Introduction

WrkWrk is part of the FRS Network; a co-operative organisation in business since 1978. With 20 offices nationwide it includes FRS Farm Services, FRS Fencing, FRS Training, Herdwatch and Turas Nua.

WrkWrk is a Data Controller in our capacity as your agent in respect of the personal data you supply to us.  Your data will be shared with third party Clients in order to advance your prospect of obtaining your desired position.  The purpose of this document is to set out the privacy entitlements of data subjects, which are defined in the General Data Protection Regulation (GDPR) as natural (living) individuals.

The General Data Protection Regulation (GDPR) is a European Union Regulation that was enacted into Irish law under the Data Protection Act 2018.  The GDPR sets out the data entitlements of data subjects and the obligations of those who process the personal data of data subjects. GDPR seeks to protect and enhance the rights of data subjects.

We have identified our data subjects as being:

• General candidates looking for temporary work.
• Individuals who are engaged on a contract of employment by our company to be placed in temporary assignments in our client companies.
• Individuals who are our own internal employees carrying out the work of the recruitment agency – our own employee data processing information is set out separately
• Candidates whom we introduce to companies and who provide contractual work to those companies
• Client contact details, those being the personal details in the form of the client contact email address and telephone number

How Do We Collect Information?

The following non-exhaustive methods of data collection are an indication of ways in which we may obtain your information:

• Obtain personal data directly from you;
• Personal data that we receive from other sources; for example any information that you provide by filling in forms on our app or websites: www.frsnetwork.ie, www.frsfarmrelief,ie, www.frsrecruitment.com, www.frstraining.com, www.frsfencing.com, and www.herdwatch.ie .
• When entering some of our premises, you may be recorded on CCTV surveillance and you may be asked to sign the Visitor Sign In tablet/book for security purposes.
• It is important that the personal data you provide is up to date and accurate. As outlined in your data subject rights section of this notice, if personal data we hold on you is inaccurate or incomplete, you will be able to update the information directly on the WrkWrk app. You may also contact us to update the information.

Categories of Data

We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual. This PII may include your:

• First and last name
• PPSN number 
• address
• email address(s)
• phone number(s)
• date of birth
• education,
• employment history,
• CV and any other information required to provide you with job placement services
• passport, identification copy, visa (where applicable)
• photo’s, work position, qualifications, job interests, transcripts, training history, cover letters, salary details, 
• bank details, next of kin, tax, VAT details, 
• interviews attended which are recorded on the app, interview feedback
• Special category data, such as data concerning health (with your consent) 
• We may source contact details through social media and reach out to you there
• Garda Vetting and International Police clearance where applicable

Use of your Personal Information 

Candidate Data:

WrkWrk collects and uses all Personal Identifiable Information (PII) that you provide to deliver the job-seeking or related services you have requested. Your information will only be used for matching your skills with potential job opportunities and will be only disclosed to prospective employers that you are interested in. We may use the information:

• to consider your application for employment
• to notify you of our new employment opportunities
• to respond to your requests
• to improve our level of service
• share your information with prospective employers to increase your chances of securing the contract you want
• to share market knowledge and career information with you

References & Emergency Contacts

As part of our recruitment process, we may contact referees using the contact information provided by the candidate to obtain references.  For temps working with us, we will contact emergency contacts using the contact details provided by the temp in the event of an emergency.

Client Data:

WrkWrk collects and uses all PII in accordance with the provisions of this policy and furtherance of our recruitment business. Your information will only be used to contact you in the following circumstances:

• to discuss potential requirements for our services
• to develop an understanding of the Clients organisation and the Candidate profile requirements
• to discuss potential candidates for vacancies you have requested us to assist you in recruiting for
• to schedule candidate interviews
• to update you on candidates whose data we have shared with you and their progression in the process and on-boarding of successful candidates
• to share interview contact information with candidate(s) who are actively interviewing with you.
• to share market knowledge and career information with you

We use Client and Supplier personal data for the purposes of making and receiving payments in the ordinary course of business.

Any contact information that you provide through our system will not be sold, leased and/or distributed to any third party for the purpose whatsoever.  

Purpose of Processing

We will process the information you give us in accordance with the Irish Data Protection Acts 1988 – 2018 and, the GDPR 2018, for the purposes of:

• When you register with WrkWrk, you are agreeing to us acting as an agent for you in your pursuit of an employment position with a third party until you opt out (which you can do at any stage).
• fulfilling our obligations to provide recruitment services and to enable the provision of services to support the FRS Group
• Providing you with information or services that you request from us or which you have indicated may interest you
• Carrying out our obligations arising from any contracts entered into between you and us; and
• Notifying you about changes to our services.

If at any time, we need to use your Personal Data for a purpose that is different from the original purpose of collecting your Personal Data, we will contact you regarding this change.

Lawful Basis for the collection and processing of data

We rely upon the following lawful bases for data collection:

Legitimate Interest:

Clients: We will utilise personal data in the form of email addresses and contact telephone numbers in order to keep our clients and potential clients informed in relation to vacancies and market related information. 

Candidates: Information is processed in the legitimate interests of the business of the employment agency, and where so processed it will be in accordance with and subject to your rights as a data subject. When you have registered with us because you are interested in gaining access to the information we provide in relation to the career opportunities with our clients and prospective clients, and other related data it is in our legitimate interest to process your data for these purposes.

Performance of a Contract:

Candidates: Information is required in order to perform the contract of “Employment agent” on behalf of our candidates with potential employers.  The basis of data gathering in that instance is contractual requirement.  This will include identification information such as but not limited to, name, address, date of birth, information education/qualifications and reference checks.

Clients/Suppliers: We will process data pursuant to business to business transactions, but where so required, we will rely on the lawful basis of necessity for the performance of the contract for the processing of personal data within this relationship.

Statutory/Legal Obligation: 

Information is required in order to perform our statutory obligations such as tax returns and compliance with employment legislation. This information will include PPS numbers and, where relevant, evidence of entitlement to work.

Consent: 

We may rely on consent in the collection and processing of sensitive special category data e.g., data about disability, health data, genetic or biometric data, trade union membership, sexual orientation. Given the nature of the relationship of agent to Candidate and agent to Client, this data will only be utilised in necessary and appropriate circumstances. You have the right to withdraw this consent without detriment at any time.

Security of Data

Once we have received your information, we use industry standard technologies and security measures to safeguard your information, we train our staff and we keep strict advanced industry security standards to protect it.

Links to Other Websites

We may occasionally include links to third parties on this website. You should always review their privacy policy before sending them any personal data.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Usage Data

We may collect information about visitors to our website that your browser sends when you use visit our site or access it through a mobile device. This usage data may include information such as your computer’s internet protocol address, browser type, browser version, the pages of our site that you visit, time spent on the site, unique identifiers and other diagnostic data. When accessed via a mobile device, the data may include your mobile device unique id, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser used, unique identifiers and other diagnostic data.

Tracking and Cookies Data

We use cookies and similar tracking technologies to track the activity on our website.  Cookies are files with a small amount of data which may include an anonymous unique identifier.  Cookies are sent to your browser from a website and stored on your device.  

You can set your browser to refuse all cookies, accept necessary cookies only, opt-out of Cookies. Please note that some of our website features may not function as a result of refusal of necessary Cookies, or if you choose to opt-out.

Examples of Cookies we use: –

Session Cookies These are necessary for the operation of the website

Preference Cookies We use preference Cookies to remember your preferences and settings

Security Cookies Security Cookies are used for security purposes

Google analytics These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout

Disclosure

It is necessary as part of our contractual requirements to share your data with our Clients e.g., prospective employers, and contract partners and others from time to time. 

Where data is transferred to another party, we ensure appropriate technical and organisational safeguards are used to protect your personal data.

We do not pass on or broker information gained from your engagement with the company. However, it may be necessary to disclose your Personal Information to meet legal obligations, regulations or valid governmental requests.

The categories and types of third parties outlined below is a non-exhaustive list but provides an indication of the parties we share data with.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose and are subject to the provisions of a data processing agreement between the provider and WrkWrk.

Government Departments, Bodies or Agencies

WrkWrk is legally obligated to share personal data with government agencies such as those outlined in the Data Protection Act 2018. This includes Government departments, agencies, bodies, investigatory bodies, local authorities, and the Gardaí.

International Transfers

Where personal data is transferred outside the European Economic Area, WrkWrk uses safeguards known as Standard Contractual Clauses (SCCs) which is an agreement between parties to comply with European data protection standards. 

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you are located outside Ireland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Ireland and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. WrkWrk will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information. 

Data Storage

Data records management and all other data is held in Ireland using different (multiple) servers. Processing of data in a ‘Third Country’ i.e., data held outside the EEA, such as the data held in our app, is subject to the requirements of GDPR Article 28 i.e., either 1. An Adequacy Decision, 2. A written agreement which contains the required Standard Contractual Clauses, or 3. A Binding Corporate Agreement.

General Data Protection Regulations – Rights of the Data Subject 

• Right of access – you have the right to request a copy of the information that we hold about you. 
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. You can do this on the app, or you can inform us of the necessary correction
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records and we will comply with this request in accordance with our own obligations to keep records for statutory purposes as set out.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
• Right to withdraw consent where consent is the lawful basis of processing.

There are certain conditions such as statutory or competing obligations, where we may be unable to comply with the request for example, you may request that we delete your data, however, if we have been your employer can only do so after the statutory period of record retention has expired.

Data Breach

WrkWrk will without undue delay notify you when we reasonably believe that there has been a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data processed by the company.  We will investigate the Incident, take necessary steps to eliminate or contain the impact of the Incident and keep you advised of the status of the Incident and all related matters.  We will contact you to confirm what happened and which of your data was affected.  We will also inform the Office of the Data Protection Commission in the case of any high risk breach involving special category data; of any such breach should they wish to undertake an investigation. 

Subject access requests – Proof of Identity

Where we can verify your identity, for example where you are known to the person receiving the request, proof of identity may not be required.  Otherwise, we may require you to provide proof of your identity. We will accept the following forms of ID when information on your personal data is requested: 

• A copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. 
• A minimum of one piece of photographic ID listed above and a supporting document is required. 
• If we are dissatisfied with the quality, further information may be sought before personal data can be released.

All of the above requests can be directed, in writing, to the Data Protection Officer, WrkWrk Limited, Derryvale, Roscrea, Co. Tipperary. They will be forwarded on should there be a third party involved in the processing of your personal data.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by us or by our partners, you have the right to complain to the Data Protection Officer, WrkWrk Limited, Derryvale, Roscrea, Co. Tipperary, email: [email protected]

You also have the right to complain to the Data Protection Commission which is the Supervisory Authority for Ireland.  They can be contacted at:- https://www.dataprotection.ie/en/individuals/complaints-handling-investigations-and-enforcement-individuals

Changes to this Privacy Statement

Our Privacy Statement may change from time to time and changes to the statement will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy. If you do not agree to these changes, please do not continue to use this Website to submit personal information.

Contacts

1. Data Protection Officer – [email protected]

WrkWrk Limited, Derryvale, Roscrea, Co. Tipperary. E53 EV90

1. Supervisory Authority – Data Protection Commission 

www.dataprotection.ie/complaints