A) INTRODUCTION

In the course of our recruitment services, Amphitrite Resource Group will have to collect and use information about its clients and candidates. This personal information must be handled and dealt with properly, however it is collected, recorded and used, whether it be on paper, in computer records, or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.

To this end, we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with recruitment activities, as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of job applicants, candidates, clients, and suppliers.

B) DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, or online identifier. It can also include pseudonymized data.

“Data processing” is any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

C) DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  • processing will be fair, lawful, and transparent.
  • data be collected for specific, explicit, and legitimate purposes.
  • data collected will be adequate, relevant, and limited to what is necessary for the purposes of processing.
  • data will be kept accurate and up-to-date. Data found to be inaccurate will be rectified or erased without delay.
  • data is not kept for longer than is necessary for its given purpose.
  • data will be processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organization measures.
  • we will comply with the relevant GDPR procedures for the international transfer of personal data.

D) TYPES OF DATA HELD

We keep several categories of personal data in order to carry out effective and efficient processes. We keep this data in a centralized computer database to which only Flagship employees have access. Specifically, we may hold the following types of data:

Candidates:

  • Personal details such as name, address, phone numbers, gender, D.O.B.
  • Information gathered via the recruitment process, such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history, etc.
  • Immigration status and nationality.
  • Details relating to current salary and package.
  • Details of criminal convictions were applicable to the role.
  • Job title and job descriptions.
  • Communication history with Amphitrite consultants.

Clients:
We will collect data that will help us ensure that the relationship between our organizations runs as smoothly as possible. This will normally be restricted to the name, telephone number, and email address of individual contacts, plus relevant company information. All of the above information is required for our data processing activities.

E) CANDIDATE/CLIENT RIGHTS

You have the following rights in relation to the personal data we hold about you:

  • The right to be informed about the data we hold about you and what we do with it.
  • The right to access the data we hold on you. (see SUBJECT ACCESS REQUEST below.)
  • The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’.
  • The right to have data deleted in certain circumstances. This is also known as ‘erasure’. (see OPT-OUT PROCEDURE below.)
  • The right to restrict the processing of the data.
  • The right to transfer the data we hold on you to another party. This is also known as ‘portability’.
  • The right to object to the inclusion of any information.
  • The right to regulate any automated decision-making and profiling of personal data.

F) LAWFUL BASES OF PROCESSING

Legitimate Interest:
We believe that we have a legitimate interest in processing your data for the purpose of providing recruitment services to both our clients and candidates.

Candidates:

  • We believe that it is reasonable to expect that if you are looking for employment or have posted your CV onto our job board or networking site, you are happy for us to collect and use your data to offer or provide you with recruitment services. This can include forwarding your details to prospective employers or matching your details against our open vacancies. Prospective employers might want to verify certain aspects, such as references and qualifications.
  • We have to comply with various legal, regulatory, and tax obligations, and we have a legitimate business interest in doing so. Therefore, we may share your data with the appropriate authorities to meet these obligations.
  • We want to help you find a job. We believe that sending you job recommendations and relevant market intelligence will facilitate this. We will process your data to send you appropriate content.

Clients:
To ensure that we can provide you and your organization with the best possible service, we store details of the company and its contacts, including notes of conversations, emails, meetings, previous jobs, and recruitment activity. We believe that this falls within our legitimate interest in providing efficient recruitment services to you.

Consent:
In certain cases, such as processing sensitive data, we will need to obtain your consent. In this instance:

  • You have to give your consent freely.
  • You have to know what you are consenting to.
  • You should be able to control your consent.
  • We will keep a record of your consent.
  • You have the right to withdraw your consent.

Establishing, exercising, or defending legal claims:
Occasionally, we may need to process your data when it is necessary for the establishment, exercise, or defense of legal claims or whenever the courts are acting in their judicial capacity.

G) ACCESS TO DATA

As stated above, candidates have a right to access the personal data that we hold about them. To exercise this right, candidates should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive, or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request note below.

H) DATA COLLECTION

How we collect your personal data:
Candidates:

  • Personal data is received via online applications for vacancies advertised via our company website, and online jobsites and publications to which we are subscribed, such as Linked In, Tradewinds, etc.
  • Registering on our website.
  • Sending us a copy of your CV electronically or by post.
  • Personal data shared by third parties, i.e.: clients, referees, etc.
  • Information shared at trade shows, events, conferences, etc.

Clients:

  • Personal data that you share with us.
  • Information obtained from the company website and online/offline media.
  • Delegate lists from meetings, events, and conferences.

I) DATA USE
Candidates:
Recruitment Activities:
We provide recruitment services to candidates. We want to connect you to relevant opportunities as they arise. We may use your data in the following ways if we deem it necessary to do so for our legitimate interest. The ways in which we might use and process your data is as follows.

  • Submitting your data to prospective employers to apply for jobs.
  • Assessing your data against open vacancies to determine your suitability.
  • To provide you with job seeking services.
  • Storing your details on our database so that we can contact you in relation to future vacancies.
  • To provide you with job alerts and other job seeking-related communications.
  • To enable us to meet our obligations of any contracts between you and us.
  • To enable us to meet our obligations of any contracts between us and third parties with regard to your recruitment.
  • Facilitating of invoicing processes.
  • Verifying details that you have provided (e.g. references, qualifications and criminal convictions).
  • Complying with our legal obligations.

Marketing Activities:
Where you have previously contacted us (such as registering on our website, submitting a CV, applying for a job) we may send you details of recruitment-related services that may be beneficial in your job search, particularly where we inform you of vacancies similar to the one you specifically applied for. We may also ask you to participate in salary surveys and job-related questionnaires to provide us with benchmarking data to better advice in your job search. For other marketing purposes we will seek your consent.

If you do not wish to receive any marketing communications from us, you can withdraw your consent by unsubscribing at any time.

Sensitive Personal Data:
We may need to collect sensitive personal data, such as medical information and criminal convictions, if required for a specific role. We will only do this with your explicit consent. You may withdraw your consent at any time.

To help establish, exercise, or defend a legal claim:
Occasionally, we may need to use your data to establish, exercise, or defend a legal claim.

Clients:
Recruitment Services:
Our primary function is to provide your company with efficient recruitment services, including presenting you with candidates, providing market intelligence such as salary surveys, and providing recruitment process outsourcing services. To enable us to provide these services, we will process your data in the following ways:

  • Storing your data in our database so we can contact you in relation to recruitment activities.
  • Recording notes of conversations and meetings.
  • For targeted marketing campaigns.
  • Customer satisfaction surveys.

Marketing Activities:
As a matter of course, we shall not seek your consent when sending marketing materials such as our salary surveys to corporate email addresses. If you wish to opt out of receiving marketing information, you can unsubscribe from receiving it at any time.

To help establish, exercise, or defend a legal claim:
Occasionally, we may need to use your data to establish, exercise, or defend a legal claim.

J) DATA DISCLOSURE

We share your data with a variety of third parties during the course of conducting our business. They are as follows:

Candidates:

  • Our group companies.
  • Our clients and other recruitment businesses will help us find suitable employment for you.
  • Third party IT companies with whom we are contracted and have appropriate data processing agreements.
  • Third party services providers who perform work on our behalf (e.g. auditors, lawyers, IT providers, etc.)
  • Tax and local authorities to enable us to comply with laws and regulations.
  • Marketing technology providers.
  • Job boards and job aggregators, where it helps us find you work.
  • Managed service providers where our clients have outsourced their recruitment process.

Clients:

  • Our group companies.
  • Third party IT companies with whom we are contracted and have appropriate processing agreements.
  • Third party service providers who perform work on our behalf (e.g. auditors, lawyers, IT providers, etc.)
  • Tax and local authorities to enable us to comply with laws and regulations.
  • Marketing technology providers.

K) DATA SECURITY

We take all reasonable steps to ensure that your data is safe and protected from misuse, loss, or unauthorized access. We ensure this by implementing a range of technical safeguards and operational processes. We also have processes to deal with any suspected data breach. If you suspect that your data has been misused, or has been compromised, please contact us immediately at jobs@amphitritellc.com.

L) THIRD-PARTY PROCESSING

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain Amphitrite Resource Group’s commitment to protecting data.

M) INTERNATIONAL DATA TRANSFER

As an international business, Amphitrite Resource Group may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place to provide the relevant job application information to overseas companies. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland, and Liechtenstein.

N) RETENTION POLICY

In order to provide you with the best job-seeking opportunities, we will retain your data in our secure database until such a time as you require us to delete it. In certain cases, we are required to hold your data to comply with tax, legal, or regulatory issues. Should you wish to be removed from our database at any time, please follow the steps set out below in OPT-OUT PROCEDURES.

O) GDPR RIGHTS

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data that we process about you.
  • The right to access the personal data that we process about you.
  • The right to rectification of your personal data.
  • The right to erasure your personal data in certain circumstances.
  • The right to restrict the processing of your personal data.
  • The right to data portability in certain circumstances.
  • The right to object to the processing of your personal data that was based on a public or legitimate interest.
  • The right not to be subjected to automated decision-making and profiling.
  • The right to withdraw consent at any time.

Where you have consented to us processing your personal data and sensitive personal data, you have the right to withdraw that consent at any time. (Please refer to OPT-OUT PROCEDURE below.)

P) REQUIREMENT TO NOTIFY BREACHES

Where legally required, we will report a breach to the Data Protection Commission within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

Q) SUBJECT ACCESS REQUEST

At any time, you are entitled to request to see the data that we hold on you. This request should be sent via email containing your name, email address, and contact number, with SUBJECT ACCESS REQUEST as the subject heading to jobs@amphitritellc.com.

R) OPT-OUT PROCEDURE

Should you wish to opt out of our service at any time, you should send an email containing your name, email address and contact number with OPT OUT as the subject heading to jobs@amphitritellc.com.

Once your details have been erased, we will no longer be able to keep you updated with new job opportunities and market information. However, should your circumstances change you can resend your CV to us at any time.