Data Privacy Notice

1. What is a Data Privacy Notice and why is it important?

We know your personal information is important to you and it is important to us too. This Data Privacy Notice tells you what we use your personal data for and explains your rights around how we use it.

Within this recruitment website you have a number of options, for example, you can build your candidate profile for the purpose of joining our talent pool, change your profile visibility preferences, set job notification alerts and submit applications for advertised roles. 

Please read this Data Privacy Notice to understand how and why we use your personal data. 

This Data Privacy Notice will be reviewed from time to time to take into account changes in the law or changes in how we process your personal data. Where there is a need to process personal data for a purpose other than those set out in this Data Privacy Notice, we will notify you of this and a current version of our Data Privacy Notice will always be available in a prominent position on our recruitment website.

 

2. Who are we/the data controllers?

When you register your account and create your candidate profile for the purpose of joining our talent pool “we” means the Irish Life and Canada Life Group Companies listed at Section 9 below who you choose to allow to have access to your personal data according to the visibility setting you select. This will be either :-

  1. the specific Group company managing your job application where you select to make your profile visible to ‘Only Group Companies managing jobs I apply for’ (as the sole data controller), or,
  2. to all Group Companies where you select to make your profile visible to ‘All Irish Life and Canada Life Group Companies’ (as joint data controllers).

When you submit a job application “we” means the specific Irish Life or Canada Life Group Company to whom you submit an application for employment (as your prospective employer and sole data controller).

Contact information for all relevant Group Companies is available at Section 9 of this Data Privacy Notice.

 

3. What personal information we collect and why?

3.1 Account Registration and Talent Pool

When you register with this recruitment website, we require a minimum disclosure of your first name, last name and a valid email address. You may also be required to disclose other information such as your country of residence. Collectively this is referred to as "registration data". This registration data will form part of your candidate profile and is used by us to identify you and to send you communications such as job alert notifications and to contact you in connection with your job applications. You can correct or update registration data initially provided by selecting “My Profile” under the “Options” menu where you can proceed to make required changes.

As part of your registration, you will be asked to create a password for use of this website. Please keep your password confidential at all times. If you believe that the security of your password has been compromised, please contact us immediately.

You may select at the outset to have your personal data made visible and available only to the specific Irish Life or Canada Life Group Company to whom you submit an application for employment (as your prospective employer). Alternatively, you may select to have your data visible to all Irish Life and Canada Life Group Companies listed in Section 9 who will then have access to your candidate profile in our talent pool in order to see if your details are suitable for current vacancies. You can change your visibility settings at any time to restrict or extend access to your candidate profile data as you choose.

3.2 Your Candidate Profile and Job Applications

Before you can apply for a role you first must set up a candidate profile. 

The minimum personal data required to set up a candidate profile and provided by you on account registration includes name, email address and country of residence. 

Other personal data you may submit to build your candidate profile or in connection with a job application, may include, but is not limited to:  

  • address and contact phone number,
  • work history, education history, salary and benefits package,
  • documentation required for immigration laws,
  • referee names,
  • qualification certificates, results of aptitude tests (where applicable) and related documentation,
  • photograph for authentication.

If you wish to apply for a job outside of your country of residence, we may need to ask you questions that are specific to the country where that job is located. These questions will be relevant and necessary for the job advertised.

Mandatory information required will be highlighted to you.

You can access your candidate profile at any time to review, update or delete your personal data. It is your responsibility to keep your personal data accurate and up to date and to inform us of any changes. You can also access your candidate profile to monitor the progress of any applications or to amend your personal data from time to time should you wish to do so.

If your profile has not been updated in 12 months you will receive an email notification to remind you that we are maintaining your candidate profile and that this can be updated or deleted by you.

3.3 Our Recruitment and Selection Process

We use personal data to undertake activities relating to our recruitment and selection process and to onboard and initiate the employment relationship with successful candidates. This includes using your personal data to enable us to:

  • assess your suitability as a potential candidate,
  • conduct interviews and other assessment exercises such as aptitude tests, presentations, and role plays,
  • conduct vetting for certain roles as required by regulatory authorities,
  • in the event that you are successful, to prepare your employment contract and other internal processing procedures required to onboard successful candidates.

We will use the email address and phone number provided to communicate with you. We may contact you, for example:

  • if you opt to receive automated job alert notifications of job vacancy postings,
  • when your qualifications and/or preferences made visible in our talent pool match job opportunities
  • to invite you to career events,
  • to facilitate communication relating to job applications and hiring processes you become engaged in.

Most of the personal data that we process about you is provided by you. In addition, we may collect personal data relevant to you from third parties or other sources, including: 

  • education institutions (e.g. proof of qualifications),
  • previous employers via references (with your permission),
  • third party recruitment agencies, staffing companies/websites which introduce you to us,
  • public searches including professional networking websites and background checks where permitted by law,
  • CCTV footage if you enter our premises for an interview.

In general, access to your personal data will be restricted to our staff who need it for the purposes set out in this Data Privacy Notice, which may include hiring managers and HR, IT, Compliance, Legal and Audit functions. 

Third Party Personal Data
If you give us personal data about someone else (for example, if you are acting as a recruiter/agent on behalf of a job applicant or if you provide contact details for reference purposes), you are responsible to make sure that you have that person’s permission to share their personal data and to make them aware of this Data Privacy Notice, as it applies to them.

Automated Decision-making including profiling
We may use automated decision-making including profiling in our recruitment and selection process, for example, screening for certain roles that require very specific skills or qualifications in order for candidates to be eligible for consideration for such roles. This is designed to improve efficiency in the recruitment process. We use automated decision-making and/or profiling when necessary for the purposes of entering into a contract of employment, our legitimate interests and if required for compliance with legal obligations or with your explicit consent. You will have a right to object to any automated decisions that may be made about you and you can ask to have a person review and make the final decision.

 

4. Lawful Bases for Processing Your Personal Data Explained

We must have a lawful basis to collect and use personal data and we explain this below:-

4.1 With your consent

We will process your personal data for the purposes set out above with your prior consent, to the extent such consent is mandatory under applicable law.

  • Special Categories of Personal Data: We need your consent to collect and use personal data referred to as special categories of personal data or sensitive personal data or for certain uses of your personal data. You may provide sensitive personal data to us by responding to questions when creating your candidate profile or as part of your job application (ie. in your CV or otherwise). If you provide sensitive personal data to us, you do so voluntarily.
  • Cookies: We need your consent to collect personal data through the use of cookies when you visit our website. Cookies are small files of information that save and retrieve information about your visit. Please read our cookies policy for further information on this.
     

Your right to withdraw or revoke consent

Where we process your personal data based solely on consent, you have the right to withdraw or revoke that consent at any time. The revocation methods will depend on how the consent was collected and will be explained when you give us your consent, for example,

  • you can change your mind about your profile visibility setting so that you can choose to be either visible only to recruiters and hiring managers that manage job roles you apply for or you can choose to be visible and searchable to all recruiters and hiring teams in our Group Companies listed in Section 9 below. This setting can be changed at any time in your candidate profile under ‘My Profile’;
  • you can revoke your candidate profile under ‘Settings’ - ‘Delete Profile’, or
  • you can withdraw a specific job application and the data provided for that application

Please note that this will not affect our right to process personal data based on legal bases other than your consent.

What happens if you do not provide us with your personal data or withdraw consent?

You may decline to provide us with certain of your personal data. However, if we believe that we require relevant information to effectively and properly manage your application through the recruitment process, we may not be able to continue to maintain your candidate profile or to proceed with your job application.

It is important to note that if you revoke your candidate profile all of your current job applications will automatically also be withdrawn.

4.2 Needed for the purposes of entering into an employment contract

We will process your personal data for the purpose of entering into an employment relationship which will cover the assessment of your personal data as part of the application process and when the recruitment process results in an offer of employment, your onboarding as an employee and the initiation of our employment relationship. This processing may include automated-decision making including profiling.

For a prospective employer/data controller in Germany, the basis of data processing for the job application process is Section 26 Federal Data Protection Act (FDPA).

4.3 Legitimate interests

The processing of your personal data is also necessary for our legitimate interests, including:

  • maintenance and security of our website: we process your personal data, in particular your registration data, to maintain an effective and secure website
  • management of the recruitment/application process: we process personal data to ensure that we have an effective recruitment process and to enter into an employment contract with successful candidates, including:
  1. receiving and reviewing CV’s and application information from candidates,
  2. assessing suitability for employment for the role for which applications are submitted as well as future roles that may become available which may include automated decision-making and profiling processes,
  3. managing applications,
  4. communicating with candidates regarding applications,
  5. tracking of interview assessments,
  6. in some cases record online interviews for further review,
  7. performing administrative functions,
  8. job offers,
  9. job declines/regrets,
  10. capturing of referee’s details,
  11. preparation and issue of contracts to successful candidates.
  • quality checks and audit: we use job application data of all candidates (successful and unsuccessful) to quality check the recruitment process and to ensure proper process in the event of complaints
  • statistical analysis and metrics: we combine candidate personal data to perform data analytics including analysis of our talent pool in order to better understand the candidate base and how to attract talent

Where we rely on our legitimate interests for processing described above, this doesn’t affect your privacy rights. We have taken account of any privacy risks and ensured that your data protection rights are not affected. We believe that this processing is of benefit to you. Please contact us if you have any questions.

4.4 Required by Law

The processing of your personal data is necessary to ensure that we are complying with our legal obligations. For example:

  • it is mandatory to check a successful applicant’s eligibility to work in Ireland
  • certain roles carry additional requirements under law and regulation and these require more comprehensive due diligence regarding successful candidates. We may request information about your financial and/or criminal records from third parties, where required for this purpose

 

5.   Who do we share your personal information with?

We disclose personal data with third parties only in connection with the purposes for which it was collected, including, with:-

5.1 Service Providers:

  • Group Companies: companies within our Group that act as service providers and only process your personal information as instructed by us. Our main intra-group processors are Irish Life Group Services Limited and Canada Life Group Services Limited and they provide HR and other services, including website, recruitment and talent management administration services
  • Information System (IS) Providers: your personal data is stored on our HR IS provider systems (including cloud based applications). We ensure that the providers selected have the appropriate technical and organisational measures and safeguards in place to protect your personal data
  • Online Assessment Providers: if an online assessment is part of the selection process. The data shared will be mainly your name and email address and the assessment provider will share your results with us
  • Occupational Health Specialists (OHS): we will share necessary personal data with our OHS where required
  • Auditors: when your recruitment file has been randomly selected as part of an audit
  • Security Staff: for authentication and security purposes
  • Independent contractors and external consultants: occasionally we engage with independent contractors and external consultants, for example, to complete a specialist recruitment and selection process

5.2  Other Third Parties:

  • Resourcing Partners: your personal data will be shared with a recruitment agency/third party resourcing partner where you are being represented by an agency/third party resourcing partner
  • Corporate Partnerships: your personal data will be shared with other financial services providers where a corporate working partnership exists and you have applied to be included in the selection process for one of these roles
  • Group Companies: we disclose your information to other companies within our Group, where we have a lawful basis to do so

5.3 Regulators: we share personal data with relevant regulatory authorities where necessary, for example, to meet fitness and probity requirements

5.4 Law Enforcement: your personal data will be shared with other companies, organisations and associations in order to prevent detect or investigate crime and we will also share any information that is required by law

 

6.  Do we transfer your personal data outside of the European Union (EU)?

Personal data provided as part of your candidate profile (depending on your visibility setting) and/or any job applications you submit may be available to Irish Life and Canada Life Group Companies listed in Section 9 which you should note are not all located in the EU.

We may share your personal data with our parent company – Great-West Lifeco Inc. in Canada and associated companies for legitimate business interests, for example, recruitment status reporting.

We may use third party suppliers and outsourced service providers (including for cloud based services), which can require transfers of personal data outside of the EU.

We will ensure that all Group Companies and third party suppliers and service providers that process personal data outside of the EU have the appropriate technical and organisational measures in place to protect your personal data. This means that you will have a similar standard of protection for your personal data as you have within the EU.

 

7.  How long do we keep your personal data?

We retain your personal data as long as we have an ongoing relationship with you. We will send you notifications (at least annually) to remind you that we continue to maintain your candidate profile subject to the visibility setting last selected by you.

If your candidate profile has been inactive (ie. you haven’t logged in and applied for a job or changed your profile) for 12 months you will receive an email from us to inform you that your profile will be deleted unless you log in to refresh your candidate profile.

If you are offered and accept an offer of employment, certain personal data collected during the pre-employment period may become part of your employee file to be retained throughout your employment and for a period after your employment. 

If your application is unsuccessful, or you revoke your candidate profile and all current applications, we may continue to retain personal data relevant to your job applications. Your personal data will only be retained for as long as required by local employment legislation and our internal policy and practices, and in compliance with applicable law. Please contact us if you have any questions on our retention policy and practices.

 

8.  What are your rights?

You have a number of rights over your personal data which you can exercise free of charge by contacting us using the details in Section 9 of this Data Privacy Notice. You will need to give us information to identify you and we will respond to you within one month. Any restrictions to your rights will be explained in our response.

8.1 Right to Information
You have a right to the information set out in this Data Privacy Notice. The most recent version of our Data Privacy Notice will always be accessible on our website. If we change the type of personal data we collect and/or how we use it, we will inform you of the changes.

We have controls in place to protect your personal data and minimise the risk of security breaches. However should any breaches result in a high risk for you, we will inform you without undue delay.

8.2 Right to Restrict or Object
You can restrict or object to any unfair and unlawful collection or use of your personal data.
As explained above you have the right to withdraw consent and object to certain processing, for example direct marketing. You have the right not to be subject to automated decision-making including profiling.

8.3 Right to Correct and Update
You can ask us to correct and update personal data we hold about you.
It is important that we have your up to date personal data to ensure a fair and efficient recruitment process.

8.4 Right to Delete and Be Forgotten
You can have your personal data deleted if it is incorrect, if it is no longer needed or has been processed unfairly or unlawfully. We will keep a record of your request so we know why your personal data was deleted.

Where we process your personal data based solely on consent, you have the right to withdraw that consent at any time. Please note that we retain certain personal data as explained in Section 7 above notwithstanding that you may revoke your consent in order to delete your candidate profile.

8.5 Right to Portability
You can ask for a copy of all personal data that you gave us (including through your interactions with us), and which we hold in an automated format. You can receive this in a machine readable format that allows you to keep it.

You may also request us to send your personal data in a machine readable format to another company. The format will depend on our ability to provide this in a secure way that protects your personal data.

8.6 Right to Access
You have the right to know what personal data we hold about you and to receive a copy of your personal data. We must tell you:

  • why we hold it
  • who we pass it to, including whether we transfer it outside the EU
  • how long we keep it for 
  • where we got it from
  • if we carried out any automated-decisions, and if so, the logic behind it and what it means for you

This right does not allow you to access personal data about anyone else.

To access your personal data please write to us or email us using the contact details in Section 9 of this Data Privacy Notice. To help us respond as quickly as possible please let us know if you are only looking for copies of specific personal data.
In certain circumstances, we may need to restrict the rights listed above in order to safeguard the public interest (e.g. the prevention and detection of crime) and our interests (e.g. compliance with our legal responsibilities).

 

9.  Irish Life and Canada Life Group Companies/Data Controller Details

Ireland

Irish Life Group Services Limited, Irish Life Centre, Lower Abbey St, Dublin 1, Ireland
Registered in Ireland. Registered Number: 498692

Irish Life Assurance plc, Irish Life Centre, Lower Abbey St, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 152576.  Regulated by the Central Bank of Ireland

Irish Life Financial Services Limited, Irish Life Centre, Lower Abbey St, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 489221.  Regulated by the Central Bank of Ireland

Irish Life Health dac, Irish Life Centre, Lower Abbey Street, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 376607.  Regulated by the Central Bank of Ireland

Irish Life Investment Managers Limited, Beresford Court, Beresford Place, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 116000.   Regulated by the Central Bank of Ireland

Setanta Asset Management Limited, Beresford Court, Beresford Place, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 297730.  Regulated by the Central Bank of Ireland

Irish Progressive Services International Limited, Block C, Irish Life Centre, Lower Abbey Street, Dublin , Ireland
Registered in Ireland.  Registered Number: 286708.  Regulated by the Central Bank of Ireland

Canada Life Group Services Limited, Irish Life Centre, Lower Abbey St, Dublin 1. 
Registered in Ireland.  Registered Number: 410263.  Regulated by the Central Bank of Ireland

Canada Life Re Ireland  dac, Irish Life Centre, Lower Abbey St, Dublin 1. 
Registered in Ireland.  Registered Number: 180407.  Regulated by the Central Bank of Ireland

Canada Life International Assurance (Ireland) dac, Block D, Irish Life Centre, Lower Abbey St, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 440141.  Regulated by the Central Bank of Ireland

Canada Life Assurance Europe plc, Irish Office 14/15 Lower Abbey Street, Dublin 1, Ireland
Registered in Ireland.  Registered Number: 297731.  Regulated by the Central Bank of Ireland

Germany

Canada Life Assurance Europe plc, Niederlassung für Deutschland, Höninger Weg 153a, 50969 Köln
AG Köln HRB 34058/ Umsatzsteuer ID-Nummer: DE 234 786 232

United Kingdom

Canada Life Limited, Canada Life Place, Potters Bar, Hertfordshire, EN6 5BA
Registered in England and Wales.  Registered Number: 973271

CLFIS (U.K.) Limited , Canada Life Place, Potters Bar, Hertfordshire, EN6 5BA
Registered in England and Wales.  Registered Number: 04356028

Isle of Man

Canada Life International Limited, Canada Life House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2QJ 
Registered in Isle of Man.  Registered Number:  033178 C

CLI Institutional Limited, Canada Life House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2QJ 
Registered in Isle of Man.  Registered Number:  108017 C

Canada Life International Services Limited, Canada Life House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2QJ Registered in Isle of Man.  Registered Number 114982 C

9.1 If you have any queries in relation to our use of your personal data, you should firstly contact the relevant Group Company Recruitment Team contact.

Ireland:                                   Recruitment Team
                                              Irish Life Group
                                              Irish Life Centre,
                                              Lower Abbey Street,
                                              Dublin 1
                                              Tel: +353 (0)1 704 1887
                                              Email: LifeCareers@irishlife.ie

Germany:                                Recruitment Team
                                              Canada Life Assurance Europe plc
                                              German Branch
                                              Höninger Weg 153a
                                              50969 Cologne
                                              Tel: +49 (0)221-367560
                                              Email: karriere@canadalife.de

United Kingdom:                      Recruitment Team
                                              Canada Life Place 
                                              Potters Bar 
                                              Hertfordshire 
                                              EN6 5BA 
                                              Tel: +44 (0)1701 422 978
                                              Email: HRRecruitment@canadlife.co.uk

Isle of Man:                             People Engagement Team
                                              Canada Life International
                                              Canada Life House
                                              Isle of Man Business Park
                                              Douglas
                                              IM2 2QJ
                                              Tel: +44 (0) 1624 820337
                                              Email: People.Engagement@canadalifeint.com

9.2 If your queries are not satisfied or you wish to escalate any matter for the attention of our Data Protection Officers/Contacts, the relevant contact details are below for each jurisdiction. For company details within each jurisdiction please see section 9.1.

Ireland Based Companies 

Irish Life Group Data Protection Office (HR), Irish Life Group, Irish Life Centre, Lower Abbey Street, Dublin 1, Ireland.  Tel: +353 (0)1 704  2000  Email HRDPOIreland@Irishlife.ie

German Based Companies/Offices:

Datenschutzbeauftragter, Canada Life Assurance Europe plc, Siemensstraße 8, 63263 Neu-Isenburg, Email: CLE_Datenschutz@canadalife.de

UK Based Companies

Data Protection Officer, Canada Life Limited, Canada Life Place, Potters Bar, Hertfordshire, EN6 5BA 
Tel: : +44 1707 651 122  Email: dpo@canadalife.co.uk

Isle of Man Based Companies:

Data Protection Officer, Canada Life House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2QJ
Tel: +44 (0) 1624 820337  Email FMRiskandCompliance2@canadalifeint.com

 

10. Complaints

If you are not happy with how we have processed your personal data or handled your data protection rights, you have a right to take the matter up with the Data Protection Authority, either in the country where you live, the country you have applied to work in, or, the country where you consider that data protection law has been infringed.

Ireland:                    Data Protection Commission
                               21 Fitzwilliam Square
                               Dublin 2
                               D02 RD28
                               Ireland
                               Tel. +353 76 110 4800
                               email: info@dataprotection.ie
                               Website: http://www.dataprotection.ie/

Germany:                 Postanschrift:
                               Landesbeauftragte für Datenschutz und Informationsfreiheit
                               Nordrhein-Westfalen
                               Postfach 20 04 44
                               40102 Düsseldorf
                               Tel.: 0211/38424-0
                               Fax: 0211/38424-10
                               E-Mail: poststelle@ldi.nrw.de

United Kingdom:       The Information Commissioner’s Office
                               Water Lane, Wycliffe House
                               Wilmslow - Cheshire SK9 5AF
                               Tel. +44 1625 545 700
                               email: casework@ico.org.uk
                               Website: https://ico.org.uk

Isle of Man:              Isle of Man Information Commissioner,
                               P.O. Box 69, Douglas,
                               Isle of Man, IM99 1EQ   
                               Telephone: +44 1624 693260  
                               Email: ask@inforights.im

A full list of EU National Data Protection Authorities and contact details are available at:
https://edpb.europa.eu/about-edpb/board/members_en

This Privacy Notice is effective from May 2019