EU PRIVACY NOTICE

1.    ABOUT OLENICK GLOBAL

1.1    We are Olenick Global Limited, a company registered in Northern Ireland, with registered address at 3rd Floor Forsyth House, Cromac Square, Belfast, BT2 8LA (we, us, our). 

1.2    We are part of a group of companies, with headquarters in Chicago and branches in Philadelphia and Argentina (any reference to our Group Companies shall be a reference to those other entities).

1.3    We provide a range of services to our clients, including software testing and quality assurance, system integration, dev ops, software engineering, training and management consulting through the placement of Resources or otherwise. From time to time we might also source permanent members of staff for our clients. Any such services, our Services.

1.4    We also use our website to advertise available positions for which we (or our Group Companies) require Resources. 

2.    ABOUT THIS NOTICE

2.1.    The nature of our Services means that we will process Personal Data (that is information relating to an individual who can be identified). The Personal Data we hold may be about you or other people. This notice is intended primarily to let our Clients and Prospective Clients and any Resources and Applicants know how we’ll manage the Personal Data they give us or which we collect about them. 

2.2.    We might need to change this privacy notice from time to time. We will publish our privacy notice on our website (available at www.olenick.com) and do our best to update you directly if we think the changes might affect you. Please do keep an eye on our notice before sending us any Personal Data.

2.3.    In some instances, we may need to share Personal Data with third parties (which parties will also act as controllers in respect of, and be responsible for their handling of any Personal Data shared). For instance:

•    If you are an Applicant or a Resource we may need to transfer your name and certain information from your CV to our Client.

•    If you are an Applicant submitting an application for a position to be filled by a Group Company, we will need to transfer your details to that Group Company to facilitate your application.

This notice only deals with our use of Personal Data. Other people or companies (including Group Companies based outside the EEA) with whom we share Personal Data are not bound by this privacy notice. 

2.4.    If you have any questions about the policy feel free to send us an email to This email address is being protected from spambots. You need JavaScript enabled to view it.  

3.    WHO DO WE HOLD PERSONAL DATA ABOUT?

3.1.    It is likely that we will process Personal Data (that is information which can be used to identify someone) in connection with our Services. This Personal Data may be about you or other people. This notice explains how we will use any Personal Data we hold on the following groups of people:

(i)      Clients: any businesses (in each case including key contact data) which enter into a contract for services with us;

(ii)     Prospective Clients: key contacts in businesses we think may be interested in receiving our Services, but which are not in contract with us;

(iii)    Applicants: that is anyone who submits their details to us for the purposes of becoming a Resource or who we think may be interested in an available position; and

(iv)    Resources: that is any individual engaged by us (whether directly or through a company) for placement with a Client.


4.    CONTROLLER OR PROCESSOR

4.1.     We are a Controller in respect of any Personal Data which we hold about Clients, Prospective Clients, Applicants and Resources. This means we decide what data we think we need to collect and how to use it.

5.    WHAT PERSONAL DATA DO WE HOLD AND WHERE DO WE GET IT FROM?

5.1    We may collect Personal Data in the following ways:

(i)    Information an individual provides us with directly

For Clients and Prospective Clients this might include:
•    Identity data of their key contacts 
•    Information about their business, workforce and needs
•    Information about their requests, disputes, complaints or feedback
•    Information about their marketing preferences
•    Payment details
•    Transaction data about services they have purchased 
•    Any information which they or their staff provide us with when they contact us, whether by post, email or telephone

For Applicants and Resources this might include:
•    Identity and contact data
•    Information about their location
•    Information relating to their work experience
•    Any other information set out in any CV that they provide 
•    Any information which they provide us with when they contact us, whether by post, email or telephone

(ii)    We may collect some information ourselves or source it from third parties in the following circumstances:

For Applicants this might include information obtained from:
•    References provided by the Applicant
•    Information obtained from publicly available resources such as business websites and social media sites.

For Resources this might include information passed to us by our Clients
•    Relating to the quality of any services provided on our behalf; or
•    As may be required to assess commission payable or rebates due in respect of permanent placements.

(iii)    We may collect some Information automatically about visitors to our website. This might include:

•    Usage data about how a website visitor uses our website
•    Traffic data: which might include information about websites, ads or links clicked on by  the user before, during or after visiting our website
•    Technical data: which might include information about the device used by the user to access our website. This may include using Google Analytics. For more information about what cookies we use, please see our Cookies Policy, which can be accessed here.

5.2    We may collect and process Special Categories of data (that is, details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data or data relating to criminal convictions in relation to Resources. If we do so, we will only process as is strictly necessary for performing or exercising our obligations or rights under employment law or to ensure equality of opportunity.

6. HOW WE USE PERSONAL DATA AND OUR LAWFUL BASES FOR DOING SO

6.1     We may use Personal Data relating to our Clients and Prospective Clients for the processing activities set out in the table below.

PURPOSE

DESCRIPTION

LAWFUL BASIS

To provide our services

 

This shall include any processing activities which we need to carry out in accordance with any contract (and statement of work) entered into with our Client. This may also include contacting you to notify you about any changes to our services, provided maintenance or support.

 

Necessary for the performance of the contract for the provision of our services or taking steps necessary to enter into a contract.

Administration and Dispute Resolution

We may also need to process Personal Data about you to meet our internal administration requirements and for matters such as dispute resolution or credit control.

 

Legitimate Interest of protecting our business.

Marketing

From time to time we might contact you by telephone or email about updates to our services, new features or functions or new products we are bringing out. We will always include the right to opt out in any such correspondence.

 

Legitimate Interest of promoting our business (or consent where required by law).

 

6.2     We may use Personal Data relating to Applicants and Resources for the activities set out in the table below.

PURPOSE

DESCRIPTION

LAWFUL BASIS

To process any application we receive from you in relation to a position

 

If the position is with one of our Group Companies, this will mean transferring the application to such Group Company, which may be based outside the EEA. The location of the Group Company will be clearly marked on the post published on our website

Explicit Consent (for transfers outside EEA) and/or appropriate safeguards implemented between us and our Group Companies.

 

If you are applying for a position which we are advertising this may include carrying out due diligence (checking references) and passing your name and CV to the relevant Client.

Taking steps necessary to enter into a contract with you

For HR purposes

This may include holding an HR file which includes details of positions undertaken, payments/salary, bonuses and any disputes

Legitimate interest of running our business efficiently

Process salary payment or agreed fees

This may include us using bank details provided to us by a Resource.

Necessary for the performance of the contract between you and us.

To add you to our database of Applicants

If you have agreed that we may do so, we will add you to our database of Applicants and may contact by email or telephone if a position becomes available which we think may be of interest to you. We will always give you the option to opt out of receiving any further communications.

 

Consent

From time to time we might also contact you to make sure you would still like to remain on our database and to make sure that the information we hold is up to date

Necessary to comply with our lawful obligations of ensuring your consent remains valid and the data we hold on you is accurate and up-to-date.

 

Administration and Dispute Resolution

We may also need to process Personal Data about you to meet our internal administration requirements, compliance with legal, regulatory and corporate governance obligations and good practices, for matters such as dispute resolution and credit control, operational reasons, such as recording transactions, training and quality control and credit checking.

Legitimate Interest of protecting our business.

 

7.    DO WE DISCLOSE PERSONAL DATA TO ANYONE ELSE?

7.1    We may disclose Personal Data to our employees and third parties who are contracted to help us provide our Services. Any such third parties will be acting as processors on our behalf and will be contractually bound only to use the data in accordance with our instructions and to implement adequate security measures. Our head office, Olenick and Associates Inc. processes data on our behalf and have implemented such safeguards in respect of any data transferred in this manner.

7.2    We may share Personal Data with third parties (which will also be acting as controllers in respect of that Personal Data) in the following circumstances:

(i)       If we are under a legal duty to do so or if it is required to enforce or apply our contracts or to protect the operation of our website, or the rights, property or safety of us or others. For example, this may include transferring payment details to HMRC.

(ii)      If we sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners will only be entitled to use Personal Data in accordance with the provisions set out in this privacy notice.

(iii)    If you apply for a position advertised by us on behalf of one of our Group Companies or a third party. This company may be based outside the EEA in a location with lower data protection at law than in the EEA. The location of the company is clearly marked on the vacancy post.

(iv)    If you have agreed to be placed with a Client, we will transfer your name and CV to the named Client for use by the Client in connection with the Services provided.

(v)    Since our head office, Olenick and Associates, Inc. is responsible for our website, the information collected using cookies is used generally by the Olenick Group for assessing usage and developing general online marketing strategies.

If you have any questions about who your data might be transferred to please send us an email at This email address is being protected from spambots. You need JavaScript enabled to view it..

8.    WHAT SECURITY PROCEDURES DO YOU HAVE IN PLACE?

8.1    We implement robust security procedures to safeguard the data we hold. We have a security policy in place and have appointed a data protection officer, responsible for data management. Our IT department is required to ensure that acceptable security standards are implemented and maintained and regularly check and scan security hardware and software to ensure it is functioning properly. We also use encryption techniques to encrypt any data we store and transfer.

8.2    There are some steps you can take to help make sure that your data is protected. For example:

(a)         If you are contacting us with a query or complaint, only ever give us your work details rather than your personal contact details; and

(b)        If you are sending any financial details or sensitive information, consider sending it in separate emails or encrypted, password protected documents.

9.    WHERE DO YOU STORE THE PERSONAL DATA YOU COLLECT?

9.1    Our servers are currently based in the US and managed by our head office, Olenick and Associates Inc. which is based in Illinois. Our head office, processes data on our behalf and both we and Olenick and Associates Inc. have implemented adequate safeguards in respect of any transferred in this manner.

9.2    If you would like further information about where we store your data, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it..
 

10.    FOR HOW LONG DO WE STORE PERSONAL DATA?

10.1    Our retention policies are as follows: 

DATA

RETENTION PERIOD

Accident books (which may include data relating to Clients or Resources)

3 years after date of last entry

Accounting records

2 years for private companies, 6 years for public companies

 

Details of transactions or disputes

6 years from completion of the services or date of the dispute in question

Tax information

Not less than 3 years after the end of the financial year to which they relate

Records relating to retirement benefits schemes

6 years from the end of the scheme

Details relating to maternity pay

3 years after the end of the tax year in which maternity ends

 

Details relating to statutory sick pay

3 years after the end of the tax year to which they relate

Salary records (overtime, bonuses, expenses)

6 years

Applications

1 year (subject to obtaining renewed consent thereafter)

 

Parental leave

5 years from birth/adoption of a child or 18 years if child receives disability allowance

Details relating to pensions

12 years after benefit ceases

 

Time cards

2 years after audit

 

 

11.    YOUR RIGHTS AS A DATA SUBJECT

11.1    You (as the Data Subject) have the following rights in respect of Personal Data held by us (as the Controller): 

(a)    Right to be informed: the right to be informed about what Personal Data the Controller collects and stores about you and how it’s used.

(b)    Right of access: the right to request a copy of the Personal Data held, as well as confirmation of:
(i)      the purposes of the processing;
(ii)     the categories of personal data concerned;
(iii)    the recipients to whom the personal data has/will be disclosed;
(iv)    for how long it will be stored; and
(v)     if data wasn’t collected directly from you, information about the source.

(c)    Right of rectification: the right to require the Controller to correct any Personal Data held about you which is inaccurate or incomplete.

(d)    Right to be forgotten: in certain circumstances, the right to have the Personal Data held about you erased from the Controller’s records.
 
(e)    Right to restriction of processing: the right to request the Controller to restrict the processing carried out in respect of Personal Data relating to you. You might want to do this, for instance, if you think the data held by the Controller is inaccurate and you would like to restrict processing until the data has been reviewed and updated if necessary.

(f)    Right of portability: the right to have the Personal Data held by the Controller about you transferred to another organisation, to the extent it was provided in a structured, commonly used and machine-readable format.

(g)    Right to object to direct marketing: the right to object where processing is carried out for direct marketing purposes (including profiling in connection with that purpose.)

(h)    Right to object to automated processing: the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects (or other similar significant effects) on you.

11.2    If you want to avail of any of these rights, you should contact us immediately at This email address is being protected from spambots. You need JavaScript enabled to view it.. If you do contact us with a request, we will also need evidence that you are who you say you are to ensure compliance with data protection legislation. 

11.3    Since some of the data we hold relates to transactions and data collected in connection with employment, we may be able to rely on certain exemptions under the Data Protection Act 2018 in respect of certain requests. These exemptions may enable us to resist the disclosure of information in certain circumstances, and exempted from some notification obligations and some requests in respect of rectification.

11.4    We will confirm to you in writing to acknowledge receipt of any request we receive relating to your rights as a Data Subject, and we will let you know if we have complied with your request. If having, carried out an assessment, we believe we have an overriding reason for retaining the data, we will let you know why we have reached that conclusion.

12.    WHAT HAPPENS IF YOU NO LONGER WANT US TO PROCESS PERSONAL DATA ABOUT YOU?

12.1    You may notify us at any time that you no longer want us to process Personal Data about you for particular purposes or for any purposes whatsoever. A request to stop receiving direct marketing communications will not impact your ability to continue to receive our Services or apply for a position.

13.    WHAT TO DO IF YOU AREN’T HAPPY ABOUT HOW WE PROCESS PERSONAL DATA RELATING TO YOU

13.1    If you have any questions or concerns about how we are using Personal Data about you, please contact our Data Protection Officer immediately at our registered address (see paragraph 1.1 above) or by email to This email address is being protected from spambots. You need JavaScript enabled to view it.. If we are processing Personal Data about you on behalf of our Client, we will need to pass your complaint to our Client – we will only do so with your consent.

13.2    If you wish to make a complaint about how we have handled Personal Data about you, you may lodge a complaint with the Information Commissioner’s Office by following this link: https://ico.org.uk/concerns/

Last updated: 10th July 2018.
 

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