We know that your personal information is important to you and we are committed to ensuring it is kept secure and used carefully.  Below you will find a short summary of how and why we collect your data, who we share it with, and what we’re doing to make sure your data is safe and secure.  You will also find details of your privacy rights.

This is the privacy policy of Emerald Contact Centre (ECC).  If we change our privacy policy, we will notify you of those changes here.

Our Website (http://emeraldcontactcentre.ie/) may include hyperlinks to other websites that are not operated or controlled by us. This privacy policy only applies to our Website and we are not responsible for the content or the privacy practices of third party websites.

If you want to skip to a particular section of this policy, please click on the relevant link below.

What does Emerald Contact Centre do?

What personal information does Emerald Contact Centre collect and why?

Who does Emerald Contact Centre share my personal information with?

Legal basis for processing personal information

How does Emerald Contact Centre keep my personal information secure?

International data transfers

Data retention

Your data protection rights

Updates to this privacy policy

How to contact us


What does Emerald Contact Centre do?

Emerald Contact Centre provides customer care for a range of European and US based clients.

What personal information does Emerald Contact Centre collect and why?

We collect information that visitors to our website provide to us when they use our “Contact Us” page to  submit their curriculum vitae to apply for vacancies advertised on our Website.  All such information is held on secure servers.

We only use personal data you have given us or that we have collected from you when you visit our Website. We do not obtain personal information from or sell it to third parties.  We sometimes share your personal information with third parties, but only to personalise and improve your experience with us. We never release your personal information to others for their mailing or marketing purposes.

The personal information that we may collect about you broadly falls into two categories:

  • Information that you provide

We may ask you to provide personal information in order to provide our services and correspond with you.  This includes asking you to provide your contact details to respond to any queries you may have about our company or employment opportunities.

The personal information you are asked to provide, and the reasons why you are being asked to provide it, will be made clear to you at the point you are asked to provide it.

  • Information that we collect automatically

When you visit our Website and use our Contact Us forms, we may collect certain information automatically from your device.

The data we collect may include information like your IP address, device type, unique device identification numbers, browser-type, and other technical information.  We may also collect information about how your device has interacted with our Website or order form, including the pages accessed and links clicked.

We collect this information so we can better understand the visitors who come to our Website and what content may be of interest to them.  Using the information allows us to improve the quality and relevance of our Website and services.

Some of this information may be collected using cookies and similar technology.  This is explained in more detail in our Cookie Policy.

Who does Emerald Contact Centre share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies who provide data processing services to us, for example, enhancing the security of our Website, or who process personal information for the purposes described in this privacy policy or when we collect your personal information, including for recruitment. Those companies are Agora Integrated Marketing, Agora Publishing Services Ireland, Threefold, International Living and Pathfinder International Inc.
  • to any competent law enforcement body, regulatory, government agency, or similar other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, or (ii) to exercise, establish or defend our legal rights; and
  • to any other person with your consent.


Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the information concerned and the context in which we collect it.

We will normally collect personal information from you where:

  • we need the personal information in order to take steps to enter into a contract with you, (for example, the personal information you have included in your curriculum vitae); or
  • the processing is in our legitimate interests and not overridden by your rights; or
  • we have your consent to do so (for example, respond to your queries about Woodlock House or give you further details about a job opportunity);

If we collect and use your personal information in reliance on our legitimate interests, this will normally be to operate and improve our services, Website, and communications.  It would also include responding to your queries or detecting or preventing illegal activities.  We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

How does Emerald Contact Centre keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.  Where we share data with third parties, we ensure that your data will be kept secure and will not be provided or sold to another party.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, group companies and third party service providers operate in the United States and elsewhere around the world.  This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the European Economic Area in accordance with European Union data protection law. We have implemented similar appropriate safeguards with our third party service providers.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service or to comply with applicable legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below (http://emeraldcontactcentre.ie/connect/). We may not be able to delete your personal information if we have to retain it in order to comply with our legal obligations, to perform a task carried out in the public interest, to establish, exercise or defend any legal claims or to exercise our right of freedom of expression and information.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below (http://emeraldcontactcentre.ie/connect/).
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below (http://emeraldcontactcentre.ie/connect/).
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


Updates to this privacy policy

We may update this privacy policy from time to time in response to changing legal, technical or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material privacy policy changes if and where this is required by applicable data protection laws.

You can see when this privacy policy was last updated by checking the “last updated” date displayed at the top of this privacy policy.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us by using the Contact Us link on our Website (http://emeraldcontactcentre.ie/connect/).

The data controller of your personal information is Emerald Contact Centre Ltd.

 

Privacy notice for candidates

Emerald Contact Centre is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you as part of the recruitment process.

 

It is important that you read this notice so that you are aware of how and why we are using your data.

 

Data Protection Principles

We comply with all relevant data protection principles, and this means the personal data we hold about you is:

  1. Used lawfully, fairly and in a transparent way;
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  3. Relevant to the purposes we have told you about and limited only to those purposes;
  4. Accurate and kept up to date;
  5. Kept only as long as necessary for the purposes we have told you about; and
  6. Kept securely.

 

What information we hold about you, and why

 

Emerald Contact Centre is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

We collect personal data about candidates through the recruitment process, either directly from them or through recruitment agencies.  We may sometimes collect additional information from third parties including former employers or other background check agencies where required.

In order to assess your application and communicate with you about the recruitment process, we may collect and hold about you the following categories of personal data:

  • Contact details such as name, title, address, telephone number and email address;
  • CV or cover letters or any other supplementary document provided during the application process;
  • Information about your right to work in the country;
  • Information regarding your work experience, qualifications and education, or employment references;
  • The results of any personality profiling assessment that we may carry out as part of the recruitment process; and
  • Criminal convictions and offences (where the nature of the role requires this).

We only use your personal data if the law allows us to, and most commonly, for the following purposes:

  1. In order to take steps to enter into a contract with you – if your application is successful, we will retain that personal data in order to perform that contract;
  2. Where we need to comply with a legal obligation (for example, we are required to check a successful candidate’s eligibility to work in the country before employment starts);
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Processing candidates’ data allows us to manage the recruitment process, assess a candidate’s suitability for employment and make the appropriate recruitment decision; and
  4. To respond to and defend against legal claims.

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide information which is necessary for us to consider your application (such as evidence of qualifications or work history) when requested, we may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the country and satisfactory references.

We will only use your personal data for the purposes for which we collected it unless we reasonably believe we need to use it for another reason and that reason is compatible with the original purpose.  We will notify you if that is the case and explain the legal basis which allows us to use the data.

Please note we may process personal data without your knowledge or consent where this is required by law or other regulations.

Data Sharing

Your application will be assessed by members of the People Team, relevant hiring managers and interviewers involved in the recruitment process. We may also have to share your data with third parties, including third-party service providers (e.g. work agencies) and other entities in the Agora Group.

  1. Third parties

We may share your information with third party service providers (such as recruitment agencies or applicant tracking software providers) which provide technical and support services in relation to the recruitment process.

We require third parties to respect the security of your data and to treat it in accordance with the law. They will not share your personal information with any organisation apart from us and they will hold it securely and retain it for the period we instruct them to.

We may also share your personal information with a regulator or otherwise to comply with the law.

  1. Other Agora Companies

We may share personal data with other Agora entities as part of recruitment support, regular reporting, reorganisations and for system maintenance, support, and hosting of data.  In certain circumstances and when there is a genuine business purpose, this may include members of People Teams in other Agora entities assisting with the application process.

To ensure personal data is adequately protected, data transfer agreements are in place with the US Agora entities.

Your personal data during the recruitment process

Please keep us informed of changes to your personal data so we can ensure it is current and accurate.

You can request access to your personal data, that it be corrected (if it is incomplete or inaccurate), ask us to delete it (where there is no good reason for us continuing to have it), object to its processing where we are relying on a legitimate interest (and your legitimate interest overrides ours), request restrictions on the processing or that it be transferred to another party.

If you are asked to provide your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent at any time by writing to a member of the People Team.  Once we are aware you have withdrawn consent, we will no longer process your data for those purposes unless we have another legitimate basis for doing so.

Data Retention

If your application is unsuccessful, we will retain your personal information for [6] months after we have communicated our decision to you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

If your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment.

Automated Decision Making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. Should we ever use automated decision-making that will have a significant impact on you, we will let you know in advance and give you an opportunity to object.

If you would like to exercise any of your rights or if you have any questions about this notice or our processing of your data more generally, please contact a member of the People Team.  If you believe we have not complied with our data protection obligations you can also lodge a complaint with the local data protection supervisory authority.

Last updated 1 October 2019

 


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