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Privacy Notice

Privacy Notice – General Users

Privacy Notice – Job Applicants

 

Privacy Notice – General Users

Introduction

opensky Data Systems takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data. If you need more information, please contact privacyteam@openskydata.com

Our personal information handling policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018).

This notice is subject to change and any such changes to our privacy notice will be posted on this page without prior notification.

Under the GDPR, there are six data protection principles that opensky data systems comply with. These provide that the personal information we hold about you is:

  • Processed lawfully, fairly and in a transparent manner.
  • Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
  • Adequate, relevant and limited to what is necessary in relation to those purposes.
  • Accurate and, where necessary, kept up to date.
  • Kept in a form which permits your identification for no longer than is necessary for those purposes.
  • Processed in a way that ensures appropriate security of the data.

Who are we?

Our Privacy Policy applies to all services offered opensky data systems, a company with company registration number 380089 and whose registered office address is Premier Business Centre B, Osprey Business Campus, Devoy Quarter, Naas, Co. Kildare.

What information do we collect?

We collect and process personal data about you when you interact with us and our products and when you purchase goods and services from us. The personal data we process includes:

  • your name       
  • your home or work address, email address and/or phone number;
  • your job title (Position)
  • and/or any other information you provide

How We Use Your Information and the legal basis for this use:

We process the personal data listed above for the following purposes:

  • as required to establish and fulfil a contract with you, for example, if you enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services, maintaining services and managing our relationship with you (for example customer service and support activities). We require this information in order to enter into a contract with you and are unable to do so without it;
  • to comply with applicable law and regulation;
  • in accordance with our legitimate interests in protecting opensky data systems legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
  • with your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;

With whom and where will we share your personal data?

opensky will not sell, share or rent your information to any third party, and will only disclose information to a third party acting on our behalf when necessary. These parties include:

  • our professional advisors such as our auditors and external legal and financial advisors;
  • our suppliers and sub-contractors;

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws.

How long will you keep my personal data?

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a customer, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 12 months.


Where you are a prospective customer and you have expressly consented to us contacting you, we will only retain your data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 12 months from when you last interacted with us or our content.

Where is my data stored?

The personal data that we collect from you may be transferred to, and stored outside the European Economic Area (“EEA”).  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the third country's data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our Privacy Team.

 

What are my rights in relation to my personal data?

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don't have a good reason to continue to use it; or (d) if we haven't handled your personal data in accordance with our obligations.

 

Where can I find more information about Opensky Data Systems handling of my data?

Should you have any queries regarding this Privacy Notice, about opensky’s processing of your personal data or wish to exercise your rights you can contact opensky’s Data Protection Representative using this email address: privacyteam@openskydata.com. If you are not happy with our response, you can contact the Data Protection Commissioner's Office:  info@dataprotection.ie

 

Privacy Notice - For job applicants

Introduction:

opensky takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about how opensky collects and uses your personal data.

 

As part of our recruitment process, opensky collects and processes personal information, or personal data, relating to job applicants. This personal information may be held by the Company on paper or in electronic format. The Company is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”). The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information during the recruitment process. We are required under the GDPR to notify you of the information contained in this privacy notice. This privacy notice applies to all job applicants. It is non-contractual.

Data protection principles

Under the GDPR, there are six data protection principles that opensky comply with. These provide that the personal information we hold about you is:

  • Processed lawfully, fairly and in a transparent manner.
  • Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
  • Adequate, relevant and limited to what is necessary in relation to those purposes.
  • Accurate and, where necessary, kept up to date.
  • Kept in a form which permits your identification for no longer than is necessary for those purposes.
  • Processed in a way that ensures appropriate security of the data.

 What information do we collect and process?

We collect and process personal data about you when you apply for a job with us.
The personal data we process includes:

  • your name, home address, email address and/or phone numbers;
  • your date of birth, marital status, nationality (where you provide this to us);
  • your educational and employment history;
  • other information contained within your CV or other documents or information you submit to us;
  • information from the selection process, if any;
  • references and assessments relating to your work for previous employers;
  • medical and financial information (where you provide this to us)
  • information relating to your feedback on our organisation.

 What is the source of this information?

We obtain this information directly from you, our personnel, through our systems and equipment, as well as from third parties such as recruitment agencies or former employers. We may also obtain it from your public profiles available online.

How do we use this information and what is the legal basis for this use?

We process the personal data listed in the information we collect and process above for the following purposes only in accordance with our legitimate interests:

Our legitimate interests include: pursuing our business by employing employees, workers and contractors; managing the recruitment process; conducting due diligence on prospective staff and performing effective internal administration.

  • to enable us to comply with our legal and regulatory obligations;
  • to make recruitment decisions;
  • to establish, exercise or defend our legal rights; and
  • to manage risk
  • manage the recruitment process and assess your suitability for employment or engagement
  • decide to whom to offer a job
  • comply with statutory and/or regulatory requirements and obligations, e.g. checking your right to work in Ireland/Poland
  • comply with the duty to make reasonable adjustments for disabled job applicants and with other disability discrimination obligations
  • ensure compliance with your statutory rights
  • ensure effective HR, personnel management and business administration
  • monitor equal opportunities

Change of purpose

We will only use your personal information for the purposes for which we collected it, i.e. for the recruitment exercise for which you have applied. However, if your job application is unsuccessful, the Company may wish to keep your personal information in case there are future employment opportunities with us. We will ask for your consent before we keep your personal information for this purpose. Consent can be withdrawn at any time.

What if you fail to provide personal information?

 If you fail to provide certain personal information when requested, we may not be able to process your job application properly or at all, we may not be able to enter into a contract with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory rights.

Who has access to your personal data?

Your personal information may be shared internally within opensky for the purposes of the recruitment exercise, including with members of the HR department, members of the recruitment team and managers in the department which has the vacancy. The Company will not share your personal information with third parties during the recruitment process unless your job application is successful and we make you an offer of employment or engagement. At that stage, we may also share your personal information with third parties (and their designated agents), including professional advisors, such as lawyers.

We may also need to share your personal information with a regulator or to otherwise comply with the law. We may share your personal information with third parties where it is necessary to steps at your request to enter into a contract with you, or to enter into a contract with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).

How long will you keep my personal data?

We will not keep your personal information for longer than is necessary and will only retain the personal information that is necessary to fulfil the purpose. We are also required to retain certain information by law or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

We will keep the personal data connected to your job application (including any interview records) for 2 years from the date of their creation by opensky or receipt from you. Once this 2 years has expired, the personal data will be deleted (electronic) and destroyed (paper). If your application is successful and you become a member of staff we will provide you with a copy of the Staff Privacy Notice. The retention periods referred to therein will apply to your personal data during your employment.

Transferring personal information outside the European Economic Area

The Company will not transfer your personal information to countries outside the European Economic Area.

What are my rights in relation to my personal data?

As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:

• request access to your personal information - this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it

• request rectification of your personal information - this enables you to have any inaccurate or incomplete personal information we hold about you corrected

• request the erasure of your personal information - this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected

• restrict the processing of your personal information - this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy

• object to the processing of your personal information - this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground

• data portability - this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.

 If you wish to exercise any of these rights, please contact our data protection Representative (see details below).

We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal.

 If you wish to withdraw your consent, please contact our data protection representative.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.

 

Where can I find more information about opensky’s handling of my data?

Should you have any queries regarding this Privacy Notice, about opensky’s processing of your personal data or wish to exercise your rights you can contact opensky’s data protection representative using this email address: privacyteam@openskydata.com.

 

If you are not happy with our response, you can contact the Data Protection Commissioner's Office: info@dataprotection.ie

 

This notice is subject to change and any such changes to our privacy notice will be posted on this page without prior notification.