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THE PERSONAL DATA AND PRIVACY STUFF.

Data protection policy in accordance with the EU General Data Protection Regulation

(GDPR)

Data protection policy


i-Recruit is a recruitment agency specialising in AI and robotics.


i-Recruit are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have recognised our obligations in updating and expanding this program to meet the demands of the GDPR and the Data Protection Act Ireland.


i-Recruit are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

i-Recruit is fully compliant with the GDPR as follows:


- Information Audit - a company-wide information audit has been carried out to identify and
assess what personal information we hold, where it comes from, how and why it is processed
and if and to whom it is disclosed.
- Policies and Procedures - data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
o Data Protection – our main policy and procedure document for data protection has
been overhauled to meet the standards and requirements of the GDPR. Accountability
and governance measures are in place to ensure that we understand and adequately
disseminate and evidence our obligations and responsibilities; with a dedicated focus on
privacy by design and the rights of individuals.
- Data Retention and Erasure – we have updated our retention policy and schedule to
ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that
personal information is stored, archived and destroyed compliantly and ethically. We
have dedicated erasure procedures in place to meet the new ‘Right to Erasure’
obligation and are aware of when this and other data subject’s rights apply; along with
any exemptions, response timeframes and notification responsibilities.
- Data Breaches – our breach procedures ensure that we have safeguards and measures
in place to identify, assess, investigate and report any personal data breach at the
earliest possible time. Our procedures are robust and have been disseminated to all
employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers and Third-Party Disclosures – there is no transfer of
personal information outside the EU.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate
the revised 30-day timeframe for providing the requested information and for making
this provision free of charge. Our new procedures detail how to verify the data subject,
what steps to take for processing an access request, what exemptions apply and a suite

of response templates to ensure that communications with data subjects are compliant,
consistent and adequate.

- Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis
for processing and ensuring that each basis is appropriate for the activity it relates to. Where
applicable, we also maintain records of our processing activities, ensuring that our obligations
under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR,
ensuring that all individuals whose personal information we process have been informed of why
we need it, how it is used, what their rights are, who the information is disclosed to and what
safeguarding measures are in place to protect their information.
- Obtaining Consent – we have revised our consent mechanisms for obtaining personal data,
ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing – we are not currently carrying out any direct marketing. However, future
campaigns will include clear opt-in mechanisms for marketing subscriptions; a clear notice and
method for opting out and providing unsubscribe features on all subsequent marketing
materials.
- Data Protection Impact Assessments (DPIA) – we do not process personal information that is
considered high risk, involves large scale processing or includes special category/criminal
conviction data.
- Processor Agreements – where we use any third-party to process personal information on our
behalf (i.e. Payroll, Hosting etc), we have drafted compliant Processor Agreements and due
diligence procedures for ensuring that they (as well as we), meet and understand their/our
GDPR obligations. These measures include initial and ongoing reviews of the service provided,
the necessity of the processing activity, the technical and organisational measures in place and
compliance with the GDPR.
- Special Categories Data - we do not obtain and process any special category information.

Data Subject Rights


In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our office, of an individual’s right to access any personal information that i-Recruit processes about them and to request information about: -


- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the
process for requesting this

- The right to request erasure of personal data (where applicable) or to restrict processing in
accordance with data protection laws, as well as to object to any direct marketing from us and
to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security and Technical and Organisational Measures


i-Recruit takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: -


Password policy - includes complex passwords for access to customer information.
Access control – Candidate and client access is restricted to those staff directly dealing with customers requirements.


GDPR Roles and Employees


i-Recruit have designated Christopher Walter as our Data Protection Officer. His duties include the implementation of GDPR awareness and ongoing compliance and implementing new policies, procedures and measures as required. i-Recruit understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program which will be provided to all employees and forms part of our induction and annual training program.If you have any questions about our data protection policies, please contact Christopher Walter.