About the Recruitment Data Privacy Notice (RDPN)
We know that your personal data is important to you; we want to demonstrate our commitment to privacy and to inform you about the personal data we collect at Fexco and process in connection with our recruitment and selection process.
When we talk about “Fexco,” “we,” “our,” or “us” in this Recruitment Data Privacy Notice, we are referring to Fexco Unlimited Company, registered in Ireland under number 83934, with a registered address at Fexco Centre, Iveragh Road, Killorglin, Co. Kerry and our Affiliates. “Affiliates” in this context means any entity that directly or indirectly controls, is controlled by, or is under common control with us, and “Control” means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity).
This Recruitment Data Privacy Notice sets out an explanation of what personal data about you we process, why and how we process your personal data, with whom your personal data is shared and a description of your rights with respect to your personal data. It applies to all persons applying for a role; those who submit a speculative application and those who register their interest in working with Fexco, including through Fexco’s careers’ portal available at https://careers.fexco.com/. It does not apply to our employees, contractors or customers.
This Recruitment Data Privacy Notice will be reviewed from time to time to take into account changes in the law or changes in how we process your personal data.
If you have any queries in relation to our use of your personal data, you should contact us by emailing email@example.com or by writing to us at Fexco Data Protection Team, Fexco Centre, Iveragh Road, Killorglin, Co. Kerry, Ireland as also outlined in Section 12 of this Data Privacy Notice.
1. What is personal data?
Personal data is any information that can identify you or another individual, either directly or in combination with other information we may hold. We only collect personal data which we need to fulfill the purposes outlined in this Notice and we will not retain it for any longer than is necessary.
2. Categories of personal data collected by Fexco
As part of the recruitment and job application process, we will collect your personal data via our careers portal, email, in person at interviews and/or by any of the methods set out at section 3 below. Such personal data may include:
- Personal details such as your name, address, email address, mobile number, date of birth, Personal Public Service Number (PPSN), work permit details/proof of your eligibility to work in a particular country, and your CV etc.;
- Details about your employment history such as the name and address of your previous employers, job title held, salary and benefits package, information provided by your referees, etc.
- Details about your qualifications such as education, certification, professional membership, languages you speak, etc.;
- Details about any special assistance or support that you may require if called to interview;
- Your image in the form of a photograph (for verifying your identity/ authentication) or on CCTV if attending for interview at office locations which have CCTV in place; and
- Any information you provide to us in response to our queries or questions at interview stage (including information about you which we generate throughout the interview and/or recruitment process such as notes of interviews or other assessments, including test results or results from group activities, presentations and pre-interview tasks).
When you submit personal data about another person, for example, referees, to Fexco, we assume that you have their permission to share this information with us.
Certain categories of personal data such as that about race, ethnicity, religion, health, trade union membership, sexual orientation or criminal convictions are considered to be sensitive personal information or “special categories” of personal data under Data Protection Law. For a definition of Data Protection Law, please see Section 8 below.
Fexco may collect, store and use the following sensitive personal data in the recruitment and application process:
- Information about your nationality, ethnicity, or country of birth.
- Information about your health, including any medical condition, disability status, health and sickness records, insofar as may be necessary to establish your fitness for work or to provide you with adequate support at interview stage.
- Information about criminal convictions and offences where we are legally required to request this information.
- If required to complete credit/background checks for relevant roles, we will use your personal data to perform these checks.
While you may choose to send us additional information (such as cover letters, references, academic transcripts) to support your application, we ask you not to send sensitive personal information to us of your own volition. Fexco is an equal opportunity employer and does not discriminate, directly or indirectly, either on the grounds of gender, family or marital/civil status, age, disability, sexual orientation, religion, race or membership of the travelling community. Please note that, should you include additional information that is likely to contain your personal data, we will hold and process any such personal data in accordance with the terms of this notice and Data Protection Law. For a definition of Data Protection Law, please see Section 8 below.
3. How is your personal data collected?
We collect personal data about candidates from the following sources:
- You, the candidate;
- previous employers via references (with your permission);
- due diligence conducted for Fitness & Probity roles;
- background checks including credit, criminal & educational where relevant;
- education institutions (e.g. proof of qualifications);
- recruitment agencies; and
- social media and other publically available sources (insofar as such sources disclose information about you that may be relevant to the recruitment and application process).
Where we receive your personal data via a third party recruitment agency or an education institution (together "Agency"), we encourage you to read the relevant Agency's data protection notice to understand how your personal data is processed by such an Agency who is a controller of your personal data independently of Fexco.
4. Why we process your personal data?
For prospective employees, we use personal data to undertake any activity relating to our recruitment and selection process and to administer employment contracts where candidates have been successful. This includes using your personal data to enable us to contact you, conduct interviews, assess your suitability as a potential candidate and, if successful, preparing your employment contract and completing internal processing procedures to ‘on-board’ you.
The processing is necessary to enter into a contract with you (where successful) and for our legitimate interests. Such legitimate interests may include managing an effective recruitment process; protecting Fexco’s legal interests and establishing, investigating, exercising or defending a legal claim (e.g. potential employment equality claims which you or a recruiter may bring against us).
We may also need to process your personal data in order to comply with legal obligations applicable to us. For example, it is mandatory to check a successful applicant’s eligibility to work in Ireland before employment starts and, in the case of certain roles, to undergo a background check for the purpose of meeting requirements prescribed by the Payments Cards Industry Standard or other requirements arising in the regulated sectors in which Fexco operates.
We will only use your personal data for the purposes for which we collect it (as outlined in this section 4), 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 in accordance with section 9 of this notice and we will explain the legal basis which allows us to do so.
5. What happens if you do not provide us with your personal data?
In some cases, you may decline to provide us with your personal data. However, if we believe that we require relevant information to effectively and properly manage your application through the recruitment process, we may not be able to continue with your job application.
6. How is your personal data shared/disclosed by Fexco?
We may share some or all of your personal data with the following parties:
- your prospective Fexco employer;
- those directly involved in the recruitment process at Fexco, i.e. your potential future manager(s), personnel in HR, IT, Compliance, Marketing, Legal, Finance and Accounting and Internal Audit;
- other affiliate companies within the Fexco group, where, for example, you agree for your CV to be retained for possible future vacancies.
Fexco Service Providers:
- Resourcing partners: if you are being represented by or applying via a registered third party resourcing partner, we will share the required personal data with them to facilitate any communication needed throughout the recruitment process.
- Information system (“IS”) providers: We ensure that the companies/bodies selected have the appropriate organisational, technical, security measures and safeguards in place to protect your personal data.
- Online assessment providers: we may share your personal data with online assessment providers if an online assessment is part of the selection process.
- Occupational Health Specialists: we will share required personal data with our Occupational Health Specialists (“OHS”) where required.
- Auditors: we will share required personal data with our external auditors only when your recruitment file has been randomly selected as part of an audit.
- Facilities: We will share required personal data with facilities for authentication purposes. There is CCTV in operation in our offices.
- Independent contractors: occasionally we engage with external contractors to complete a specific type of work, for example, recruitment and selection. Your personal data may be shared with these individuals in the course of carrying out their specified purpose.
- External consultants: companies that act as a service provider under contract with us and only process your personal data as instructed by Fexco Unlimited Company. Your personal data is transferred securely and is not used by other parties for any other reason.
- Fitness and Probity: we share personal data in relation to the Central Bank of Ireland’s Fitness and Probity regime with relevant regulatory authorities, for example the Central Bank of Ireland and other financial services providers where a corporate working partnership exists.
- Your personal data will be shared with other companies, organisations, associations and authorities in order to prevent, detect or investigate crime and/or to comply with legal requirements.
- Your previous employer(s) (where you have listed them as your referee(s)).
7. Transfers of your personal data outside of the European Economic Area
We may transfer your personal data outside the European Economic Area ("EEA"), for example, to affiliate companies within the Fexco group or other recipients. Certain recipients (e.g. some of our third party service providers) who process your personal data on our behalf may transfer your personal data outside the EEA to a country that does not provide an adequate level of protection to your personal data. Where such transfers occur, it is our policy that: a) they do not occur without our prior authority; and b) that an appropriate transfer agreement such as the Standard Contractual Clauses or other approved transfer mechanisms approved by the European Commission and supervisory authorities (such as the Data Protection Commission) is put in place to protect your personal data. If you would like to find out more about any such transfers, please e-mail firstname.lastname@example.org.
8. How long do we keep your information for?
Your personal data will only be retained for as long as required and in compliance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (EU) 2016/679 (as amended, varied and supplemented from time to time) (“Data Protection Law”).
In determining those periods, we take account of local employment legislation, any relevant legal requirements to preserve your personal data for mandatory timeframes and our legitimate interests to hold on to your personal data for particular timeframes (for example, where we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your personal data.
9. Changes to this Recruitment Data Privacy Notice:
If we amend this notice, in whole or part, at our sole discretion, any changes will be effective immediately upon notifying the revised notice to you.
If, at any time, we decide to use your personal data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you and you will have a choice as to whether or not we use your personal data in the new manner.
10. Your responsibilities
It is your responsibility to ensure that the personal data and information you provide to us is true and complete; any omissions or false information may result in the withdrawal of any offer of employment made to you or, if you have been hired, disciplinary action up to and including dismissal.
11. What are your rights under Data Protection Law?
You have the following rights under Data Protection Law, although your ability to exercise these rights may be subject to certain conditions:
- the right to receive a copy of and/or access the personal data that we hold about you, together with other information about our processing of that personal data;
- the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete;
- the right, in certain circumstances, to request that we erase your personal data;
- the right, in certain circumstances, to request that we no longer process your personal data for particular purposes, or object to our use of your personal data or the way in which we process it;
- the right, in certain circumstances, to transfer your personal data to another organisation; and
- the right to complain to the Data Protection Commissioner.
12. Fexco Data Protection Contact
If you have any queries in relation to this recruitment data privacy notice, or if you have any concerns as to how your personal data is processed, contact the relevant Data Protection contact:
Address: Fexco, Data Protection Team, Fexco Centre, Iveragh Road, Killorglin, Co. Kerry, Ireland
Phone: +353 66 9761258
If you are not happy with how we have processed your personal data or handled your data protection rights, you can complain to the Data Protection Commission by contacting them below:
Data Protection Commission,
Co. Laois, R32 AP23
Telephone: +353 761 104800
LoCall: 1890 252231