Welcome to the Reperio Human Capital privacy and cookies policy. We respect your privacy and are committed to protecting your personal data.
Reperio Human Capital (“Reperio”) acts as an employment agency and an employment business. Reperio must process personal data (including sensitive personal data) so that we can provide these services and run our business. In doing so, Reperio acts as a data controller.
This policy will inform you how we look after your personal data;
- when you interact with us as one of our customers or suppliers (or as an employee or representative of same);
- when you visit our premises;
- when you visit and use our website (regardless of where you visit it from), currently www.reperiohumancapital.com (our website), as a customer, supplier, or otherwise;
- if we otherwise process your personal data, including information you provide on an application or registration form, or which we may collect from other sources such as online job boards and other professional networks.
1. IMPORTANT INFORMATION / WHO WE ARE
Reperio consists of three companies, Reperio Human Capital Limited (registered in the UK under company number 07242009) (Reperio UK), Reperio Human Capital (Ireland) Limited (registered in Ireland under company number 587781) (Reperio IE) and Reperio Human Capital, Inc. (registered in North Carolina under EIN 83-3722447) (Reperio US).
Patrick Bleakley (Data Protection Officer)
Email address: email@example.com
Postal address: 6-9 Trinity Street, Dublin 2, D02 EY47
Patrick Bleakley (Data Protection Officer)
Email address: firstname.lastname@example.org
Postal address: 3rd Floor, 207 Regent Street, London, W1B 3HH
Patrick Bleakley (Data Protection Officer)
Email address: email@example.com
Postal address: 1 Glenwood Avenue, Raleigh, NC 27603
If you are a citizen of the European Union and/or the United Kingdom, you have the right to make a complaint at any time under the General Data Protection Regulation (GDPR) to:
- The Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), in respect of any processing carried out by us in the UK.
- The Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (https://www.dataprotection.ie/), in respect of any processing carried out by us in Ireland.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or DPC so please contact us in the first instance.
Changes to this Policy and Your Data
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.
2. THE DATA WE COLLECT ABOUT YOU
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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Telephone Recordings - Telephone conversations may be recorded to improve training, to ensure a high level of consistent customer service, or otherwise as required in our legitimate interests or to process contracts we have with you or your business.
- Technical Data - We may use certain technical services to gather technical data online whenever you use our website. You are not personally identifiable from any of the technical data we collect using such services.
- Social Media – where you have engaged us through social media facilities such as LinkedIn or similar websites, we may receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information, where you have given clear consent to do so.
- Publicly Available Information – we may collect personal information about you from publicly available sources, including social media sources such as LinkedIn. This can include your name, address and other publicly available information. As far as possible, we ensure that where any third-parties are involved in supplying such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register.
This data will either be provided to us by you, collected by us from third parties or publicly available sources, or collected via automated methods.
We do not collect any Special Categories of Personal Data about you (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) or information about criminal convictions and offences.
If you Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
A Cookie is a small text file that is added to your device’s hard drive by a web server within our domain. Cookies cannot be used to run software programs or add a virus to your device. They are unique to you and avoid you having to input the same information and preferences each time you visit our website.
Our website servers automatically record 'log files' containing information about the volume and characteristics of our website traffic (e.g. IP address, numbers of pages viewed, length of time spent on our website). Log files are used to build pictures of how our website is used and help to monitor and improve the service provided by our website. You cannot be identified from your log files.
We also use Google Analytics to collect information about traffic on our website, what type of device was used to view the website and the probable geographic location of the visitor. To learn more about Google Analytics click here.
3. 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 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.
Generally we do not rely on consent as a legal basis for processing your personal data other than as set out below in relation to marketing.
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 contact us if you need details about the specific legal ground we are relying on to process your personal data.
Our Standard Business Operations:
- To provide the services that we contract to do so with you;
- To provide you with information that you request from us;
- To confirm your identity as a natural living person; and
- As part of our billing, payments and recovery processes.
We may also use contact information to notify you of any office closure, and how you may contact us should an emergency arise during the closure period.
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in or out over the phone, by email, or online.
We strive to provide you with choices regarding personal data uses for marketing and advertising and currently use Microsoft Office 365® and/or Mailchimp to manage our email correspondence. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us 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 product or service purchase or any other transaction.
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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering or terrorist related activities.
Children Under Sixteen
Our website and services are not intended to be used by children under 16 years old. We will never knowingly collect data from children below 16 years old. If you become aware of such a child (or another person) supplying data to us, please contact us.
We will take care when processing such data and only do so where one of the legal grounds set out above applies.
4. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in in paragraph 3 above or otherwise below:
- with HM Revenue & Customs, the Irish Revenue Commissioners, the Internal Revenue Service, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, Ireland, or the United States who require reporting of processing activities in certain circumstances;
- with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement. 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;
- with third party purchasers, if our assets are acquired by a third-party, and data is transferred as part of the purchased assets;
- with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union or United Kingdom who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above;
- where you have appointed a third-party umbrella company to provide invoicing services (or other services on your behalf) we may disclose your information to them in connection with such services;
- with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable);
- with service providers acting as processors based in the European Union or United Kingdom who provide IT and system administration services, as set out below:
o with email marketing services i.e. Mailchimp to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails;
o with our customer relationship management software provider, which stores all customer details (these are held on a secure server only accessible with an authorised username and password);
o with analytical service providers in order to analyse our website’s traffic to improve services; and
o with processors offering software tools, or EU or UK based external servers (including externally provided original and backup servers), that are used to store personal information provided by you on our behalf (our current servers are maintained by Microsoft Office 365® and Access UK Limited, whose privacy policies are available at https://privacy.microsoft.com/en-gb/privacystatement and https://www.theaccessgroup.com/en-gb/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 the minimal personal data required for the specified purposes and in accordance with our instructions.
We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing purposes.
5. INTERNATIONAL TRANSFERS
Where you are a European citizen, we do not transfer your personal data outside the European Economic Area (EEA), Switzerland and/or the UK, and any processing of personal data will be undertaken by Reperio IE or Reperio UK.
Where you are a US citizen, we do not transfer your personal data outside of the USA, and any processing of personal data will be undertaken by Reperio US.
Reperio makes use of internal group data barriers which prevent such processing as outlined above.
The exemptions to this are where:
a) As a US citizen, you have expressly or impliedly consented to your personal data being transferred in connection with a potential role in Europe and/or the UK; or
b) As a European and/or UK citizen you have expressly or impliedly consented to your personal data being transferred in connection with a potential role in the USA.
Such data will only be processed specifically for the purposes for which it was collected and in accordance with the terms of this policy.
6. DATA SECURITY
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.
7. DATA RETENTION
Reperio will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employees Agencies and Employment Businesses Regulations 2003 require us to keep work-seeker records for at least one year from: (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records for as long as is legally required by HMRC, the Irish Revenue Commissioners or the IRS (as applicable) and under associated legislation.
Where Reperio has obtained your consent to process your personal data we will do so in line with our retention policy. Upon expiry of that period, Reperio will seek further consent from you. Where consent is not granted, Reperio will cease to process your personal data.
8. YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (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.
Request correction of the personal data that we hold about you. 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 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 and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or 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.
Withdraw consent at any time 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.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.