Data Protection Privacy Notice (Recruitment)
This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Who collects the information
Fenergo Limited (‘Company’) is a ‘data controller’ and gathers and uses certain information about you.
Data protection principles
We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection Policy.
About the information we collect and hold
We may collect the following information up to and including the shortlisting stage of the recruitment process:
- Your name and contact details (i.e. address, home and mobile phone numbers, email address);
- Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
- Details of your referees.
We may collect the following information after the shortlisting stage, and before making a final decision to recruit:
- Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
- Information regarding your academic and professional qualifications;
- Information regarding your criminal record
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
- A copy of your driving licence or passport.
- Results of the applicant testing process. This includes contact information, Test Event ID, test results and information contained in any documents uploaded to the Service.
How we collect the information
We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body and via background checks.
We use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. We use Workable to process personal information as a data processor on our behalf. Workable is only entitled to process your personal data in accordance with our instructions.
We use the applicant testing platform HireSelect provided by Criteria Corp that allows candidates to take aptitude, personality and skills tests. Criteria Corp are a data processor in respect of this data. Criteria Corp may share your data with Insight Venture Management, LLC as an independent controller in respect of this personal data. On completion of psychometric assessments, reports are generated with the following information visible to Fenergo:
- Name of candidate;
- Position applied for;
- Summary test score.
Where you apply for a job opening posted by us, these Privacy Notice provisions will apply to our processing of your personal information in addition to our other Privacy Notice which has been provided to you separately or is available on Our Website.
Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.
See the following for further details on how our service providers protect your privacy; https://www.criteriacorp.com/privacy-policy, https://www.ondemandassessment.com/insight/privacy.htm and https://www.workable.com/privacy
Information we collect from other sources
Workable provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
Workable’s technology allows us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way, we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
Why we collect the information and how we use it (our legal basis for processing)
We collect and use this information for the following purposes:
- to take steps to enter into a contract;
- for compliance with a legal obligation;
- for the purposes of our legitimate interests or those of a relevant third party (such as a benefits provider), but only if these are not overridden by your interests, rights or freedoms
- because it is necessary for carrying out obligations or exercising rights in employment law;
- to establish, exercise and/or defend any legal claims that may be brought by or against us in connection with your recruitment.
- to process your data using our service providers based on your consent
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
We may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we progress to assessment stage will be made by our staff. For further information on how Workable protect your data see https://www.workable.com/privacy
We may use Criteria Corp’s technology to aid in progressing candidates through the recruitment process based on suitability assessments. This process involves profiling. Data subjects will be asked to participate in Psychometric Assessments which will help assess, with other considerations, their suitability for a particular role. You have the right to object to profiling and can do this by informing our Recruitment Team that you refuse to participate at [email protected]. Alternatively you can contact our Data Protection Team to exercise your Right to Object under the GDPR, subsequent to participation at [email protected]
For further information on how Criteria Corp (Hireselect) protect your privacy please see https://www.criteriacorp.com/hireselect/insight/privacy
How we may share the information
We may also need to share some of the above categories of personal information with internal parties and may also be required to share with certain external parties.
Your personal information may be shared internally with the following groups:
- HR and Recruitment Teams
- Hiring managers/interview panels
- IT and Facilities Teams (upon successful appointment)
We may also need to share your information with certain external parties:
Where required, to comply with a legal obligation
The information will be subject to Security of Processing measures and the recipient of the information will be bound by confidentiality obligations.
Where information may be held
Information may be held at our offices and third-party agencies, service providers, representatives and agents as described above.
Where we store your personal data in our own systems, it is stored Ireland. In addition, Fenergo uses Workable to assist with our recruitment process. The data we collect using Workable’s services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). For further information, please see https://www.workable.com/privacy
Assessment tools are used as part of our recruitment process. The primary purpose of this information is not to make the hiring decision, but to help validate or challenge the information gathered through the recruitment process. Assessments are utilised to help provide extra information to make more informed decisions. They do not to replace human judgment. The data that collected from you and processed using Criteria Corp’s services may be transferred to, and stored in the USA. For information on how Criteria Corp store and manage data please see https://www.ondemandassessment.com/insight/privacy.htm
This data may also be processed by staff operating outside the EEA who work for us or for one of the appointed data processors. These staff members may be engaged in the recruitment process or the provision of support services.
How long we keep your information
We keep the personal information that we obtain about you during the recruitment process for a period of 24 months. Data will be deleted before this if request by the data subject.
If your application is successful and you become employed by us, we retain your data as detailed in our HR Data Protection Policy which is made available to all staff internally. The retention period under that policy will vary depending on the nature of the information concerned and the purposes for which it is processed.
For further information on how Criteria Corp protect your privacy please see https://www.criteriacorp.com/hireselect/insight/privacy
Your right to object to us processing your information
Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
Please contact our Data Protection Team, who can be contacted at [email protected] if you wish to object in this way.
Your rights to correct and access your information and to ask for it to be erased
Please contact our Data Protection Team, who can be contacted at [email protected] if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our Data Protection Team for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
See the following for further details https://www.criteriacorp.com/privacy-policy and https://www.workable.com/privacy for further information on how service providers protect your privacy.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to Our continued processing of your personal data
- otherwise restrict Our processing of your personal data in certain circumstances
- claim compensation for damages caused by Our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the Data Protection Commissioner: -https://www.dataprotection.ie/sites/default/files/uploads/2018-12/Rights-of-Individuals-under-the-General-Data-Protection-Regulation-04-2018.pdf
How to complain
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. See ‘Contact’ below for contact details. If not, you have the right to contact the Data Protection Commission at https://www.dataprotection.ie/en/contact/how-contact-us for further information about your rights and how to make a formal complaint.
All questions, comments and requests regarding this Privacy Notice should be addressed to the Fenergo Data Protection Team.
Title: Liam McKenna, Data Protection Officer
Address: Fenergo Limited, Castleforbes House, Mayor Street, Dublin 1, D01 A8N0
Phone: +353 01 901 3600 Email: [email protected]