PRIVACY NOTICE
1. WHO ARE WE?
Our Services encompass providing recruitment services for temporary nursing, healthcare staff, locum doctors, and allied health professionals to healthcare service providers. We are fully committed to ensuring the protection of your personal data throughout our operations.
This notice outlines the basis on which we process any personal data collected from you or others. We kindly ask you to carefully read the following information to understand our practices regarding your personal data and how we will handle it.
Should you have any concerns or questions regarding data protection, our data protection contact can be reached at Emerald Nursing, 20 Harcourt St, Saint Kevin’s, Dublin 2, D02 PF99 or by email at gdpr@emeraldnursing.ie.
2. DETAILS OF PERSONAL DATA PROCESSING
In the course of our business, we collect and process the Personal Data as set out in this Notice. This may include data we receive directly from an individual (Data Subject) for example, by completing forms or by corresponding with us by mail, phone, WhatsApp, social media messages, email or otherwise and data we receive from other sources including, for example, our website, our recruitment operating system (Vincere), garda vetting, NMBI, health certificate providers and others.
We will sometimes record phone conversations for training and improvement purposes, and we will always let you know and capture your consent when we do this.
We will only process Personal Data for the specific purposes set out in this Notice or for any other purposes specifically permitted by the applicable law. We will notify those purposes to the Data Subject when we first collect the data or as soon as possible thereafter.
The personal data we collect, details of the processing activity and the lawful basis is as follows:
| PROCESS | DESCRIPTION OF DATA COLLECTED, PURPOSE OF PROCESSING AND USE | LAWFUL BASIS |
| Clients | We collect the following information from new clients: name, address, contact details including email address and phone number, financial information. We use this data to set you up as a client on our systems, liaise with you about projects that we are undertaking with you, to make appropriate financial returns to revenue, to process payment of invoices, etc.
We collect the following personal data through our organisations “work with us” form:
We use this data to match your staffing requirements to the availability of our nurses and carers. When corresponding with us by phone, e-mail or otherwise, we ask you to disclose only as much information as is necessary to provide you with our services. |
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| Suppliers | We collect and process information relating to our suppliers (and their employees’) such as names, contact details, financial information.
We use this data to set you up as a supplier on our system; to liaise with you on projects that we are undertaking with you, to provide you with information and to process payment of your invoices. |
Performance of a Contract |
| Candidates | We collect the following information through our online registration form and sometimes through social media messaging:
The type of information you may provide in your CV:
We use this data to screen candidates, to assess suitability for roles and to contact successful candidates. 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. |
Legitimate Interests |
| Agency Worker / Contractor Set Up | When you enter into a contract with us, we collect the following information:
We collect the following personal data from new recruits:
We gather this personal data directly and from third parties. We use this data to decide and recommend on our agency or permanent employment that might be suitable for you and to verify identities and ensure that all relevant legal requirements are met, and certifications are up to date. If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our services. |
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| Sales and Marketing | We are not collecting any information for sales and marketing purposes. Any data collected is on signup, referral purpose, and how this is used should be outlined by Emerald Nursing.
All information is collected in the following forms:
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| Website Data and Cookies | We collect data from cookies on our website.
A cookie is a little piece of text at that our server places on your device when you visit any of our websites. We use this data to improve your experience on our website and understand how you use our website.
See our cookie policy for more information [Our Cookie Policy]. |
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| Special Category Data Collected | We will collect certain medical information such as:
We also collect:
We collect this special category data to ensure that all relevant legal and industry requirements are met. |
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When you become a client, supplier or join the ENL team, the processing of your personal data, 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 and to comply with certain legal obligations. In those circumstances, if you do not provide your information when requested, we may be unable to provide our services to you.
3. WHAT INFORMATION ABOUT YOU DO WE OBTAIN FROM OTHERS?
When you use ENL’s Services, we may obtain the following categories of personal data from others:
- We will collect candidate reference forms from two previous employers of each job candidate.
- Where we refer you for a medical exam, we may receive a medical report from the medical practitioner.
- We will collect Certificate of Fitness to Practice certificates from a third-party supplier.
- Garda vetting information received from ERF.
4. WHO DO WE SHARE YOUR DATA WITH?
We share your personal data with selected clients to provide you with our Services. These clients include hospitals, nursing homes and a number of other health care facilities.
We will never share your CV or other personal data with our clients without your consent.
We will also share your personal data with third parties service providers engaged by ENL, for the provision of human resource services, payroll services, IT services. We have data processing agreements in place with our third-party service providers.
In addition, we may disclose your personal information to third parties:
- 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 we or substantially all of our assets are acquired by a third party, in which case information held by us about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
We attach at Schedule 1 a list of all data processors, who process data on our behalf, with whom your personal data is shared
5. HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
We only collect the amount of personal data that is necessary for us to fulfil our obligations as your recruitment agency/employer and to fulfil operational and statutory legal purposes for the provision of nursing staff to healthcare providers. We will only keep that data for certain periods. The time periods for which we retain your data depends on the type of personal data and the purposes for which we use it. We will keep your personal data for no longer than is required or permitted.
For further information on the periods for which your personal data is kept, please see our data retention policy.
6. DO WE TRANSFER YOUR INFORMATION OUTSIDE THE EUROPEAN UNION OR EUROPEAN ECONOMIC AREA?
Yes.
The data that we collect from you may be transferred to, and stored in the United Kingdom, outside the European Economic Area (“EEA”), for which there is currently an adequacy decision relating to the safeguards for personal data from the European Commission.
7. AUTOMATED DECISION-MAKING AND PROFILING
We use automated decision-making/profiling when we use non-essential cookies on our website site such as Google Analytics. See our cookie policy for more information [Our Cookie Policy].
8. WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?
You have the following rights in relation to your Personal Data processed by ENL:
- To request access to any Personal Data held by us relating to you (a “Data Subject Access Request”). To make a Data Subject Access Request, please email us at gdpr@emeraldnursing.ie
- To have any inaccurate or misleading data rectified, corrected or erased (subject to certain statutory restrictions);
- To restrict the processing of Personal Data in certain circumstances;
- Not to be subject to a decision based solely on automated decision–making including profiling (subject to certain statutory restrictions);
- To data portability, which allows individuals to move, copy or transfer Personal Data from one IT environment to another. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
- To object to processing of Personal Data based on public interest grounds or based on legitimate interest of the data controller (subject to certain statutory exceptions).
- Where your data is processed based on your consent, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing based on consent before your consent was withdrawn.
Please note that these rights are not absolute rights and may be subject to statutory restrictions.
You also have the right to make a complaint.
If you have a complaint about the use of your personal information, please let us know so we have the opportunity to put things right as quickly as possible.
If you wish to make a complaint you may do so in person, by telephone, in writing and by email. Please be assured that all complaints received will be fully investigated. We ask that you supply as much information as possible to help our staff resolve your complaint quickly.
You can also make a complaint to a supervisory authority. For a list of Supervisory Authorities in Europe, please see this list on the European Commission’s website: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
To avail of any of the rights set out above, you may write to us at the address above or by email at: gdpr@emeraldnursing.ie. Suitable proof of identification may be required before a request can be processed.
9. WHAT WILL HAPPEN IF WE CHANGE OUR PRIVACY NOTICE?
This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This notice was last updated on 13 April 2022.
10. SECURITY AND DISCLOSURE OF INFORMATION
The Company will take all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of both electronic and manual information in accordance with GDPR and current Irish Legislation, we also reserve the right to share information with our finance providers
11. HOW TO CONTACT US
For data protection queries our Data Protection Contact can be reached by phone on 0818 485 682, by email at gdpr@emeraldnursing.ie or you can write to us at Emerald Nursing, 20 Harcourt St, Saint Kevin’s, Dublin 2, D02 PF99.
SCHEDULE 1
If you wish to be disclosed with the list of third-party suppliers we may share your data please contact us directly by email at gdpr@emeraldnursing.ie and we will be happy to provide this information.
