Recruitment Notice

Contents.

1. What is a privacy Notice? 
1.1. Purpose and scope
1.2. Multi-layered approach
2. Contact details. 
2.1. Data Controller
2.2. Data Protection Officer
3. Data Protection Principles 
4. How CareChoice manages your personal information
4.1. What data does CareChoice collect about you?
4.2. How personal information is collected. 
4.3. What CareChoice uses your personal information for
4.4. Change of purpose.
4.5. Who is your data shared with?
4.6. The lawful bases for use of your data
4.7. Keeping your information up to date
4.8. Data Security
4.9. Retention of your data 
4.10. Transfers outside the European Economic Area (“EEA”).
5. Your rights
6. Changes to this privacy notice
7. Questions about this privacy notice
8. How can I complain about the handling of my personal information?


1. What is a Privacy Notice?

The General Data Protection Regulation (GDPR) requires that data controllers provide information to people whose personal data they hold and use. A privacy notice is one way of providing this information by identifying who the data controller is, providing contact details for the Data Protection Officer (DPO) and explaining the purposes for which personal data are collected, used, how long it is kept, and the controller’s legal basis for processing. 

1.2 Purpose and scope

The purpose of this privacy notice is to explain how CareChoice manages your personal data when@

  1. You participate in a CareChoice recruitment initiative. 
  2. You voluntarily submit an employment application/CV to CareChoice on a speculative basis. 
  3. You register onto the CareChoice online recruitment system. 
  4. You apply for a speculative or advertised role within CareChoice. 
  5. An external recruiter provides your personal data to CareChoice for employment consideration purposes. (Such external recruiters are controllers of your personal data independent of CareChoice).

This privacy notice applies to the processing of your personal data from the time the data is provided to CareChoice by you or an external recruiter on your behalf for employment consideration purposes. For successful candidates who commence employment with CareChoice, the way we process your personal data will no longer be dealt with under this notice but will instead be managed in accordance with the CareChoice Employee Privacy Notice.


1.3 Multi-layered Approach

This privacy notice is provided in a layered format so you can browse through to specific areas depending on how much you wish to read, what you need to know and how quickly you need to obtain the relevant information.


2. Contact details. 

2.1. Data Controller

CareChoice is a data controller under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Its head office address is:
Block 10-2 Blanchardstown Corporate Park 1, 
Blanchardstown, Dublin 15 A25K. 
Telephone 01 2233000. 

2.2.Data Protection Officer

If you have any queries about this privacy notice or about how CareChoice process personal data please contact the data protection officer by email at dpo@carechoice.ie or at the address below. 

Data Protection Officer
Block 10-2 Blanchardstown Corporate Park 1 
Blanchardstown, Dublin 15 A25K 
Telephone 01 2233000

3. Data Protection Principles 

Under the General Data Protection Regulation (GDPR) all personal data obtained and held by CareChoice must be processed according to a set of core principles. In accordance with these principles, CareChoice will ensure that: 
  • processing is fair, lawful, and transparent. 
  • data is collected for specific, explicit, and legitimate purposes. 
  • data collected is adequate, relevant, and limited to what is necessary for the purposes of processing. 
  • data is kept accurate and up to date.
  • data is not kept for longer than is necessary for its given purpose.
  • data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful 
  • processing, accidental loss, destruction, or damage by using appropriate technical or organisational measures. 

4. How CareChoice manages your personal information

4.1 What data does CareChoice collect about you?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

To enable CareChoice to consider whether to enter into a contract with you and to meet certain legal requirements, CareChoice will collect, store, and use categories of personal information about you. The data you provide may include a variety of information, such as your name, contact information, work history, curriculum vitae, education details, qualifications, referee names, and a photograph. 

Further data may include shortlisting notes, interview notes, score sheets, date of birth, PPS number, visa documentation if relevant, professional registration details and health information including fitness to work confirmation and health issues requiring adaptions to the working environment. 

For all roles CareChoice seek information about past criminal convictions, working with children or vulnerable adults, and/or your fitness to practise in certain regulated professions.

4.2 How personal information is collected.

Much of the personal data which CareChoice process will be collected directly from you. Personal data is also provided by third parties, such as recruitment service providers or consultants if they were involved in the recruitment process, from referees, either external or internal, from Garda vetting and from Occupational Health and other health providers. 

4.3 What CareChoice uses your personal information for.

CareChoice will use your personal data to:
  • process your job application including to contact you in relation to interviews and/or offer you a job after the interview stage. 
  • assess your skills, qualifications, and aptitude against vacancies in CareChoice which may be suitable for you.
  • request information from third parties (such as references from previous employers.
  • to contact you about future vacancies/roles with CareChoice which may be of interest to you. 

4.4 Change of purpose.

CareChoice will only use your personal information for the purposes for which it was collected unless it is reasonable to use it for another reason and that reason is compatible with the original purpose. If CareChoice need to use your personal information for an unrelated purpose, you will be notified and advised of the legal basis which allows such processing of your data. Please note that CareChoice may process your personal information without your knowledge or consent, where this is required or permitted by law.

4.5 Who is your data shared with?

Your personal information may be shared with the following parties: 
  • those employees who would have managerial responsibility for you or are acting on their behalf
  • employees in HR who have responsibility for certain HR processes (for example recruitment, assessment, pre-employment screening) 
  • employees who are part of the selection and / or interview panel employees with responsibility for policies and contractual requirements.
  • your previous employer(s) (where you have listed them as your referees.
  • external recruiters (where your application is being managed by an external recruiter).
  • outsourced service providers who assist CareChoice with recruitment initiatives and campaigns.
  • professional advisors such as legal advisors.
  • Garda vetting


4.6 The lawful basis for the use of your data.
 

Under data protection laws CareChoice must have a legitimate and lawful basis for processing your personal data. CareChoice will primarily process your personal data to consider whether to enter into a contact with you and to enable it to comply with legal obligations e.g., employment legislation, care and welfare regulations, health, and safety requirements, garda vetting legislation etc.

Where your data is processed to perform contract obligations the legal basis is:

Article 6(1)(b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract.

Where CareChoice has a specific legal obligation that requires the processing of personal data, the legal basis is:

Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject.

Where relevant CareChoice may process your personal information to look after your vital interests in the event of an emergency.

In this case the legal basis is:

Article 6(1)(d) – processing is necessary to protect the vital interests of the data subject or of another natural person.

It may be necessary to process your personal data to establish, investigate, exercise, or defend a legal claim.

The legal basis here is:

Article 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

Where special categories of personal data are processed for these purposes, the legal basis for doing so is: Article 9(2)(f) – processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. 

Where special categories of data are processed for employment purposes the condition is: Article 9(2)(b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law. 

4.7 Keeping your information up to date

It is important that the personal information held about you is accurate and current. Please keep CareChoice informed if your personal information changes. 

4.8 Data Security

CareChoice has 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. Access to your personal data is limited to those employees, contractors and other third parties on a strict need-to-know basis, i.e., who need the access to fulfil the tasks and duties relating to service provision.

All service providers are permitted to process your personal data based on CareChoice instructions, they are subject to a 
duty of confidentiality, and they are required to be compliant and demonstrate compliance with data protection legislation. 

Information technology (IT) systems are protected against unauthorised access with various levels of controlled and password protected access rights. Technologies and processes such as access control procedures, network firewalls, and physical security are deployed to protect your privacy.Where personal records are kept in paper format these are stored securely with controlled access. Robust procedures are in place to deal with any actual or suspected data security breach and CareChoice will notify you and any applicable authority about a breach where it is legally required to do so. 

4.9 Retention of your data.

Successful applicant data resulting in subsequent employment will be retained for 7 years following cessation of employment. 
Where you are an unsuccessful job applicant, CareChoice will retain your personal data for 12 months from the most recent of the following occurrences: 
  • you register online as a candidate, or an external recruiter registers your details with CareChoice.
  • either you or an external recruiter on your behalf submit or withdraw an application.
  • you or an external recruiter on your behalf is advised that your application has been unsuccessful.
  • you decline an offer of employment. 

In certain circumstances, CareChoice may hold your data for a longer period, for example, if it is processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably expect or require CareChoice to preserve your personal data. 

4.10 Transfers outside the European Economic Area (“EEA”)

If for any reason CareChoice is required to process personal data outside the EEA, CareChoice will ensure that such a transfer takes place 
strictly in accordance with one of the methodologies permissible by law to ensure that personal data is processed securely and afforded the same levels of data protection that applies in the EEA under the General Data Protection Regulation (GDPR).

5. Your Rights 

Under certain circumstances, you have the right to: 

  • Request access to your personal information. This enables you to receive a copy of the personal information CareChoice holds about you and to check that CareChoice is collecting and using it lawfully.
  • Request correction of the personal information that CareChoice holds about you. 
  • Request erasure of your personal information. This enables you to ask CareChoice to delete or remove personal information where 
  • there is no good reason for continuing to use it. You also have the right to ask CareChoice to delete or remove your personal information where you have exercised your right to object to processing. 
  • Object to processing of your personal information where CareChoice is relying on a legitimate interest (or those of a third 
  • party) and there is something about your situation which makes you want to object to processing on this ground. 
  • Request the restriction of collecting and using your personal information. This enables you to ask CareChoice to suspend the 
  • usage of personal information about you.
  • Request the data portability of your personal information to another party.
  • Right to lodge a complaint to the supervisory authority i.e., the Data Protection Commission.
  • Right to withdraw consent. In circumstances where you have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

You may exercise any of the above rights by emailing the Data Protection Officer at dpo@carechoice.ie or by post to:

CareChoice, Block 10-2 
Blanchardstown Corporate Park 1,
Blanchardstown, Dublin 15 A25K  
Telephone 01 2233000. 

6. Changes to this privacy notice

CareChoice reserves the right to update this privacy notice at any time and will provide you with a new privacy notice when any substantial updates are made. This privacy notice was updated on February 20th, 2023. 

7. Questions about this notice.

If there is anything in this notice that you are unclear about, please contact the CareChoice Data Protection Officer at dpo@carechoice.ie or by post to: 
CareChoice, Block 10-2 Blanchardstown Corporate Park 1, 
Blanchardstown, Dublin 15 A25K. Telephone 01 2233000. 

The Data Protection Officer will answer any queries you may have concerning this privacy notice or the way in which CareChoice process your personal data. 

8. How can I complain about the handling of my personal information?

If you believe that CareChoice has not complied with its data protection obligations please contact the Data Protection Officer at the contact details provided in this notice, who will endeavour to address your concerns.

Should you not be satisfied with the DPO’s response you may lodge a complaint with the Data Protection Commission.

Contact details for the Data Protection Commission are as follows: 

Phone Number: 0761 104 800 or 0578 684 800 
E-mail: info@dataprotection.ie 
Postal Address: Data Protection Commission, 21 Fitzwilliam Square South, 
Dublin 2 D02 RD28