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Processing of (personal) data by the entity in charge of the online application process

EMPLOYMENT CANDIDATE PRIVACY NOTICE
 
Thank you for your application for employment with RCPI.
 
We respect your right to privacy throughout the recruitment process and, in accordance with the GDPR, this document provides you with information on how the personal data that you provide, in applying for a position with RCPI, will be used.
 
How does RCPI collect personal data about you?
What type of data does RCPI hold about you?
How will RCPI use your personal data?
What is the legal basis in GDPR for RCPI’s processing your personal data?
With whom will RCPI share your personal data?
How will RCPI store your personal data and keep it safe?
How long will RCPI retain your personal data?
Will applicants be subject to profiling or automated decision making?
What are your rights in relation to your personal data?
How can you raise a query or complaint about the use of your personal data?
 
How does RCPI collect personal data about you?
As part of the recruitment process, we collect personal data about candidates from the following sources:
·      You, the candidate
·      Your named referees
·      From publicly accessible sources such as LinkedIn
 
What type of data does RCPI hold about you?
In connection with your application, we will collect, use and store the following personal data about you:
·      The data you have provided to us in your curriculum vitae (CV) and the personal data contained in your covering letter which is likely to include:
-      First name, surname and title
-      Address
-      Telephone number
-      Personal email address
-      Date of birth
-      Employment history
-      Education and qualifications
-      Professional memberships
·      Personal data you have provided to us during interviews whether by phone, online or face-to-face
·      Any personal data provided to us about you by your referees which will include dates of previous employment and performance during previous employment
 
How will RCPI use your personal data?
We will use the personal data we collect about you to:
·      Assess your skills, qualifications, and suitability for the role
·      Communicate with you about the recruitment process
·      Carry out background and reference checks where appropriate
·      Keep records related to our hiring processes
·      Comply with legal or regulatory requirements
 
 What is the legal basis in GDPR for RCPI’s processing your personal data?
It is a ‘legitimate interest’ of RCPI to process the personal data of job applicants to assess their suitability for the role in question.
Processing of candidate personal data is also necessary for RCPI to prepare for a potential contract with the data subject.
Where applicable, the processing of data relating to a job applicant’s entitlement to work is necessary to enable RCPI to comply with legal obligations to which it is subject.
 
With whom will RCPI share your personal data?
The RCPI recruitment process is managed within RCPI without the engagement of any third parties. 
We engage third party to provide various ICT services e.g. HR Information Systems. We have Data Processing Agreements in place with these providers to that they have taken appropriate technical and organisational measures to process, store, and safeguard your personal data.
In the event that a particular role required that we share your personal data with a third party, in addition to having a Data Processing Agreement in place, we would ensure that:
·      The transfer is based on a legal obligation, the performance of a contract, or explicit consent.
·      Where data is transferred to another party, we ensure appropriate technical and organisational safeguards are used to protect your personal data.
 
How will RCPI store your personal data and keep it safe?
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.
We limit access to your personal data to those who have a business need-to-know. They will only process your personal data on our specific instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
 
How long will RCPI retain your personal data?
If your application for employment is successful and you accept a post with RCPI, your personal data will be incorporated into your personnel file. After 12 months, information that related only to the recruitment process such as cover letter and references will be destroyed in accordance with our Data Retention Policy.
If your application for employment was unsuccessful, we will retain your personal data for a period of 1 year after your last application date and will securely destroy your personal data in accordance with our data retention policy. In this instance we retain your personal data for the following purposes:
·     As evidence that we have conducted the recruitment exercise in a fair and transparent way
·     In case a similar role becomes vacant for which you will be a fitting candidate. We will request your explicit consent to use your data for this purpose
 
Will applicants be subject to profiling or automated decision making?
Profiling means the automated processing of personal data to evaluate certain things about an individual. RCPI does not use any means of individual profiling.
Automated individual decision-making is when an organisation makes a decision solely by automated means without any human involvement. RCPI does not use any automated decisions making.
  
What are your rights in relation to your personal data?
Under the GDPR you have the following rights in relation to your personal data:
·        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.
·        Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
·        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.
·        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.
·        Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
·        Request the transfer of your personal data to another party.
 
How can you raise a query or complaint about the use of your personal data?
You can address any questions or concerns about the use of your personal data with the RCPI Data Protection Officer using the contact details below.
 
If you are unhappy with the RCPI’s handling of your personal data or believe that the requirements of the data protection legislation are not being complied with and the issue has not been resolved to your satisfaction by RCPI, you also have the right to submit a complaint to the Data Protection Commissioner using the contact details below
 
RCPI Data Protection Officer
Data Protection Officer
RCPI,
4th Floor Frederick House,
19 Frederick Street South,
Dublin 2
D02 X266
Data Protection Commissioner,
21 Fitzwilliam Square South
Dublin 2
D02 RD28
 
Phone: 01 8639700
Phone: 01 7650100
Email: dataprotectionofficer@rcpi.ie
https://www.dataprotection.ie/en/contact/how-contact-us

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.