Client - Data Protection Statement | Morgan McKinley Recruitment

We want to explain clearly how we process Client personal data in the provision of our services.

For ease of use, we have split our Data Protection Statements into sections so you can easily find the information that you need:

Our Client - Data Protection Statement (this statement) provides specific information about our processing activities relevant to business clients, whose personal data we process as part of our business activities
Our Candidate - Data Protection Statement provides specific information about active/potential job seekers, and candidates supplied on assignment, whose personal data we process as part of our business
Our Other Contact - Data Protection Statement is relevant to all other individuals whose personal data we process who are not considered Candidates or Clients. This includes but is not limited to suppliers, agencies, partners, referees, emergency contacts, website users and members of the public
Our Group Information Statement provides information about the companies in the Group including relevant contact details. This information is relevant to all data subjects
The Data Protection Rights Statement is relevant to all data subjects and provides information about your rights and what you should do if you want to raise a concern

For further information about our group of companies please see.

References to “we”, “us” and “Company” shall apply to the company in the group that is processing your personal data.

When sharing Candidate personal data with the Client, the Client is independently responsible for its own compliance with applicable data protection laws when processing Candidate personal data including the provision of a separate Client privacy notice to the Candidate.

This Data Protection Statement applies to Clients

For the purposes of this Client – Data Protection Statement, Clients are those business contacts that we engage with for the purposes of delivering services including:

to hire/employ Candidates in temporary, permanent or contract positions
for resource augmentation services
consultancy or advisory services
managed service solutions
recruitment process outsourcing
managed staffing provider services
business process managed solutions

We source Client personal data in order to serve the business relationship.

We receive personal data about Clients from a variety of sources, as follows:

the personal data is often provided by the Client or created by us as part of the relationship;
the personal data may be collected from public sources;
the personal data may be collected indirectly from another person within the company of the Client;
the personal data may be collected through our website;
the personal data may be collected indirectly from a website or from a third party.

This section describes the lawful basis we may use to process Client personal data.

We process all personal data lawfully and in accordance with the requirements of the Data Protection Laws. In the EU, the GDPR sets out the legal grounds available for processing personal data. When we process personal data any one of the following legal grounds will generally apply.

CONTRACT
We will process personal data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract.

LEGITIMATE INTEREST
At times we will need to process your personal data to pursue our legitimate interests, for example for administrative purposes, to collect debts owing to us, to provide information to you, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights.

We will not process your personal data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweigh our legitimate interests.

You may object to any processing we undertake on this basis. If you do not want us to process your personal data on the basis of our legitimate interests, contact us at privacy@morganmckinley.com and we will review our processing activities.

LEGAL OBLIGATION
If we have a legal obligation to process personal data we will process personal data on this legal ground.

DEFENCE OF LEGAL CLAIMS
In limited circumstances and in accordance with the law we may use personal data in the defence of legal claims or enforcing legal rights.

CONSENT
For certain processing activities we may rely on your consent.

Where we are unable to collect consent for a particular processing activity, we will only process the personal data if we have another lawful basis for doing so.

You can withdraw consent provided by you at any time by contacting us at privacy@morganmckinley.com

We only collect the personal data that we require in order to ensure we can have a productive business relationship with Clients.

The table below sets out the general categories of personal data that we collect in relation to Clients:

Personal Data Category	Description
Communications Data	may include personal data included in communications with us over email, phone , letter and electronic communications (social platforms and chats)
Contact Data	may include a person’s name, email address, phone number, postal address, other communication details, including social media links (e.g. Skype, LinkedIn)
CCTV Data	may include images recorded on CCTV footage
Financial Data	may include payment details, bank or credit card details
Marketing Data	may include your Contact Data and any preferences in receiving marketing from us and your communication preferences.
Position Data	may include Client role, job title, reporting line etc
Reference Data	may include opinions or references provided by the Client or any feedback received about the Client.
Web Data	may include information provided on any forms completed by a Client on our website and, to the extent that it includes personal data, information on the type of device being used, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

We want to ensure that the personal data is used for the purposes that you would expect.

The table below sets out the personal data we collect, the purpose for which we collect it and our lawful basis for doing so.

Purpose/Activity	Personal Data Category	Lawful basis for processing
Managing payments and our relationship with the Client and administration of the contract to process payments to and from our business to negotiate and administer the relationship with the Client to fulfil our legal/contractual obligations to manage/respond to complaints/issues to generate placement activity on our systems for invoicing purposes to communicate payroll and other financial information to Clients to communicate due diligence/security assessments to produce aggregated models to predict trends and produce market insights and business development to undertake modelling to produce lead scores in order to predict which Candidates our Clients are most likely to deploy to undertake modelling to identify improvements in efficiencies in the engagement process	Communications Data Contact Data Financial Data Position Data Reference Data	Contract Legitimate Interest in managing payment and contracts Legal Obligation
Service delivery activities to keep in contact with the Client to discuss and review their requirements to inform, update and discuss a Candidate that may be of interest to consider a Candidate for engagement to organise and schedule meetings between a Candidate and a Client to inform the Client about progression of a Candidate through the engagement process, to discuss the contracts and on-boarding of a Candidate to discuss any reference or other pre-screening information provided for a Candidate to obtain information about the performance of a Candidate including the provision of references by the Client to understand the type of solutions (including type of Candidates) required by the Client, and build up knowledge and understanding of the Client organisation and its structure to create a record/file for the Client on our internal systems including all notes and tracking throughout the engagement process, meetings held, negotiation, on-boarding and contracting process to send Client Contact Data to Candidates in relation to the interview and on-boarding process to carry out our obligations under our contract with the Client to ask for feedback about our products or services to manage relationship with Client	Communications Data Contact Data Financial Data Position Data Reference Data	Contract Legitimate Interest in fulfilling our service delivery activities
Website Delivery to respond to web forms completed by Client to promote our products and services on the website to administer the Website for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes to tailor our products and services to better identify the right opportunities at the right time and meet Client needs more effectively to produce aggregated models to predict trends and produce market insights. to undertake modelling to produce lead scores in order to predict which Candidates our Clients are most likely to deploy to undertake modelling to identify improvements in efficiencies in the engagement process to ensure the safety and security of our website and our services	Contact Data Communications Data Web Data	Consent Legitimate Interest in the administration and security of our website
Prevention of fraud and ensuring security	CCTV Data	Legitimate Interest in ensuring security in our operations
Marketing activities to keep in contact with Clients and review requirements for services to personalise marketing communications to respond to any requests from you to send newsletters and other information that may be of interest to inform you of events or webinars that might be of interest to deliver and organise our conferences, seminars and events to follow up with attendees of our events/webinars to promote our products and services to ask for feedback about our products or services to aggregate data used as part of surveys or to produce market insights to segment and distribute targeted marketing	Marketing Data Contact Data Web Data	Consent Legitimate Interest in marketing and promoting our business

Our mission is to build lasting relationships with clients, not just for one assignment but for the purposes of building a partnership over many years.

Our goal is to continue to engage and interact with Clients, for example to keep them informed of market developments, invite them to topical seminars and networking events, and to be on hand to offer advice.

We recognise that the level of engagement we have with different Clients may vary and we manage our retention activities carefully to reflect this.

Examples of the activities that we would consider evidence of our ongoing engagement with a Client and thus a reason to continue to retain their personal data include:

a placement has been added against the Client record
a Client contact is added as a Billing Contact on a placement
a Client contact is added as a Timesheet Approver on a placement
a Client contact gives us a vacancy to recruit for
a Client contact who we send CV’s to
a Client contact who we arrange interviews with
a Client contact who extends an offer
a Client contact who we meet with face to face with or over the phone
Exchanging email correspondence or having telephone conversations with the Client

If a Client contact unsubscribes to marketing communications, no further marketing communications will be sent.

We may need to share your personal data in order to deliver our services. We will always ensure that any disclosure of personal data is undertaken in compliance with Data Protection Law and ensure that appropriate technical and organisational measures are undertaken to protect and secure any personal data that is transferred.

Client Personal Data is shared in certain circumstances as follows:

between the companies identified in this Data Protection Statement and in particular in our Group Information Statement for the purposes of administration, marketing and provision of our services
to business partners and third party service providers for the purposes of delivering services to or on behalf of our company and administration of our business, including email, chat, ticketing, Customer Relationship Management, Applicant Tracking System, payment processors, data aggregators, hosting service providers, external consultants, accountants, auditors, IT consultants and lawyers
if a company in the Group or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets
if we are under a duty to disclose or share personal data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have
to official authorities to protect our rights, property, or safety, or those of other persons (including you)
to payment service partners for the processing of payments to and from our business,
to protect our rights, property, or safety, or that of our customers or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection
to analytics and search engine providers that assist us in the improvement and optimisation of our Website. This consists of information relating to the web pages visited on the Website and tracking codes from service providers like LinkedIn and Google
to insurance brokers and providers where required for administering claims
to our email distribution partner and service providers in the case of marketing and newsletters
to Candidates for the purposes of communicating with Clients

In some circumstances we may need to transfer personal data outside of the country where it was originally collected. We will always undertake such transfers in accordance with data protection laws.

We may transfer Personal Data outside of your home country; however, we will always ensure that this is done in compliance with the relevant laws of your country.

We will normally use and share personal data outside of your country for the following reasons:

to carry out corporate oversight of our global business organization
to provide shared services in certain functions such as HR, Finance, and IT
to deploy certain tools and resources across the global organisation
to facilitate interactions between our employees across our global locations
to work with our Group Entities to identify Clients
We will ensure that any transfer of Personal Data outside of any jurisdiction is undertaken using legally compliant transfer mechanisms and in accordance with relevant laws.

We monitor for and do everything that we can to protect personal data and prevent security breaches.

We will take all steps reasonably necessary to ensure that all personal data is treated securely in accordance with this Data Protection Statement and the Data Protection Laws. In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the personal data we process.

We monitor for and do everything we can to prevent security breaches of the personal data that we process. Once we have received your personal data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your personal data can access it.

We also use secure connections to protect personal data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone.

If you think that there has been any loss or unauthorised access to personal data of any individual, please let us know immediately.

It is important to be careful when visiting third party websites and when providing personal data to third parties. We have no control over third party websites that you may access.

Websites that you access via a link on our website or otherwise, are outside our control and are not covered by this Data Protection Statement. If you access other websites using the links provided, the operators of these websites may collect personal data from you, which will be used by them in accordance with their own statements, which may differ from ours. Please check the statements on those websites before you submit any personal data to them.

Please see our separate Cookie Notice available at https://www.morganmckinley.com.cn/en/cookies-policy for further information.

We will update the date on this Data Protection Statement when we make changes to it.

We will post any changes to this Data Protection Statement on the Website and when doing so will change the effective date at the top of this Data Protection Statement.

In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

Please contact us if you have any questions or concerns about how your personal data is being used by us.

Premier Recruitment International UC is available as your central point of contact for all queries at:

Data Protection Officer
Penrose Dock Two, Alfred St,
Victorian Quarter,
Cork, T23 YY09

Email: privacy@morganmckinley.com

Please see our Data Protection Rights Statement for further information about your rights

If we are unable to resolve your concerns, you have the right to contact the supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached.

Please see section 2 of our Data Protection Rights Statement “Queries and Supervisory Authority Contact Details” for further information about relevant Data Protection Authority contact details.

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Data Protection Statement

Client - Data Protection Statement