the processing of the personal data;

When processing is restricted, your personal data will only be processed: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest.

Kate Cowhig Recruitment will contact you confirm where the request for restriction is fulfilled and will only lift the restriction after Kate Cowhig Recruitment has informed you that Kate Cowhig Recruitment is doing so.

7.7 Right to Data Portability

You have the right to the provision of all personal data held in relation to you in a structured, commonly used and machine-readable format where:

  • Processing is completed on the basis a contract;
  • Processing is completed based on consent by the you;
  • Processing is carried out by automated means.

You may also request that Kate Cowhig Recruitment sends this personal data to another data controller where technically feasible.

7.8 Right to Object

You have the right to object to the processing of your personal data; however, the processing must have been undertaken on the basis of public interest or legitimate interest by Kate Cowhig Recruitment.

If you wish to object to the processing of data, please contact Kate Cowhig Recruitment with your request. Kate Cowhig Recruitment will then stop the processing of personal data unless it is required for legal proceedings.