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Privacy Policy - Software Placements Ltd

​1. General Statement
Software Placements fully respects your right to privacy and are committed to ensuring that your privacy is protected. Software Placements will not collect or publish any personal information about you on our website without your permission. Any personal information which you volunteer will be treated with the highest standards of security and confidentiality, strictly in accordance with the Regulations.

2. Personal Data explained
‘Personal Data’ refers to “any information relating to an identified or identifiable natural person (“Data Subject”)”.
This Privacy Policy serves to:
• Inform you what Personal Data Software Placements collects relating to you
• Inform you how Software Placements uses, processes and handles your Personal Data
• Inform you how Software Placements protects your Personal Data against unauthorised or unlawful processing
• Inform you of your rights as a “Data Subject”
This Privacy Policy was most recently updated on 15/05/2018.

3. Collection and use of Personal Data – Software Placements website
Software Placements does not collect any Personal Data about you directly through this website.
The only way we collect your Personal Data is when you submit it to us via email, see section below.

4. Collection and use of Personal Data – By Application
The only way Software Placements collects your Personal Data is when you submit it to us via email application. This would usually be for job application purposes and would typically include your CV and personal details.
Any information which you provide in this way is not made available to any third parties without your permission and is used by Software Placements only in line with the purpose for which you provided it. The legal basis on which your Personal Data will be processed are Articles 6 1(a) and 6 1(a) of the Regulations.
By providing Software Placements with your Personal Data you are consenting to us:
• Collecting, storing and processing your Personal Data for recruitment purposes as outlined in the privacy policy
• Disclosing your Personal Data to external parties as outlined in this Privacy Policy
If, in the past, you have provided us with Personal Data including your CV/Resume, and you want us to continue to include your details on our system then you will need to inform us of same and that can be done by contacting us in writing at info@softwareplacements.ie. Should you no longer consent to Software Placements processing your Personal Data please contact us in writing at info@softwareplacements.ie and we will promptly remove your Personal Data from our system.

Personal Data collected/obtained by Software Placements via your email application may include categories set out in the section below.
The Software Placements collects your Personal Data through the following channels:
• Email applications
• Email enquiries
• Telephone enquiries
• Meetings
• Reference and background checks

4.1. The Personal Data collected includes the following:
• Your Name
• Your Email Address(es)
• Your Phone Number(s)
• Areas of professional interest
• CV and the details contained therein
• Social Media profile URL’s provided within application, and/or where you have a public profile (for example LinkedIn), we may process the information available in conjunction with the information you provide directly to us
• Referral data – If you provide Software Placements with information relating to persons other than yourself, for the purpose of Software Placements providing recruitment services, you are responsible for its accuracy and relevance, and you must have the authorisation of the relevant individual to disclose their details to us

4.2. For the purpose of the recruitment services process we may also (but are not limited to) collect the following information.
• Education and Qualifications
• Salary details
• Work experience details
• Skill sets
• Limited Company Details
• Interview notes in relation to your suitability for a specific role(s) and client requirements
Software Placements may also collect Personal Data from third party sources, for verification and vetting purposes. Prior to contacting third parties, Software Placements will gain your consent, and will contact you if seeking additional information.
For example:
• Reference information ( written)
Information obtained during reference checks, will be passed on to a prospective employer (usually at offer of employment stage).

5. Personal Data Uses & Processing
Software Placements is an Irish owned and run recruitment consultancy, recruiting for and placing candidates on a permanent and contract basis in the areas of IT and Semiconductor.

5.1. Software Placements collects stores and processes your Personal Data, for the purpose of providing you with recruitment and/or related services, including:
• Matching your details against relevant job vacancies
• Informing you of suitable job opportunities
• Forwarding your Personal Data to client companies, in connection with a specific job, with your consent in each case
• Submission of your Personal Data to a client in relation to general employment, but only with your consent in each case
• Allowing you to apply for specific positions with client companies
• Allowing you to revert to us on any job or market enquiries

6. Disclosure of Personal Data
Software Placements may disclose your Personal Data to third parties, only in relation to specific recruitment services if this is deemed necessary, and only with your consent to do so.
Third parties include;
• Organisations acting on behalf of our client’s, involved in supporting their HR functions (for example: outsourced HR firms and outsourced reference / background checking firms)
• Software Placements internal advisors (for example: professional advisors, IT consultants involved in system upgrades or issues, outsourced email)
• Third party contractor – If Software Placements engages a third party contractor to perform services which involves handling or processing your Personal Data, we will ensure that they process your Personal Data in accordance with Software Placements GDPR policies
• If the business structure of Software Placements should change, for example in the event of a Sale, Merger or Joint Venture, your Personal Data may be disclosed to new or potential business owner(s) / business partner(s). In this event Software Placements will ensure that such third parties only processes your Personal Data in accordance with GDPR

7. The Storage and Upkeep of Personal Data
Software Placements will make every reasonable effort to keep your Personal Data current and up-to-date. This will happen via phone calls, email and general communication in order to stay in touch, and noting relevant changes to your profile. If there have been any major changes since our most recent interaction please contact us to allow us to update our records of your Personal Data.
Software Placements will store your Personal Data in the context of the services of a professional recruitment consultancy. If we have had no two-way communication with you about specific positions, career planning, salary levels, market intelligence, and other relevant recruitment services as outlined in this statement, for a period of 7 years, we will delete your Personal Data. As set out in 14 below, you have the right to instruct us to erase your Personal Data at any time. Software Placements may erase your personal data at any point if we consider that we are unable to provide the recruitment services to you as described in this Privacy Policy, and as a result, there is no necessity for us to retain your Personal Data for the purposes for which it was collected.
Third Party Software
Software Placements makes use of third-party software and we endeavour to ensure that they are GDPR compliant.
We use Bullhorn for applicant tracking:
https://www.bullhorn.com/uk/gdpr-commitment-statement/

8. Collection and Use of Technical Information
Our website use three types of cookies; session, third-party and persistent cookies. Visitors can use this website with no loss of functionality if cookies are disabled from the web browser.
Technical details in connection with visits to this website are logged by our internet service provider for our statistical purposes. No information is collected that could be used by us to identify website visitors. The technical details logged are confined to the following items:
• The IP address of the visitor’s web server
• The top-level domain name used (.ie, .com, .org, .net)
• The previous website address from which the visitor reached us, including any search terms used
• Google analytics which shows the traffic of visitors around this website
• The type of web browser and operating system used by the website visitor
Software Placements will make no attempt to identify individual visitors or to associate the technical details with any individual. It is the policy of Software Placements never to disclose such technical information in respect of individual website visitors to any third party (apart from our internet service provider, which records such data on our behalf and which is bound by confidentiality provisions in this regard), unless obliged to disclose such information by a rule of law. The technical information will be used only by Software Placements and only for statistical and other administrative purposes. You should note that technical details, which we cannot associate with any identifiable individual, do not constitute "Personal Data" for the purposes of GDPR.

For more GDPR information check out: www.dataprotection.ie

9. IP Address
An IP address can reveal information about a visitor such as the general geographic location of the visitor or the internet provider they are using to connect to the internet. Software Placements website does not track visitor IP addresses directly. The site uses cookies in place for basic tasks as outlined above.

10. Data Security
Password protected data will be stored in the cloud. Our systems are protected by up-to-date security measures including firewall and top of the range antivirus software to protect your data from unauthorised or unlawful processing and against accidental loss, destruction or damage.

11. Procedures Related to Data Protection
Training
All current staff will participate in GDPR training to ensure compliance with current regulations. All new staff will participate in GDPR training during their on-boarding process with Software Placements. Software Placements will hold GDPR training bi-annually for all staff.
Procedures
Software Placements have implemented strict procedures to protect your Personal Data, these include:
• Regularly updated and changed password settings for company computers and mobile devices
• Printed paper files, if deemed necessary, will be securely kept in locked storage. All temporary paper files will be shredded weekly
• Software Placements premises is protected with a monitored alarm system and is securely locked
• On receipt of an application request Software Placements will require a GDPR opt-in/opt-out response from you. This is a legal requirement in order for Software Placements to collect and process your Personal Data for the purpose of your job application

12. Consent
By using the services of Software Placements your Personal Data as set out in 4.1 and 4.2 will be processed for the purposes set out in 5 above on the basis of your consent.
You have the right to withdraw your consent to Software Placements processing your Personal Data at any time by notifying us in writing at any time on info@softwareplacements.ie for the attention of Míchéal O’Maoldomhnaigh, Data Protection Lead. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Software Placements requires your Personal Data for assisting you with your job application(s), if you do not consent to Software Placements processing your Personal Data you cannot register with Software Placements

13. Right of Access
You have the right to obtain from Software Placements access to your personal data being processed by Software Placements. You can do this by emailing info@softwareplacements.ie for the attention of Míchéal O’ Maoldomhnaigh Data Protection Officer.
Software Placements will always verify the identity of anyone making a Subject Access Request before handing over any information and provide the relevant data within one month of receipt of a Subject Access Request.
This will be provided free of charge in accordance with GDPR. Where your access requests are manifestly unfounded or excessive, Software Placements reserves the right to charge a reasonable fee taking into account the administrative costs of providing the information.
You have the right to have Software Placements rectify any inaccurate Personal Data which Software Placements holds relating to you.

14. Right to erasure
Should you wish for your Personal Data to be deleted by Software Placements, you can email info@softwareplacements.ie for the attention of Míchéal O’ Maoldomhnaigh Data Protection Officer, providing your name, email and contact details asking for your information to be deleted from our records.

15. Complaints
Applicants have the right to lodge a complaint with the data protection commissioner if they feel there has been a data protection breach at www.dataprotection.ie

16. Contact
All comments, queries and requests relating to our use of your Personal Data are welcomed and should be addressed to info@softwareplacements.ie for the attention of Míchéal O’ Maoldomhnaigh, Data Protection Officer.

17. Data Protection Officer
Míchéal O’ Maoldomhnaigh
Software Placements Ltd
12 Merrion Square North
Dublin D02 H798,