Who are we?
We are Brightwater Selection (Ireland) Limited with company number 286849 and a registered address at 36 Merrion Square, Dublin 2 and Brightwater Selection (Belfast) Limited with company number NI40329 and a registered address at 51-53 Adelaide St., Belfast BT2 8FE (“Brightwater”)
. We are committed to protecting and respecting your privacy.
We provide recruitment consultancy services to individuals and companies.
This policy and any other documents referred to in it sets out the basis on how Brightwater will process any information we collect from you or you provide to us, as a candidate, prospective employee, client or supplier. Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of the General Data Protection Regulation (GDPR) the data controller is Brightwater Selection (Ireland) Limited and Brightwater Selection (Belfast) Limited (“Brightwater”)
Our nominated representatives for the purpose of GDPR; Aoife Clarke and John O’Donnell - firstname.lastname@example.org
What information do we collect about you?
- You may give us information by filling in forms on our website www.brightwater.ie and www.brightwaterni.com (our website) or by corresponding with us by phone, e-mail, in person or otherwise. We ask you to disclose only as much information as is necessary to provide you with our services or to submit a question / suggestion / comment in relation to our website or our services.
- By seeking employment through Brightwater, you may provide us with; your CV information, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, referee details, and so forth). We ask that you do not disclose sensitive personal information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.
- Northern Ireland based candidates and prospective employees will provide monitoring information to Brightwater which is legally required by Equality Commission for Northern Ireland, Fair Employment (monitoring) Regulations (Northern Ireland) 1999.
- As a client or supplier, you may provide us with your employee contact information and your company bank details in order to effectively secure payment.
With regard to each of your visits to our website we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
The security of your personal data is very important to us. All information you provide to us is stored on secure servers using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We take all reasonable and appropriate measures to guard against accidental, unauthorised or unlawful loss, access, disclosure, alteration, or destruction of your Personal Information, taking into account the risks involved in the processing and the nature of the personal information. We use industry-standard security measures to protect the integrity and confidentiality of any personal data we own or process on behalf of our customers and visitors, including, in appropriate circumstances, the use of firewalls, restricted access and encrypted transmissions. We limit access to personal data to those persons in our organisation who have a business need to process such personal information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Brightwater will not retain your Personal Data longer than is necessary for the purposes for which it is collected.
What information do we receive from other sources?
We may receive information about you as follows:
- If you use any of the websites we operate. This data may be shared internally and combined with publicly available data taken from data on other job websites.
- We may also collect references from referees who you have nominated.
- We may also work with third parties with your permission and may download information about you from them for example; online recruitment platforms, such as job sites.
Why do we use this information?
We collect and process the information in order to provide you with our services, to market our services, to improve our website and to recruit staff.
We will use this information:
- By submitting your CV information to Brightwater, you agree that we may use it for recruitment purposes. It will not be shared with others for non-recruitment purposes.
- To create a profile for you if you are a prospective employee.
- To administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- As part of our efforts to keep our website safe and secure.
- To deliver information about our services, where you have subscribed to receive same.
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, and services that you request from us.
- To notify you about changes to our service.
- To combine this information with information which you have given to us to create a candidate profile for you.
- To make suggestions and recommendations to you and other users of our website about services that may interest you or them.
The legal basis for the processing of your data are:
- Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract.
- Processing necessary for compliance with a legal obligation to which we are subject.
- Processing necessary for the purposes of the legitimate interests in running our business effectively, which we pursue where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information.
- You may also give us your consent to certain processing activity.
Disclosure of Your Information
We may share your personal data with any member of the Brightwater Group. We may also share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- 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 Brightwater or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- For our legitimate business interests in running our business effectively e.g. using cloud computing providers / shredding / archiving.
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
- Credit reference agencies for the purpose of assessing your credit score where this is a client requirement- it will not be carried out without your permission.
How long do we keep hold of your information?
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.
- A candidate record is kept for no longer than 2 years after last point of contact with one of our consultants. This is to ensure that the recruitment ethics pertaining to Brightwater is adhered to and that a candidate that we represent or place in an organisation is not inadvertently re-approached by our consultant teams.
- A prospective employee record is kept for the duration of the recruitment process, and twelve months after as legally required.
- A client and supplier record is kept until such time as the client / supplier informs Brightwater to remove their information from our database. This is necessary for the effective running of our business.
Do we transfer your information outside the European Union or European Economic Area?
The data that we collect from you as a candidate may be transferred to, or stored at, a destination outside the European Economic Area ("EEA") for the purpose of a job application with a company who has operations outside the EEA.
The above mentioned transfers are necessary for the conclusion or performance of your contract with the company to whom the personal data is transferred and is in the interest of the individual candidate (Article 49(1)(c)
What are your rights with respect to your personal data?
You have the following rights:
- The right to access the information we hold about you.
- The right to require us to rectify any inaccurate information about you without undue delay.
- The right to have us erase any information we hold about you in circumstances, such as, where it is no longer necessary for us to hold the information for your use of our services or if you have withdrawn your consent to the processing.
- The right to object to us processing information about you, such as, processing for profiling or direct marketing.
- The right to ask us to provide your information to you in a portable format or where technically feasible, for us to port that information to another provider, provided it does not result in a disclosure of information relating to other people.
- The right to request a restriction of the processing of your information.
Where our processing of your information is based on your consent to that processing, you have the right to withdraw that consent at any time, but any processing that we have carried out before you withdrew your consent remains lawful.
You may avail of each of the above rights. If you wish to avail of these rights, a request must be submitted in writing to: Brightwater, Privacy Officer or email email@example.com In order to protect your privacy, you may be asked to provide suitable proof of identification before we can process your request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise this right at any time by contacting us at firstname.lastname@example.org
You may lodge a complaint with your local Supervisory Authority with respect to our processing of your information. The local Supervisory Authority in Ireland is the Data Protection Commissioner. The Data Protection Commissioner’s website is www.dataprotection.ie
When you become our customer the processing of your information, and/or that of your team who you nominate to liaise with us, will become a condition of the contract between us as we require certain information in order to be able to provide you with our services (e.g. Contact information). In those circumstances, if you do not wish Brightwater to process your information we may be unable to provide our services to you.
How can you contact us?