A) PRIVACY NOTICE – INTRODUCTION
Origina are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and the Texas State personal act privacy protection law. Origina have implemented this privacy notice to inform US job applicants of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to job applicants who are not successful in their application and/or have not been employed by Origina.
B) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we 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 which is found to be inaccurate will be rectified or erased without delay
- 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 unauthorized or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organization measures
- we comply with the relevant GDPR procedures for international transferring of personal data
C) TYPES OF DATA HELD
We keep several categories of personal data on our job applicants in order to carry out effective and efficient processes. We keep this data in a recruitment system for each applicant and we also hold the data within our computer systems, for example, emails.
We collect various types of data, such as:
- personal details such as name, address, phone number, email address
- your photograph (If submitted as part of your resume/application)
- your gender, civil status, information of any disability you have or other medical information
- right to work documentation
- information gathered via the recruitment process such as that entered into a resume or included in a resume cover letter
- references from former employers
- details on your education and employment history
- background check and verification information
- information relating to your potential employment with us, including:
- job title and job descriptions
- existing salary or salary requirements
- interview notes
- information regarding terms and conditions of employment for the role which you are applying
D) COLLECTING YOUR DATA
You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Personal data is kept in personnel files or within the organization’s HR and IT systems.
E) BASIS FOR PROCESSING
The laws on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the recruitment process.
- The information below categorizes the types of data processing we undertake and the lawful basis we rely on.
- To assess your suitability for the position that you applied for or any other position that we may consider you for
- To communicate with you about the recruitment process and your application status
- To conduct background checks and verification services as permitted by law and as necessary for the position that you applied for or any other position that we may consider you for
- To comply with our legal obligations, such as verifying your right to work in the USA or reporting to tax authorities
- To protect our legitimate interests, such as ensuring the security of our systems and premises, preventing fraud or misconduct, defending or asserting legal claims, or conducting audits
- To comply with your requests or consent, such as contacting your references or providing you with reasonable accommodations
We will only collect and use your personal data if we have a valid legal basis for doing so. The legal bases that we rely on are:
- Your consent. You have the right to withdraw your consent at any time by contacting us [email protected]
- Our legitimate interests or those of a third party. We will always balance our interests against your rights and interests
- A contract or pre-contractual measures. This applies if we enter into an employment contract with you or take steps to do so at your request
- A legal obligation. This applies if we are required by law to collect or use your personal data
We carry out processing activities using relevant special category data. Special categories of data are processed when there is a legal basis to do so.
Special categories of data are data relating to your:
- health
- sex life
- sexual orientation
- race
- ethnic origin
- political opinion
- religion
- trade union membership
- genetic and biometric data
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.
G) WHO WE SHARE YOUR DATA WITH
Employees within the organization who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. Job applicant data is only shared with third parties for the purposes of recruitment for roles within Origina.
As part of the recruitment process Origina may utilize the services of third-party organizations for the purpose of performing background checks when it is appropriate given the nature of the role you are applying for and where the law permits us.
H) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
Origina take appropriate technical and organizational measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction.
These measures include:
- Using passwords, firewalls, antivirus software, and other security tools to protect our systems and networks
- Limiting access to your personal data to those who need it for the purposes that we have disclosed to you
- Training our staff on confidentiality policies and procedures
- Conducting regular technical reviews of our data protection practices and systems
- Origina maintain an Information Security Management System via our ISO27001 certification which is subject to external audit by an independent third party
- Conducting regular reviews of our third parties’ data protection practices and systems including location to ensure that the country where data is hosted has been deemed to provide an adequate level of protection by the European Commission
I) RETENTION PERIODS
We only keep your data for as long as we need it for. Job application information (Application forms and interview notes) of unsuccessful applicants will be deleted within 18 months of the open position being filled, other than for good reason, e.g., pending litigation.
J) AUTOMATED DECISION MAKING
Automated decision-making means making decision about you using no human involvement e.g. using computerized filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement).
K) JOB APPLICANTS’ RIGHTS
You have the following rights in relation to the personal data we hold on you:
- The right to access. You have the right to request a copy of the personal data that we hold about you and to check that we are processing it lawfully
- The right to rectification. You have the right to request that we correct any inaccurate or incomplete personal data that we hold about you
- The right to erasure. You have the right to request that we delete or remove your personal data from our systems when there is no longer a legal basis for us to keep it
- The right to restriction. You have the right to request that we limit the processing of your personal data in certain circumstances, such as when you contest its accuracy or object to its processing
- The right to data portability. You have the right to request that we transfer your personal data to another organization or to you in a structured, commonly used, and machine-readable format
- The right to object. You have the right to object to our processing of your personal data based on our legitimate interests or those of a third party. You also have the right to object to our processing of your personal data for direct marketing purposes
- The right not to be subject to automated decision-making. You have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, that produces legal effects or significantly affects you
L) CONSENT
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
M) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with Origina’s Data Protection Officer. [email protected]
Alternatively, you may contact the Ireland Data Protection Commission, known as the ‘DPC’ using the details at the following link: Your Data | Data Protection Commissioner. You may also seek recourse through the appropriate judicial authorities, either in Ireland or in the State of Texas.
N) DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is: [email protected]
