This policy governs the use by Lincoln Group Holdings and its wholly owned subsidiary Steering Point Advisory Limited (together ‘Lincoln’ ‘us’ ‘we’) of any data you share with us whether by using our website www.lincoln.ie or www.steeringpoint.ie (the ‘Lincoln Websites’), submitting a CV to us or otherwise engaging with our services.
At Lincoln it is of paramount importance to us that your information is safeguarded and secure. This privacy notice will inform you as to how we use your personal data when you visit either of the Lincoln Websites (regardless of where you visit it from) or otherwise share data with us and tell you about your privacy rights and how the law protects you. For the purpose of this document, any reference to ‘our website’ or ‘this website’ or ‘the website’ shall be deemed to be a reference to the Lincoln Website accessed by you.
Please click through to the specific areas set out below.
THE PURPOSE OF THIS DATA NOTICE
This privacy notice aims to give you information on how Lincoln collects and processes your personal data through your use of the Lincoln Websites, including any data you may provide through any of our websites when you sign up to a newsletter, purchase a product or service or apply to participate on any courses or programmes provided by us. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller: Lincoln Group Holdings with company registered in Ireland with company number 720010 and with registered address at 5 Fitzwilliam Square, Dublin 2 and Steering Point Advisory Limited is a company registered in Ireland with number 710175 and a registered office at 5 Fitzwilliam Square, Dublin 2 are the processors and controllers responsible for your personal data. Lincoln Group Holdings and Steering Point Advisory Limited are recruitment companies based in Ireland which are part of the same corporate group. The parties share certain resources including their recruitment software system and a common database of candidates. In addition, Lincoln Group Holdings provides business management services to Steering Point Advisory Limited. Each party acknowledges that they are data processors and controllers in their own right in respect of any Personal Data which is shared between them and have entered into a data sharing agreement in relation to their respective obligations. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below. Name: Shay Dalton Address: 5 Fitzwilliam Square, Dublin 2 Email: firstname.lastname@example.org. You have the right to make a complaint at any time to the relevant data protection supervisory authority being the Data Protection Commissioner’s Office (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner’s Office so please email us at email@example.com in the first instance Changes to the privacy notice and your duty to inform us of changes This version was last updated on 1 May 2022 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links: The Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal Data Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, title, date of birth
Contact Data includes address, email address and telephone numbers.
Financial Data includes bank account, salary information.
Curriculum Vitae Data includes employment history, education and training history
Recruitment Data includes details about positions for which you have been put forward, interviews attended, interview feedback.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Aggregated Data We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories ”Special categories” of particularly sensitive personal information require higher levels of protection (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations.
Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We do not ordinarily request or require medical or health information. You are not obliged to provide this information but if we are not made aware of any relevant medical or health issues we will be unable to take appropriate measures to ensure your safety and comfort. In other instances we may collect information about other special categories such as ethnicity for statistical purposes or to assist us with achieving intercultural and diversity aims. The provision of such information is optional.
Criminal convictions If applying for certain positions which will involve working with children or vulnerable adults such as coaching positions it may be necessary for Garda vetting purposes to collect information about criminal convictions and offences to comply with our legal obligations to safeguard child safety. We will provide you with further information in that regard if it becomes necessary.
Further information We may provide you with further specific information about the type of data and purpose of it at the point of data capture.
HOW YOUR DATA IS COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Curriculum Vitae Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
— apply directly to us for placement services;
— create an account or profile on our website;
— apply for jobs advertised by us via third party sites such as Indeed;
— give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below
— LinkedIn or other public forums;
— Former employers in the context of reference checking;
— Potential employers in the context of interview feedback;
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Below set out the types of lawful basis that we will rely on to process your personal data.
If consent is used as a legal basis for processing your data, you have the right to withdraw consent at any time by sending an email from the account we use to contact you to firstname.lastname@example.org or use the Unsubscribe link on any of our marketing emails.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. The lawful basis of processing that we use are as follows
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing us at firstname.lastname@example.org
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To process your application for an advertised position
|(a) Identity (b) Contact (c) Curriculum Vitae
|Consent where you apply directly to a job advertisement posted by us or on our behalf Legitimate Interest where we obtain your data from a 3rd party pending our obtaining your Consent to be considered for a position.
|To keep your data on file for ongoing Candidate placement services
|(a) Identity (b) Contact (c) Curriculum Vitae (d) Recruitment (e) Financial (f) Technical (g) Marketing and Communications
|(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
|(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey
|(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Identity (b) Contact (c) Technical
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|(a) Technical (b) Usage
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Change of purpose 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 email us at email@example.com.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Opting Out You can ask us to stop sending you marketing messages at any time by emailing us at firstname.lastname@example.org at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a course participation, membership registration or other transactions.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties. Other members of the Lincoln corporate group.
External Third Parties
Service providers based inside and outside of EEA who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Ireland who provide consultancy, payroll, banking, legal, insurance and accounting services.
Revenue, governmental agencies, regulators, grant authorities and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances or to whom we are obliged to share information about our organisation and participation in it.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In order to provide certain services to you including the website, we may need to transfer personal to locations outside the jurisdiction in which a visitor is viewing the website (the User Jurisdiction) and process personal data outside the User Jurisdiction. If the User Jurisdiction is within the European Economic Area (the EEA) please note that such transfers and processing of personal data may be in locations outside the EEA. Any data sent or uploaded by users may be accessible in jurisdictions outside the User Jurisdiction (including outside the EEA). The level of data protection offered in such jurisdictions may be less than that offered within the User Jurisdiction or (as the case may be) within the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by emailing us at email@example.com In some circumstances you can ask us to delete your data: see [Request erasure] below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may;
Request access to your personal data. This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Click here for more information on our subject access request policy.
Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data. You may object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent. Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org