Cpl Healthcare Privacy Policy

1. Purpose

The purpose of this Privacy Notice is to outline how we collect, process and share personal data we hold about you. This Privacy Notice will outline the types of personal data we process about you and the legal basis we rely on to do so.

Cpl Healthcare are committed to protecting and respecting your privacy. We wish to be transparent on how we collect, store and share personal data and to ensure that you understand your rights under the General Data Protection Regulation (“GDPR”).

In this Privacy Notice, we outline:

1.1 Company Information

Cpl Healthcare is an international provider of healthcare staffing services with 18 years of experience in the healthcare industry. Cpl Healthcare supports both public and private sector organisations by providing staffing in nursing, medical, allied health professions, healthcare assistants and social care workers.

If you wish to locate further information on Cpl Healthcare and the services we offer, you can find this on our website here.

1.2 Legislation

All personal data we gather will be “processed” in accordance with all applicable data protection laws and principles, including the General Data Protection Regulation, the Data Protection Act 2018 and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“ePrivacy Directive”).

1.3 Queries and Complaints

If you are unhappy with the way we have handled your personal data and wish to complain, or if you would like further information about the way your personal data will be used, please contact us at the below:

Data Protection Officer

Cpl Healthcare

Ground Floor, One Haddington Buildings, Haddington Road, Dublin 4, D04 X4C9, Ireland

Telephone: +353 1 614 6000

Email: dataprivacy@cpl.com

If you are unsatisfied with our use of your personal data or our response to any requests by you to exercise any of your rights, then you have the right to complain to the Data Protection Commission. See contact details below:

Data Protection Commission

21 Fitzwilliam Square South

Dublin 2

D02 RD28

Ireland

Email: info@dataprotection.ie

Telephone: +353 57 868 4800 / +353 761 104 800

1.4 How do we collect your personal data?

We collect personal data to enable the provision of services to support the Cpl Healthcare purpose. The following non-exhaustive methods of data collection are an indication of ways in which we may obtain your information:

It is important that the personal data you provide to us is up to date and accurate. As outlined in Section 7.2 of this notice, if the personal data we hold about you is inaccurate or incomplete, please contact us and we will update your data.

2. What personal data do we collect?

In order to provide our services, Cpl Healthcare needs to collect various types of personal data. The type of personal data we collect on you will vary depending on the nature of our relationship with you. Below we have outlined a non-exhaustive list of the types of data we may collect and our purpose for collecting that data.

Process	Types of Data Collected
Register Applicant Interest	Name, date of birth, contact details, CVs, qualifications, employment history, education history, training history
Recruitment & Selection	Name, date of birth, contact details, address, email address, passport, identification copy, PPS number, CVs, qualifications, employment history, education history, training history, driver license, professional body membership, interview notes
Background / Compliance Checks	Garda vetting, overseas police clearance, visa checks, references
Direct Marketing	Name, contact details
Occupational Health Screening	Name, contact details, medical information
Client Training Services	Name, contact details, role / position, education history, qualifications

3. How do we use your personal data?

The main purpose for which Cpl Healthcare processes your personal data is to provide a service to you, or otherwise manage our relationship with you. The following section provides more detail on the purposes for which we process your personal data and the legal basis by which we do this.

Process	Description	Lawful Basis for Processing
Register Applicant Interest	To register prospective candidates’ application details in our candidate database.	The use of this data is necessary for the performance of a contract between a prospective candidate and Cpl.
Recruitment & Selection	To select and identify the candidate most suitable for a given role.	The use of this data is necessary for the performance of a contract between our client and the candidate or between Cpl and candidate.
Background / Compliance Checks	To verify that the candidate is qualified and eligible for the role they have applied for.	The use of this data is necessary to comply with legal obligations to which Cpl is subject.
Direct Marketing	To keep candidates / prospective candidates up to date on job opportunities.	The use of this data is done with the consent of the data subject.
Occupational Health Screening	To provide occupational health assessments / screenings for staff referred by our clients.	The use of this data is done with the consent of the data subject.
Client Training Services	To deliver training services to client staff and maintain a record of who received that training.	The use of this data is necessary for the performance of a contract between our client and their staff.

4. How long do we retain your personal data?

We only keep your personal data for as long as is necessary for the purpose for which it was originally obtained, and / or in accordance with any requirements imposed by the law. This means that the period of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period of personal data, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process your personal data and any legal requirements to retain your data. The table below outlines a general summary of our retention periods.

Data Type	Retention Period
Applicant Data	Internal Recruitment – 7 years post-employment (successful candidate), 3 years (unsuccessful candidate) Client Recruitment – 7 years from last contact with candidate
Recruitment & Selection Data	Internal Recruitment – 7 years post-employment (successful candidate), 3 years (unsuccessful candidate) Client Recruitment – 7 years from last contact with candidate
Background / Compliance Checks	Internal Recruitment – 7 years post-employment (successful candidate), 3 years (unsuccessful candidate) Client Recruitment – 7 years from last contact with candidate
Direct Marketing	Until data subject withdraws consent
Occupational Health Screening Data	Duration of employment plus 7 years post-employment
Client Training Services Data	7 years

5. Who do we share your personal data with?

We may disclose your personal information to outside organisation. Below is a list of the categories of recipients we share your personal data (as outlined above) with:

Cpl Group

Cpl Healthcare is part of the Cpl Group of companies. Cpl Healthcare may share your application details and contact information with other companies in the Cpl Group to allow them to contact you where they have open roles, we believe you would be suitable for based on your experience. More information on the Cpl Group can be found here.

Your Representatives

Any party you have given us permission to speak to (such as a relative, friend or legal advisor) and other people or companies associated with you that are authorised by you to act on your behalf.

Our Representatives/ Service Providers

Our employees, agents and contractors including companies that provide services in relation to telecommunications and postage, data storage, document production and destruction, IT and IT security, or design.

Government, Statutory and Regulatory Bodies

Where required by law, state regulators and authorities such as the Data Protection Commission, the Revenue Commissioners, and Law Enforcement Agencies such as An Garda Síochána.

We may also disclose your personal data to the following recipients or categories of recipients:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Cpl Healthcare or substantially all of its business or assets are acquired or transferred to a third party whether in the event of a merger, reorganisation, transfer of undertakings, receivership, liquidation or other winding up or any other similar circumstances, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR or other agreements.
To protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organisations for the maintenance and security of the site and services.

6. International Transfers

On occasion, we may need to transmit your personal data outside of the European Economic Area. In these circumstances, we will ensure that the transfer complies with our data protection obligations, and we will ensure that the transfer agreement is based on an approved transfer mechanism, such as the European Commission’s standard contractual clauses or an adequacy decision.

7. Data Subject Rights

As a data subject, you will have the following rights in relation to the processing of your personal data. Please note that these rights are not absolute, and restrictions may apply in certain situations.

Please send all requests to dataprivacy@cpl.com with as much detail as possible about your requirements to allow us to deal with your request efficiently. Before fulfilling your request, we may ask you to provide identification to enable us to verify your identity.

Upon receipt of a valid request, we will have one calendar month to respond to your request, with the possibility of extending by two further months. If we require more time to deal with your request, we will notify you of the delay and the reasons behind it within 30 days of the receipt of the request. If we refuse your request, we will also notify you within 30 days of the receipt of the request accompanied by the reasons for the refusal.

You are entitled to contact the Data Protection Commission if we refuse your request.

7.1 Right of Access

You have the right to know what personal data we hold about you, why we hold the data and how we process your personal data

When submitting your request, please provide us with information to help us verify your identity and as much detail as possible to help us identify the information you wish to access (i.e. date range, subject of the request).

If the request is submitted by a third party (such as a solicitor) on your behalf, the request will be required to include written authorisation from you for the provision of specific data to the third party.

Please note that an access request is free of charge, however, where we determine a request to be unjustified or excessive, we may charge you a reasonable fee.

7.2 Right to Rectification

You have a right to request that the personal data held in relation to you is up to date and accurate.

Where information is inaccurate or incomplete, we encourage you to contact us to have this information rectified. Upon receipt of your request, we will ensure that the personal data is rectified and as up to date as is reasonably possible.

7.3 Right to Erasure

You have the right to seek the erasure of personal data by on you in the following circumstances:

Personal data is no longer required for the purposes for which it was obtained.
Where the use of the data is only lawful based on consent, you withdraw consent to the processing and no other lawful basis exists.
The personal data is being used unlawfully.
You object to the use of your personal data and there are no overriding legitimate grounds for the use of the data.
Your personal data requires deletion in line with legal requirements.

However, we will be unable to fulfil an erasure request if the personal data is required for any of the below activities:

Compliance with a legal obligation, such as the performance of a contract or compliance with certain legislation.
For the performance of a task carried out in the public interest.
Archiving, research or statistical purposes in the public interest.
The establishment, exercise or defence of legal claims.

7.4 Right to Restriction

You have the right to restrict the extent for which your personal data is being used by us in circumstances where:

You believe the personal data is not accurate (restriction period will exist until we update your information).
The processing of personal data is unlawful, but you wish to restrict the use of the data rather than erase it.
Where personal data is no longer required by us, but you require the retention of the data for the establishment, exercise, or defence of a legal claim.
You have a pending objection to the future use of your personal data.

When the use of your data has been restricted, your personal data will only be further used:

With your consent.
For the establishment, exercise or defence of legal claims.
For the protection of the rights of other people.
For reasons important to the public interest, such as for the protecting against cross-border threats or ensuring high standards of quality and safety of health care.

We will contact you to confirm where the request for restriction is fulfilled and will only lift the restriction after we have informed you that we are doing so.

7.5 Right to Data Portability

You have the right to the provision of all personal data, which you provided to us, provided to you in a structured, commonly used and machine-readable format where:

You may also request that we send this personal data to another legal entity where technically feasible.

We will only refuse such a request if the data being requested may adversely affect the rights and freedoms of others.

7.6 Right to Object

You have the right to object to the further use of your personal data where:

If you wish to object to the use of your data, please contact us with your request. We will then stop using the data or personal data unless it is required for legal proceedings.

7.7 Right to Withdraw Consent

Where we are processing your personal data based on your consent, you will have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact us with your request. We will then stop the further processing of your personal data.

7.8 Right to Object to Automated Decision Making

You have a right not to be subject to a decision based solely on automated processing or profiling, where such decisions would have a legal effect or significant impact on you.

Currently, we do not employ any systems which use automated decision making or profiling on data relating to our candidates.

Where we (or one of our third-party processors) use profiling, which produces legal effects for you or otherwise significantly affects you, you will have the right to object to such processing.

8. Marketing

Cpl Healthcare may contact you with information about products and services of ours that we think may be of interest to you.

You have the right at any time to stop Cpl Healthcare from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, you can use the unsubscribe button in the footer of every marketing communication or by contacting dataprivacy@cpl.com.

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