PRIVACY POLICY

This privacy policy gives you information about how Principal Connections collects and uses your personal data.

Controller

Principal Connections is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, Personal Public Service Number (PPSN), photograph, work visa and gender.
  
  
• Career Data includes education, professional qualifications, professional experience, professional memberships, competencies, interests, achievements, motivations, ambitions, remuneration, referees, limited company details, interview notes etc.
  
  
• Contact Data includes billing address, delivery address, email address and telephone numbers.
  
  
• Financial Data includes bank account details.
  
  
• Transaction Data includes details about payments to and from you and other details of services we have provided you with.
  
  
• Technical Data includes internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  
  
• Usage Data includes information about how you interact with and use our website.
  
  
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by corresponding with us in person or online, phone, email, direct message or otherwise. This includes personal data you provide when you:
  • Upload your Personal Data through our website.
  • Email (or direct message) us a copy of your CV, application or any other information.
  • Meet with us in person or online.
  • Enquire via telephone, email, direct message or website.
  • Request marketing to be sent to you.
  • Give us feedback or contact us.
    
    
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://www.principalconnections.ie/cookies for further details.
  
  
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data is collected from analytics providers such as Google.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
  • Identity and Contact Data is collected from publicly available sources.
  • Identity and Contact Data is collected by search information providers such as reference and background checks.

Legal basis The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter or have entered into with our clients.
  
  
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best client or candidate experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  
  
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
  
  
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. Consent can be withdrawn at any time.

Sensitive Personal Data While we do not actively request or seek Sensitive Personal Data, on occasion we may process it, for example religious or philosophical beliefs, race, trade union membership. We will ensure that we only process Sensitive Personal Data if we have explicit consent from you. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You may receive marketing communications from us based on your previous interactions with us and you have not opted out of receiving marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which positions or candidates may be of interest to you so that we can then send you relevant marketing communications.

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

Referrals

If you provide Principal Connections with another person’s Personal Data, you must inform the relevant individual that you are disclosing their details to us, and that Principal Connections will be processing their Personal Data. We will follow up with referees as required and provide them with a copy of this policy.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see https://www.principalconnections.com/cookie-policy/

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• Third Parties such as professional advisors, for example accountants, IT consultants, marketing companies.
• Third Parties such as organisations acting on behalf of Principal Connections or our client’s, for example outsourced - HR advisors, reference / background checking firms, occupational / leadership assessment providers, occupational psychologists, medical / health check practitioners etc, .
• Specific third parties – we share candidates’ personal data with our clients to ensure we provide an effective and reliable service. We only share this personal data when a candidate has provided it to us and has expressed interest in a specific position. We and the client act as Independent Data Controllers.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 share your personal data within Principal Connections. This may involve transferring your data outside the EEA to our offices in the UK. The UK adequacy decision ensures an adequate level of protection for personal data between both jurisdictions. We may also from time to time share your personal data with other member firms of Agilium Worldwide LLC.

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. 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.  

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "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 the personal data that we hold about you. 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 in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Object to processing of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• 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
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.v

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us:

• Email address: [info@principalconnections.ie]
• Postal address: [Bridge Street, Headford, Galway H91 VY54]

You have the right to make a complaint at any time to the Data Protection Commission (DPC). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

Should you wish for your Personal Data to be deleted by Principal Connections, you can e-mail info@principalconnections.ie, providing your name, email and contact details asking for your information to be deleted from our records.

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.