ENSURING YOUR PRIVACY IS PROTECTED
- Chill Insurance
- Information Collection
- Purposes for which we hold your Information
- Recipients of Data
- Data Collected
- Subject Rights
- Right to rectification
- Right to erasure
- Right to object
- Right to restrict processing
- Right to access
- Right to portability
- Right to withdraw consent
- Right to complain
Ensuring your privacy is protected
Chill Insurance Limited respects your right to privacy and complies with our obligations under relevant data protection legislation including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
We take great care with any personal data we hold, so that we provide the highest standard of service to you, whilst taking steps to keep your personal data secure and to ensure it is only used for the specified, explicit and legitimate purposes stated within this Policy.
It is important that you read this Policy. It contains all the information you need to understand how we use your data in the job application process. We reserve the right to change this Data Protection Statement from time to time at our sole discretion upon notice to you.
Unless otherwise stated, the controller (as defined in the GDPR) of your personal data for all purposes outlined in this Policy is Chill Insurance. We can be contacted by post at Chill Insurance House Ravenscourt Business Park, Sandyford, Dublin 18, D18 K267 Ireland by telephone at 01 400 3400 or by email at firstname.lastname@example.org. Our data protection officer (“DPO”) can provide you with additional information on this Policy and your rights as outlined in Section 9. Their contact details are below:
Data Protection Officer, Chill Insurance, Ravenscourt Business Park, Sandyford, Dublin 18, D18 K267. Email: email@example.com
1. Chill Insurance
We, our, us, Chill refers to Chill Insurance Limited trading as Chill Insurance. Chill Insurance Limited is a private company limited by shares incorporated in Ireland with company number 506021 and having its registered office at Chill Insurance House, Ravenscourt Business Park, Sandyford, Dublin 18, D18 K267, Ireland.
2. Information Collection
We collect information from you when you apply for a position with the business. As outlined in Section 3, we may obtain your personal data:
1. Verbally: As part of telephone/ face to face interviews
2. CV/Tests: CV, forms & tests where you submitted your application
3. References: Referees you provided us with
4. Social Media Channels: Social Media searches online (Facebook, LinkedIn, and Twitter, this is not meant to be an exhaustive list)
3. Purposes for which we hold your Information
The main purposes for which Chill uses your personal information are outlined below.
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.
|Purpose/Activity||Legal basis for processing|
|To enter the interview process. Including: Screening, Telephone Interview, Face to Face Interview, Aptitude Testing, Psychometric Testing & Reference checks||Performance of a contract|
|Analysis and review of Chill Insurance’s recruitment processes||Necessary for our legitimate interests to monitor and review our recruitment process|
|For successful applicants: in order to store personal data for carrying out training, performance reviews and disciplinary processes||Necessary to comply with legal obligation|
|For Compliance under relevant laws and Central Bank Regulations||Necessary to comply with legal obligation|
Sensitive Categories of Data:
Chill Insurance may require information relating to any criminal convictions you may have. Where requested, this information will be required for the performance of a contract, where authorised or required by law, in particular employment law (such as the Reputation & Character/ Minimum Competency Code).
We may need to gather information relating to any health conditions you may have. Where we gather this information it will be done where authorised or required by law, in particular employment law (such as health and safety legislation).
Effect of not providing information:
You may refuse to provide any personal data requested from you. However if you decide not to provide information requested, it may affect our ability to consider your application for the position in question.
3.1 Change of Use
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data protection officer at the contact details listed in Section 1 of this Policy.
4. Recipients of Data
We may share your personal data with outside organisations, below is a list of the categories of recipients of organisations we share your personal data with:
Any party you have given us permission to speak to (such as referee, recruitment agency or lawyer) and other people or companies associated with you.
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, fraud detection and complaints handling.
Government, Statutory and Regulatory Bodies
State regulators and authorities such as the Data Protection Commission, the Revenue Commissioners, the Central Bank of Ireland and Department of Employment Affairs & Social Protection; Law Enforcement Agencies such as An Garda Síochána & The Criminal Assets Bureau.
5. Data Collected
The table below contains a list of some examples of the types of data we collect.
|Personal Data||Name, address/Eircode, date of birth, contact details, proof of identity, passport and visa information (for non-EEA nationals requiring permission to work in Ireland and/or the UK), CCTV footage from our offices, answers and result of aptitude, psychometric or other tests any other details provided in your CV, during an interview or otherwise|
|Employment and Education Details||Employment history, education, qualification and training details, membership status of any relevant bodies, any information required for compliance with the Minimum Competency Code and/or Fitness and Probity Standards, any other details provided in your CV, during an interview or otherwise.|
|Information obtained from sources other than you||Information about your education and employment from the relevant institution and the referees you provide to us, any information from searches we carry out.|
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it. This means that the period of time for which we store your personal data may depend on the type of data we hold.
|Types of Data||Retention Period|
|Individuals who go through a job application process and are unsuccessful or do not take up a job offer.||Up to 4 years|
|Individuals who provide unsolicited CVs.||Up to 12 months|
If you become a member of staff (whether temporary, permanent, direct employee, contractor or any other variation), our Retention Policy will explain how your personal data will be processed.
7. Subject Rights
The rights outlined below apply to the processing activities carried out by Chill Insurance where we are a controller of your data.
a. Right to rectification
You have the right to have Chill correct any inaccurate personal data we have collected about you. You also have the right to have incomplete personal data completed; you may provide us with supplementary information to do this. To do so, please contact our data protection officer at the contact details listed in Section 1 of this Policy.
b. Right to erasure
In certain instances, you have the right to have Chill erase the personal data we have collected about you. This right will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information. To exercise this right, please contact our data protection officer at the contact details listed in Section 1 of this Policy.
c. Right to object
You have the right to object to the processing of your personal data at any time:
- Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights and freedoms or in connection with the enforcement or defence of a legal claim.
Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above.
To exercise your right to object, please contact our data protection officer at the contact details listed in Section 1 of this Policy.
NOTE: We will use all reasonable efforts to communicate the fact that you have exercised your right to rectification or erasure of personal data or restriction of processing in accordance with these rights outlined above, to each recipient to whom your personal data has been disclosed in accordance with this Policy, unless this proves impossible or involves disproportionate effort.
d. Right to restrict processing
You have the right to have Chill restrict the processing of your personal data where one of the following applies:
- You contest the accuracy of the personal data (we will restrict the processing of the personal data until we verify the accuracy of the personal data)
- The processing is unlawful and you oppose the erasure of your personal data
- Chill Insurance no longer requires the personal data for the purposes of the processing but the data is required by you for the establishment, exercise or defence of legal claims
- You object to the processing of the personal data as outlined above (we will restrict the processing of the personal data while we verify our legitimate grounds for the processing which may override your interests, rights and freedoms)
Where you have restricted the processing of your personal data, we will continue to store your personal data but will only process it with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of other people or for reasons of important public interest or other non-restricted purposes.
e. Right to access
You have the right to obtain from us information on the personal data we hold on you including the following:
- Purposes of the processing
- Type of personal data held
- Categories of recipients of the personal data
- Information on how long the data will be stored
- If automated individual decision making, including profiling, takes place, as well as information on the logic involved and consequences of this
- If data is not collected directly from you, information on the source of the data
- The existence of the right to request from us rectification or erasure of your personal data or restriction of processing of your personal data or to object to such processing
- The right to lodge a complaint with the Data Protection Commission
Any such request should be submitted in writing and sent for the attention of the data protection officer at the contact details listed in Section 1 of this Policy. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
f. Right to portability
You have the right to receive personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format. You also have the right to provide this data to another controller or have Chill transmit this data to another controller on your behalf, where technically feasible. This applies to automated data only to the extent provided by you to us. This right to portability is limited to the following situations
- Where the processing is based on the legal basis of consent
- Where the processing is based on the legal basis of entering into or performance of a contract
g. Right to withdraw consent
Where we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent at any time. This does not affect the legality of the processing which took place when we had your consent.
Please note if you withdraw your consent, we will no longer send direct marketing communications to you.
h. Right to complain
If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights , then you have the right to complain to the Data Protection Commission (DPC). Please see below for contact details of the DPC.
The Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois.
Phone: +353 (0)761 104 8000
LoCall: 1890 25 22 31
Fax: +353 (0)57 8684757
8. Questions or Complaints
Contact us. If you have any questions or complaints relating to this Policy, please contact us at:
Data Protection Officer, Chill Insurance, Ravenscourt Business Park, Sandyford, Dublin 18. D18 K267
Effective date of this policy: 25th May 2018