Privacy Policy

DATA PRIVACY POLICY

1. General Statement

Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

Our reputation as a recruiter is reliant on the trust of people we work with, and consequently the effective and professional use of the information you provide us is paramount.

2. Collection and use of Personal Data – By Application

Oganly Careers International (OCI) collects your Personal Data when you send us your CV and personal details via email. The information you provide us this way is not made available to any third parties without your permission and is only used by Oganly Careers International in line with the purpose for which you provided it. By sending your personal data to Oganly Careers International, you are consenting to us:

To collect, store and process your Personal Data for recruitment purposes.
To disclose your Personal Data to external parties.

3. Important definitions in this notice

"You" are a candidate, potential candidate, consultant, client contact or contact at any other organisation involved in the introduction and/or supply of a candidate's services, such as a contact at a recruitment process outsourcing company, personal service company or umbrella company.

References in this notice to:

"hirer" and "client" mean any hiring organisation to which we offer and/or provide temporary and/or permanent recruitment services;
"client contact" means a responsible owner at a client;
"candidate" means a potential or actual candidate for a permanent or temporary role;
"consultant" means a person whose services are supplied via Oganly Careers International to work on temporary assignments with a hirer;
"referee and/or emergency contact" means a person whose personal details a candidate provides for the purposes of providing a reference or acting as their emergency contact.

Specifically, this privacy notice provides you with details about the personal information we collect and hold about you, how we use your personal information and your rights regarding your personal information.

It does not cover any use of your personal information by:

an actual or potential employer or hirer;
an umbrella company;
or any other organisation involved in the supply of your services via us to a hirer, to whom we may provide your personal information as part of the recruitment process.

That use will be governed by the relevant employer's or hirer's privacy policy.

4. Where does Oganly Careers International collect data from?

This privacy notice applies to the collection, storage and use of personal information collected by Oganly Careers International ("we" or "us"):

via our website at https://www.oganlycareers.com/ or any other website operated by us (the "Site");
or as a result of you responding to an advertisement posted by us on a job board, online CV library or via social media;
or as a result of us matching your CV, as uploaded by you onto a job board, online CV library or a social media site, to a vacancy we are seeking to fill for one of our clients;
or as a result of personal recommendations; or from company websites;
or from your business card;
or in the course of us providing recruitment, resourcing, outsourcing or consultancy services to you ("Services")

5. What information do we collect on Candidates?

The personal information we collect about you where "you" are a candidate or placed consultant.

Oganly Careers International aims to collect the minimum data it needs to perform its role.

Typically, this is name, address, job title and contact details. In addition, if you are a candidate being considered for a role it may also include your CV / resume as well as other details about your skills and experience.

We may also collect other personally identifiable data, for instance we may be engaged in equal opportunity monitoring or need information to complete a contract for you or our client.

This data can include age, identity card number, passport number, driver licence number, address, email address, user ID and passwords, gender, date of birth, marital status, occupation, income range, bank account details, financial information, contact information such as telephone, mobile, nationality, personal website or social media links or other data which may be required by local regulations.

Referees and emergency contacts: We collect basic contact details (such as name, title, address, email and tel) so that we can contact you for a reference or as an emergency contact for one of our candidates/or contractors.

6. What information do we collect on Client contacts?

Client contacts: the personal information we collect about you where "you" are a contact at one of our clients or at an MSP, umbrella company or personal service company involved in the supply of a person's services to a hirer.

We need to collect information about you as an essential part of providing our Services.

We may collect personal information about you when:

we contact you with a view to providing Services to you;
or you email us expressing an interest in working with us;
you provide us with your business card or other information provided to us, given to our employees at sales and marketing events;
you post information or advertisements on job boards or social media websites;
we provide Services to you as an actual or a potential hirer of your services;
or we complete contractual documentation relevant to the Services, we will usually collect the following information from or about you: your name; your postal address;
your phone and email details; details of your role, title and responsibilities within your organisation;
where "you" are a client:any opinion or feedback you share with us regarding a candidate or consultant;
details of any queries you raise with us regarding the Services;
details of any recruitment and/or resourcing requirements or plans you share with us.

7. What is our lawful basis for processing your personal data?

We use the data we gather to perform a number of tasks, including:

placement of a candidate into a particular employment role as defined by our clients;
or the provision of resourcing, outsourcing or consultancy maintaining our records of our candidates, clients and contacts;
conducting marketing, profiling and business development activities as well as market research and statistical analysis regarding our products and/or services;
complying with any legal or regulatory requirements and to make the necessary disclosure under the requirements of any applicable law, regulation, direction, court order, guideline, circular or code which are applicable to us for the prevention of crime.

8. Reporting requirements to clients where we offer Managed Services (RPO / MSP)

Client contacts: We use the information collected from clients to ensure that we provide business services to you. This will involve identifying candidates that will meet your requirements or providing other business services from our portfolio.

Suppliers: we use the data collected to ensure the business arrangements between us run smoothly.

Referees and emergency contacts: we use the data collected to contact you for a reference or to contact you as a candidate's emergency contact in the event of an accident or other emergency.

We consider that it is necessary for our legitimate interests as a recruitment business to process your personal data.

At different stages in the recruitment processes we also have other lawful grounds for processing your data such as compliance with our legal obligations and where it is necessary for the performance of contracts related to the recruitment process.

We think you will have an expectation that if you are looking for employment or have posted your CV or other professional information on a job board or professional networking site, that you are happy for us to collect and use your personal data to provide our recruitment services to you and to share that information with prospective employers.

During the recruitment process the client may want additional information (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, where appropriate and in accordance with local laws.

We may also need to use your personal information for internal administrative purposes, such as contract administration, payroll and invoicing.

We also have our own obligations under law, and we may be required to share your data in connection with those legal requirements. Where we are required by law to obtain your consent to the processing of your personal data, we will obtain it.

9. ‍Client contacts and other third parties involved in the supply of resourcing services (e.g. umbrella companies and personal service companies)

We collect, store and use your name and contact details for our legitimate interests, so that we can: send you the details of candidates and consultants and contact you about our Services; and maintain our business relationship with you.

This allows you to be contacted to receive and administer any Services which you or your organisation has requested.

The exchange of personal data of our candidates and client contacts is an essential part of what we do as a recruitment business and, as such, it is in our legitimate interests to process your data for such purposes.

In the case of contacts at umbrella companies and personal service companies this allows you to be contacted to receive, on behalf of your employer, details of current and future assignments, related timesheet data and payment details. We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.

10. All users of the Site and our Services

We collect, store and use your personal information for the following purposes:

to make the Site available to you; and to provide any Services that you request.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable to make them operate more effectively.

In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.

11. How do we share your personal information and who do we share it with?

Your personal data provided to us is processed by Oganly Careers International.
We will ensure that:

access to your personal data is restricted to staff who are required to process such data as part of their job;
only necessary information is released to the relevant employees;
we seek your consent before sharing your details with any prospective employer or user of your services.

Referees: unless you specify otherwise, we may share your information with any of our group companies and client(s) in relation to whose vacancy your reference was given.

We will disclose information under the following circumstances:

Service and Site usage information: When we share anonymous information generated by our Services with our clients.

Third-party service providers: When we share information with third-party service companies for them to facilitate and support us in the provision of the Services.

This includes:

IT support service providers;
providers of credit reference, vetting and screening services;
payment processors and software providers;

These organisations are appointed by Oganly Careers International as data processors and authorised to use your personal information only as necessary to provide the relevant services to us. These organisations are required to process such information based on our instructions and in accordance with this privacy notice. They do not have any independent right to share this information.

‍Group companies: We provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Site and the Services. These parties are required to process such information based on our instructions and in accordance with this privacy notice. They do not have any independent right to share this information.

Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.

‍Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Recruitment and resourcing services: When we are using your personal information in the context of our recruitment and resourcing services, then we may share your personal information with clients where we believe that you may be appropriate for a particular role or vacancy with that client.

Umbrella companies and personal service companies: When you inform us that you are supplying or intend to supply your services via Ogan Careers International to a client through an umbrella company or personal service company.

Recruitment Process Outsourcing and Managed Service Providers: In certain cases, there may be an organisation such as a managed service provider acting as a gateway for the supply of Services made via Oganly Careers International to the hirer.

Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply.

Where personal information is shared with clients, hirers, umbrella companies, personal services companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.

12. Storing and transferring your data

We want to make sure that your data is stored and transferred in a way which is secure. We will only transfer data outside of the European Economic Area where the recipient is compliant with the data protection legislation and the means of transfer provides appropriate safeguards.

These will include UK or EU approved standard contractual clauses according to Article 46(2)(c) GDPR, or where the country concerned has been found adequate by the European Commission (as applicable) in respect to the levels of data protection, according to Article 45 GDPR.

Please note that where a derogation to the above applies under Article 49 GDPR, you will be informed of this prior to the transfer taking place and will have the opportunity to object to that transfer.

Oganly Careers International is a global company and to effectively provide the best service to our clients we may utilise a business processing outsourcing (BPO) service with our partners in India, Tanzania, Spain and France to help identify candidates for potential roles.

This service helps us to respond more quickly to client services by identifying potential candidates and sending this information back to the responsible consultant.

A data transfer risk assessment has been carried out, and both data processing agreements and standard contractual clauses are in place to govern the secure processing of the Irish/ EU personal data in these instances.

We may send your information between Oganly Careers International business partner entities which may exist outside of Europe, to overseas clients or to clients within your country who may in turn transfer your data internationally. Appropriate safeguards and legal requirements will always be in place to govern the secure processing of your personal data.

The data may also be stored on cloud-based storage for parts of our overall business process. Please be aware that countries which are outside the European Economic Area may not offer the same level of legal protection for your personal information as under EU/UK law.

13. Personal information, cookies and websites

Our website will only allow you to submit your information via email.

All our 3rd party suppliers have been vetted to ensure that they will meet our own privacy and security standards in the collection and processing of your personal information.

Our website may link or direct you to other websites or external content which are not within our control. Links to other websites may be provided for your convenience and information.

While we will use our best endeavour to ensure that we link or direct you only to websites that share our privacy and security standards, we are not in the position to guarantee the same and we will not be responsible for the protection and privacy of any personal data which you provide on those websites.

These sites have their own privacy notice in place, and we recommend you review these if you visit any linked website. You should therefore exercise caution including reviewing the privacy policy of those websites before disclosing any personal data.

14. How we safeguard your personal data

Oganly Careers International is passionate about protecting your information. To this end we have put in place appropriate measures that are designed to prevent unauthorised access to and misuse of your personal data.

These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately by emailing info@oganlycareers.com

15. Data retention

The period for which data is retained in each circumstance is determined by the balanced interests of the company and the data subjects concerned. If personal data needs to be retained to fulfil the documented business interests of the company, and that interest would align with the interests of the data subject, then we will continue to retain for a reasonable period.

However, we do not keep data for any longer than 5 years. For most people where we have limited contact it will be for a maximum of 2 years from the date of last contact with us. Where we have engaged with you more extensively, for instance we have worked with you as a client, or interviewed / placed you as a candidate, we may retain data longer.

We will delete personal data at the end of the legal retention period except where we need to keep any personal information to comply with our contractual (i.e. reporting requirements) or other legal obligations, resolve disputes, or enforce our agreements.

‍Emails
‍We have legal obligations to retain emails as we operate across a number of jurisdictions.

‍16. Psychometric Testing Candidates

If you have signed up to carry out a test as part of a recruitment process, our staff may provide you with additional information where we have clients who require the retention of personal data for longer periods for management intelligence purposes. This period can be up to 15 years, depending on the specific contractual obligations we have. We will ask for your consent to retain this information and you will have the opportunity to withdraw that consent easily at any time. This will be explained in detail to you at the point the data is first obtained.

For more information on our data retention policy please contact info@oganlycareers.com

17. Your rights, complaints, questions and suggestions

Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at info@oganlycareers.com at any time.

Complaints

Oganly Careers International tries to meet the highest standards when collecting and using personal information. We take any complaints we receive about this very seriously. If you wish to complain about our policies or procedures, please contact our Data Protection Officer via info@oganlycareers.com

Marketing activities

Where we have previously engaged with you (for example where you have submitted an application or CV to us) or where you have posted your details on a job board, we may have obtained your email address and retained it according to our legitimate business interests as explained above.

Having obtained your email address during an aforementioned recent course of business, we may periodically send you related information that we think you will find interesting or to ask for your expertise in completing a survey.

We may also send you relevant information to market our full range of services, or send you details of networking and client events and information about the industry sectors we think may be of interest to you.

If you do not wish to receive these communications you can unsubscribe by clicking on the relevant link on marketing emails, or contact info@oganlycareers.com requesting to be opted-out of receiving marketing communications.

Unsubscribing from job alerts

You may request to unsubscribe from job alerts and marketing material at any time. If you wish to contact us with respect to the above matters, please email us at info@oganlycareers.com

Notwithstanding the above, your rights as a data subject under the GDPR provide that you can ask for all your personal data to be removed (as explained above) at any time.

18. ‍Automated Decision-Making:

Oganly Careers International does not utilise any form of automated profiling currently. All our recruitment activities involve human decision-making during the process. This may change in the future if we implement automated technologies or machine learning, but we will only do so where appropriate and in accordance with local laws and regulations. Any changes to this notice will be notified as set out below.

‍Profiling:
Oganly Careers International utilises psychometric testing providers to conduct tests for our clients. Candidates sign into the testing provider and carry out this test. Specialists within Oganly Careers will review the results of the tests and conduct what may be described in the GDPR as profiling on the personal data. You have the right to object to profiling and can do this by refusing or withdrawing your consent to processing in the testing process at any time.

‍Third party sites:
‍This website contains links to other websites operated by third parties. Please note that this privacy notice applies only to the personal information that we collect through the Site or the Services, and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

19. ‍Changes to this Privacy Notice

‍This privacy notice was updated in March 2024.

We will publish changes to this privacy notice from time to time. If significant changes are made to our processing activities, we will take reasonable measures to notify data subjects accordingly.

We may collect personal data when:

you access and browse the Site (including when you submit personal information to us through email);
or you respond to an advert posted by us whether via a job board, LinkedIn or other social networking site;
or we download details uploaded by you onto a job board, LinkedIn or other social networking site in relation to a vacancy we are seeking to fill for one of our clients;
or we download details uploaded by you onto a job board, LinkedIn or other social networking site in connection with our internal market research;
or you contact us by phone, email or otherwise;
or we provide Services to you or to an actual or a potential hirer of your services;
or we contact you with a view to providing Services to you;
or we provide on-boarding services to a hirer of your services, we may collect the following information from or about you: your name; your postal address; your phone and email details; your bank details a copy of your passport details including your passport photograph; your current and previous employment/work details, including job title and employer; recruitment-specific details such as any professional certifications, education and qualifications, skills, career history, salary range, right to work status, citizenship, referee details and any other information relevant or required by law to enable us to provide the Services;
any other information which you include in your CV or a completed application form;
any information which has been published or made available on a social media profile or job board (whether by you or a third party), or in any news media;
details of your umbrella company or personal service company;
the contract for services we hold with your umbrella company or personal service company relating to the work you do or will do for our client, including timesheet data and charge rates relating to the work you perform under that contract;
details of your referees and emergency contacts references from third parties such as previous employers and nominated referees;
the results of pre-employment screening or vetting checks which we are asked or required to undertake in relation to you (including the results of any Disclosure and Barring checks and any information you provide relating to current and/or spent criminal convictions carried out on behalf of the hirer during the onboarding process);
any email communications, including attachments, which you send to us the results of right to work checks.

You can update your CV or personal data at any time by forwarding a copy to info@oganlycareers.com

20. Right to erasure

If you have shared your Personal Data with Oganly Careers International including your CV/Resume, and personal details and you no longer consent to Oganly Careers International processing your Personal Data, please contact us in writing at info@oganlycareers.com and we will immediately remove your Personal Data from our system.

21. Dealing with the Office of the Data Protection Commissioner (“ODPC”)

Oganly Careers International has the Data Protection Lead who is responsible for handling all correspondence with the DPC.

Contact

All comments, queries and requests relating to our use of your Personal Data are welcomed and should be addressed to Oganly Careers International

Data Protection Lead.

Email:

info@oganlycareers.com

Address

Oganly Careers International

13 Adelaide Road

D02, P950

Rep of Ireland.