Who we are
Action HR Services are committed to maintaining the confidentiality of our customers. We do not share, sell, or otherwise disclose information about our clients to any other party except as required to deliver our professional services such as employment law and HR advice.
We are the Data Controller of the personal data that you supply to us under your contract with us.
Action HR Services specialise in the provision of HR, Employment Law, Recruitment and Training consultancy services to businesses within the Republic of Ireland.
When providing these services, we take our responsibilities regarding data protection very seriously and are bound by all applicable data protection laws in respect of the handling, processing and collection of data. All employees who handle personal and business data are fully trained to ensure that the data is processed in line with the General Data Protection Regulations 2018 (GDPR) as well as The Data Protection Act 2018 (DPA 2018).
Personal Data We Collect
The type and frequency of any personal data collected will always depend on how our website and services are used. If you do not wish to provide us with certain categories of personal data, you may not be able to use our services in their entirety.
Personal Data Provided to Us
We use electronic contact forms on our website. These forms will prompt users to input basic contact details so we can generate service quotes, provide newsletter updates and respond to enquiries. You may also provide data to us when registering for an event, seminar or vacancy or when corresponding with us by phone, email, letter or social media. It is important that the personal data we hold about you is accurate and current. You should keep us informed if your personal data changes during your relationship with us.
Personal Data Collected By Us
Where you ask us to provide services, we may be required to process additional categories of personal data relating to you or other parties to ensure the provision of informed legal advice. We may also collect additional data from you as part of our recruitment process. We may also ask to verify your identity in limited circumstances by providing valid photographic identification.
Personal Data from Other Sources:
We may receive information about you and/or your company from specific third parties such as business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers. Peninsula also receives referrals from other clients and purchases marketing lists from external companies.
Special Categories of Data:
There may be instances where we need to process Special Category Data provided by you or other users of our services during the lifetime of our service. Special category data is a more sensitive type of data which reveals insights about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life, or sexual orientation. We may also process data that relates to criminal and/or civil offences as well as child data in some very limited circumstances, usually in connection with Legal advice or Employee Assistance programs. Sensitive data collection will only take place where it is applicable to the provision of the services that we are contracted to provide. The fundamental rights of the data subjects are always assessed to ensure that the processing is fair, transparent and lawful.
Online Identifiers:
When you visit our website, a record of your device’s IP address is retained which is used anonymously in order to determine website and page visitors.
For more information on how we use online identifiers or cookies please visit our cookies policy.
Our Legal Basis for Processing
Before processing any personal data, we ensure that at least one lawful basis under GDPR is met. We will not disclose personal data for any purpose other than what the data was originally collected for; unless there is an overriding legal basis that enables this processing.
We may collect, hold, use and disclose the information collected to compile statistical data and to maintain our database; to develop or improve our website; respond to any queries; notify you of any upcoming marketing, training or other events that we think may be of interest to you; provide you with publications; manage quality control and compliance issues; manage systems administration; provide you or your organisation with advice; notify you about important changes or developments to our services; contact you for your views on our services or to determine the suitability for employment.
We may also process your personal data in the following circumstances:
To Perform Our Service Under the Contract
We process information in order to support and maintain our existing or potential contractual relationships under the lawful basis ‘performance of a contract’. We may process personal data in order to provide various supporting client services, take payments and to make improvements to our website. The lawful basis which we often rely on to process data for the duration of servicing on your account and for the decision to enter an initial or any subsequent contract is under our ‘legitimate interests’. Ensuring our administrative and IT systems are secure and robust against unauthorised access also falls under this basis.
For Fraud Prevention
Due to the products we offer to companies, we also have a ‘legal obligation’ to validate the status of companies we work with which may involve identifying and verifying individual data subjects as part of our ‘legitimate interests’ to safeguard against criminal or fraudulent activities. We also need to ensure that VAT and premium tax is paid.
To Defend Legal Issues
We have a ‘legitimate interest’ to process data which may assist us in connection with the establishment, exercise or defence of legal claims.
To Process Sensitive Data
In some cases, where the processing is deemed high risk or highly sensitive, we may ask for your ‘consent’ before we undertake the processing. For example, when providing information on reasonable adjustments before an interview. Where consent is used as the lawful basis for the processing, you will be entitled to withdraw that consent at any time as well as exercise your data privacy rights.
When You Apply for a Vacancy
You provide several pieces of data to us directly during the recruitment exercise. In some cases, and to facilitate our ‘Legitimate Interests’ we will collect data about you from third parties, such as employment agencies and former employers when gathering references or credit reference agencies. Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins. We have a Legal Obligation to ensure you have a right to work in Ireland and make reasonable adjustments for you if you have a disability. The ongoing lawful basis we rely on to process your data will be under our legal obligations or legitimate interests which may include assessments made on salary.
For Marketing Purposes:
Action HR Services is a sibling Company of Action Recruitment. There may be occasions where both Action HR Services and Action Recruitment are involved in the delivery of the services you are contracted to receive. On occasion, we may share data between the two parts of the business under our ‘legitimate interests’ to enhance the delivery of any services you have.
You can opt-out of this type of marketing by emailing us at:
office@actionrecruitment.com
As part of our business-to-business sales strategy we may contact companies and individuals of companies about our products and services. To do this, we rely on our shared ‘legitimate interests’ in doing business together. This lawful basis also applies to any purchased data we may use from our various lead sources and when we share your data across our group databases.
Data Sharing and International Transfers
Personal data will only be disclosed on a confidential basis to external service providers so that they can provide services such as financial, technological or administrative assistance. When we share data with an external third party; these operations are governed by a Data Processing Agreement (DPA) and we perform regular due diligence on any external companies we work with to ensure that high levels of data integrity are maintained.
Any transfers taking place outside the EEA are only permitted with the provision of an Adequacy decision, Standard Contractual Clauses (SCC’s) or any other lawful transfer mechanism. Where necessary, we may need to share data with external organisations such as law enforcement, regulatory bodies, fraud prevention agencies, partners or advisors. Before any data is shared, we ensure that all technical and organisational controls are firmly in place and a data protection impact assessment is undertaken, where applicable, if the sharing or transfer is considered high risk. We do not sell your data to any third parties.
Data Storage and Security
We have a dedicated Information Security team who are in place to offer protection across all our networks and IT assets to assist with data security and data loss prevention. Our cloud providers have servers based within the Ireland and EEA jurisdictions. As a company we promote a ‘paperless’ culture where possible.
Data Retention
Action HR Services only keep your data for as long as necessary, unless there is an overriding legal ground. We will not retain data if it is deemed unlawful to do so. Data may be held for purposes relating to the establishment, exercise or defence of legal claims which the group or our clients may face. Where we represent you in any legal case, we retain the data for seven years from the conclusion of the litigation case. We will also typically keep data concerning your account for at least seven years from the date you end your contract with us. Some data may be deleted before this time period depending on the category of that data in line with our commercial legitimate interests and retention schedule, for example, data provided to us in the course of an unsuccessful job application will be retained no longer than 12 months after the recruitment exercise.
Your Data Privacy Rights
All data subjects have individual rights. On a case-by-case basis, you have the following rights in relation to your personal data processed by Action HR Services:
- The right to be informed about how your personal data is collected and used
- The right to request access to a copy of any personal data that we hold about you
- The right to rectify personal data we may hold which is identified as incorrect or misleading
- The right to erasure of any personal data; also known as ‘the right to be forgotten’
- The right to restrict further processing of your personal data
- The right to data portability where technology allows us to send personal data onto a new controller
- The right to object to the processing or certain processing activities
- Rights in relation to automated decision-making including profiling.
As an organisation we do not operate any automated decision-making systems. Please be aware that the rights listed in this section only apply to individuals and cannot be used to request data relating to business entities. Please be aware that your rights of access do not entitle you to physical or digital copies of any documentation we hold.
Cookies Policy
General Use
We use cookies, tracking pixels and related technologies on our website. Cookies are small data files that are served by our platform and stored on your device. Our site uses cookies dropped by us or third parties for a variety of purposes including to operate and personalize the website. Also, cookies may also be used to track how you use the site to target ads to you on other websites.
Third Parties
Our website employs the use the various third-party services. Through the use of our website, these services may place anonymous cookies on the Visitor’s browser and may send their own cookies to the Visitor’s cookie file. Some of these services include but are not limited to: Google, Facebook, Twitter, Adroll, MailChimp, Sucuri, Intercom and other social networks, advertising agencies, security firewalls, analytics companies and service providers. These services may also collect and use anonymous identifiers such as IP Address, HTTP Referrer, Unique Device Identifier and other non-personally identifiable information and server logs.
Queries and Complaints
Action HR Services have a dedicated representative who can be approached for any questions, comments and requests regarding this privacy policy. Please contact office@actionrecruitment.com
Additional Information
This version was last updated and reviewed July 2021.