All people whose personal data is collected, in line with the requirements of the GDPR.
2.1 The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Complete Protective Services collecting/processing their personal data.
3. Privacy notice
3.1 Who are we?
We are a protective services company based in Ireland. We offer complete protective and security services for domestic, commercial & retail facilities.
3.2 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: if Complete Protective Services refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
In the event that you wish to make a complaint about how your personal data is being processed by Complete Protective Services (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Complete Protective Services’ Data Protection Officer.
The details for each of these contacts are:
Data Protection Officer contact details Supervisory authority contact details
Contact Name: The Data Protection Officer Data Protection Commissioner
Address line 1: Complete Protective Services Canal House
Address line 2: Unit 1, Exchange Business Park Station Road
Address line 3: Churchfield Industrial Estate Portarlington
Address line 4: Churchfield, Cork. R32 AP23
Address line 5: T23 X773 Co. Laois
Email: email@example.com firstname.lastname@example.org
3.4 Privacy statement
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
The personal data we collect will be used for:
Employment law and practice including:
• Recruitment, vetting and screening
• Pay, tax and pension
• Health and safety
• Vehicle locating
• Next of kin
• Insurance claims handling
To carry our obligations arising from any client service contracts
Our legal basis for processing for the personal data:
• Personal data: contractual performance, legitimate interest, legal obligation, consent (marketing only)
• Special category data: Employer rights and obligations, legal claims
• Criminal convictions: as authorized by Data Protections Acts, Ireland and UK
The legitimate interests we pursue are to fulfil our legitimate purpose of running a commercial enterprise safely and profitably but only where our interests do not out weight the rights and freedoms of data subjects. We rely on legitimate interests as a basis for processing personal data as follows:
Any legitimate interests pursued by us, or third parties we use, are as follows:
• Next of kin
• Medical reports
• GPS tracking on company owned vehicles
• Documents to assess identity verification
The special categories of personal data concerned are:
• Health data
• Racial and ethnic origin
• Religion (as required by Northern Ireland legislation)
• Trade union membership
How we use your information
This privacy notice tells you how we Complete Protective Services, will collect and use your personal data for Information contained in your CV or job application such as your name, address, private and corporate e-mail address and phone number;
• information contained in any documents that you send to any of us for identity verification purposes such as your passport or driving licence;
• financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom or in the Republic of Ireland
• information that you provide about yourself when entering into a contract with us such as bank account details, PPS number, next of kin details, medical and health questionnaires or assessments, DBS or Garda screening documentation.
• Information contained in insurance claim forms
• GPS tracking on company owned vehicles
• Invoicing and billing
• Consent for Marketing
• CCTV imagery (incident details, names, address during client contract services)
Why does Complete Protective Services need to collect and store personal data?
For us to fulfill our obligations as an employer provide employment and to provide our service to clients, we need to collect personal data for the above-mentioned purposes. We are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Complete Protective Services will contact you for consent.
Will Complete Protective Services share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Complete Protective Services in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf.
Third parties that we
may use on your behalf include:
• Issuing payslips and postal service
• GPS tracking of company vehicles
• Pension and health insurance
• Insurance companies for both insuring of staff and claims handling
• Legal firms and consultants for employment related matters
• Third parties to enable the completion of pre-engagement screening checks
e.g. DBS, Garda vetting
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Complete Protective Services use the personal data it collects about me?
Complete Protective Services will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Complete Protective Services is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
3.5 Retention periods
To continue to address the legitimate purpose for which the data was originally collected the retention period for insurance and employment purposes is 10 years and for marketing purposes 1 year.
Under what circumstances will Complete Protective Services contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Complete Protective Services at your request, can confirm what information we hold about you and how it is processed. If Complete Protective Services does hold personal data about you, you can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Complete Protective Services or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Complete Protective Services accepts the following forms of ID when information on your personal data is requested:
2 forms of ID from the following:
• Drivers licence
• Birth Certificate
• Utility bill (from last 3 months)
A current version of this document is available to all stakeholders and members of staff on the Complete Protective Services website and a link to it is provided on our corporate email.