Phoenix Recruitment (“Phoenix”) is a specialist professional services search firm incorporated in Ireland in 2018 as a private company limited by shares.
Information we may hold 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).
We may collect, use, store and transfer different kinds of personal data about you as follows:
Forename, surname, date of birth, title
Telephone number, email address, address
Employment history, education and training history
Details about positions for which you have been put forward, interviews attended, interview feedback
Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Your username and password, your interests, preferences, feedback and survey responses
Information about how you use our Website and services
Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences
We may also collect, store and use “special categories” of more sensitive personal information which require higher levels of protection. This includes details about your race or ethnicity, information about your health relevant to your work (e.g. any medical condition, health and sickness records) and information about any criminal convictions and offences as part of the recruitment process. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations.
Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
How is Your Data Collected
We collect your data through a number of methods including through:
Directly through an application and recruitment process: You may provide relevant personal data by applying for a specific job on our Website, applying directly to us to place you in a role, providing us with your CV generally, creating an account or profile on our Website, applying for jobs advertised by us via third party websites, downloading and/or subscribing to Phoenix market intelligence such as our guides, subscribing to our blog and other online digital content or providing us with feedback.
Indirectly through third parties (such as previous employers when carrying out reference checks and potential employers when gathering interview feedback) or publicly available sources (such as LinkedIn or other public forums).
How We Use Your Personal Data and For What Purpose
We will only use your personal data when legally permitted to do so. The most common circumstances in which we will use your personal data are as follows:
Where we are taking steps at your request prior to entering into a contract.
Where we need to perform a contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
If consent is used as a legal basis for processing your data, you have the right to withdraw consent at any time by sending an email from the account we use to contact you to email@example.com or use the unsubscribe link on any of our marketing emails.
Please email us at firstname.lastname@example.org if you require further information about the legal ground or grounds we are relying on to process your personal data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may provide you with further specific information about the type of data and purpose of it at the point of data capture.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Once you have provided us with your email address, we may keep in touch by email to let you know about industry news, insights and events. You can ask us to stop sending you marketing messages at any time by emailing us at email@example.com.
Data Sharing with Third Parties
We may have to share your personal data with other Phoenix group entities and/or external third parties, including third-party service providers, where required by law or where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Third-party service providers may include contracted companies and business partners engaged by us to provide our services , or fulfill our contractual duties or optimise our Website. This includes payment processors, data aggregators, hosting service providers, external consultants, auditors, IT consultants and lawyers, service providers administration services, search engine providers, marketing technology platforms and suppliers.
It may also include government and/or semi-state bodies or authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances or to whom we are obliged to share information about our organisation and participation in it. In addition, any changes in our group structure (in terms of mergers, acquisitions, dispositions etc) may also involve the transfer of data to third parties.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We ensure that any transfer of data outside the EU is undertaken using legally compliant transfer mechanisms and in accordance with GDPR.
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 will use strict procedures and security features for the purpose of preventing unauthorised access. We also use secure connections to protect personal data during its transmission.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
Retaining Personal Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data so it can no longer be associated with you, for research or statistical purposes in which case we may use such information without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may:
Request access to your personal data. This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data.This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.
Request restriction of processing your personal data.This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy (b) where our use of the data is unlawful but you do not want us to erase it (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent. Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you want to review, verify, correct, request erasure or transfer of your personal data or object to the processing of your personal data, please contact firstname.lastname@example.org.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
Name: Ruth Lyndon
Address: Block D, Harcourt Road, Iveagh Court, Dublin 2