Privacy Policy | Clark Recruitment

PRIVACY AT A GLANCE

Clark Recruitment Ltd and Clark Executive Ltd take the protection of personal data seriously.

As recruitment and executive search businesses, we process personal data to provide services including permanent recruitment, temporary and contract staffing, executive search, recruitment process outsourcing, payroll and employment administration, candidate assessment, recruitment advisory services and related activities.

Depending on your relationship with Clark, we may process information about your professional background, CV, employment history, qualifications, contact information, salary expectations, recruitment activity and, where necessary, information required for employment, payroll, right-to-work or other legal obligations.

We may receive information:

directly from you;
from our clients;
through recruitment platforms and job boards;
from LinkedIn and other professional networks;
through referrals;
from publicly available professional sources; or
from information already legitimately held within our recruitment systems.

We use personal data only where we have a lawful basis to do so.

We do not sell personal data.

Candidate information may be shared with prospective employers and relevant service providers where necessary for recruitment purposes.

Where Clark uses technology, assessments or artificial intelligence to support recruitment activities, we seek to maintain appropriate human oversight and comply with applicable data protection and AI requirements.

You have important rights under data protection law, including rights of access, rectification, erasure in certain circumstances, restriction, objection and, where applicable, data portability and rights relating to automated decision-making.

Questions or requests concerning your information can be sent to:

hello@clark.ie

ABOUT THIS PRIVACY NOTICE

This Privacy Notice explains how Clark Recruitment Ltd and Clark Executive Ltd (“Clark”, “we”, “us” and “our”) collect, use, disclose, store and protect personal data.

It applies to personal data relating to:

candidates;
prospective candidates;
individuals identified through executive search or proactive recruitment;
job applicants;
placed candidates;
temporary workers;
agency workers;
contractors;
individuals administered through payroll or outsourced employment services;
client and prospective client contacts;
hiring managers;
referees;
emergency contacts and next of kin where relevant;
suppliers and business partners;
users of www.clark.ie;
marketing subscribers; and
other individuals whose personal data we process in connection with our business.

It applies whether we receive information directly from you or from another source.

This notice should be read together with our separate Cookie Policy and any additional privacy information that we may provide in connection with a particular service or processing activity.

WHO IS THE DATA CONTROLLER?

The data controller responsible for your personal data will depend on the service being provided.

Clark Recruitment Ltd will generally be the controller for personal data processed in connection with general recruitment, permanent recruitment, temporary and contract staffing, recruitment process outsourcing, payroll and associated recruitment services.

Clark Executive Ltd will generally be the controller where personal data is processed specifically in connection with executive search or services provided by Clark Executive Ltd.

Where a particular engagement involves both entities, the respective responsibilities will depend on the circumstances. Where necessary, we will provide additional information identifying the relevant controller.

Unless otherwise stated, privacy enquiries for either company can be directed to:

Clark Recruitment Ltd / Clark Executive Ltd
The Atrium
John’s Lane
Naas East
Naas
Co. Kildare
W91 YA2W
Ireland

Email: hello@clark.ie
Telephone:

+353 45 881 888

Website: www.clark.ie

For the purposes of this notice, this is also our principal Data Protection Contact.

OUR DATA PROTECTION COMMITMENT

We seek to ensure that personal data is:

processed lawfully, fairly and transparently;
collected for specified, explicit and legitimate purposes;
not used incompatibly with those purposes;
adequate, relevant and limited to what is necessary;
accurate and kept up to date where appropriate;
retained only for as long as necessary;
appropriately secured; and
processed in a manner that respects the rights of individuals.

We also maintain appropriate policies, procedures and governance measures to demonstrate accountability for our processing activities.

PERSONAL DATA WE MAY PROCESS

The information we process depends on your relationship with Clark.

Candidates and prospective candidates

We may process:

name;
address;
telephone number;
email address;
location;
date of birth where genuinely required;
CV or résumé;
employment history;
previous and current employers;
job titles;
responsibilities;
professional achievements;
skills;
qualifications;
education and training;
professional memberships;
licences and accreditations;
professional development;
career interests;
preferred roles;
preferred locations;
preferred working arrangements;
salary and remuneration;
salary expectations;
benefits information;
notice period;
availability;
reasons for seeking or considering a move;
application history;
roles discussed with Clark;
interview availability;
interview notes;
recruiter notes;
candidate assessments;
interview feedback;
correspondence with Clark;
information supplied during telephone, online or in-person meetings;
references;
referee details;
work samples where relevant;
professional profiles;
publicly available professional information;
assessment or profiling information where applicable;
right-to-work information;
work permit or immigration information where relevant;
driving licence or professional licence information where required;
information necessary to satisfy regulatory or professional requirements; and
other information reasonably necessary to provide recruitment services.

We do not require candidates to provide information that is irrelevant to a recruitment process.

HOW WE OBTAIN CANDIDATE INFORMATION

We may receive personal data directly from you when you:

register with Clark;
apply for a vacancy;
upload or email a CV;
complete a web form;
speak with one of our recruiters;
attend an interview or meeting;
complete an assessment;
provide information during a recruitment process;
communicate with us by email, telephone, messaging platform or another channel; or
otherwise engage with Clark.

We may also obtain relevant professional information from other sources.

These can include:

LinkedIn;
professional networking platforms;
recruitment websites;
job boards;
publicly accessible professional profiles;
employer websites;
professional directories;
industry publications;
professional bodies;
publicly available corporate information;
conferences or industry information;
referrals;
recommendations;
clients;
other candidates;
former colleagues or professional contacts;
recruitment partners; and
information already legitimately held within Clark’s recruitment database or CRM.

EXECUTIVE SEARCH AND PROACTIVE CANDIDATE SOURCING

A core part of recruitment and executive search involves identifying individuals whose professional backgrounds may be relevant to employment opportunities even where those individuals have not applied to Clark.

We may therefore undertake:

executive search;
talent mapping;
market mapping;
candidate research;
professional networking;
database searches; and
proactive candidate identification.

The information collected through these activities will ordinarily be professional information, such as:

name;
job title;
employer;
previous employers;
sector;
location;
career history;
qualifications;
professional expertise;
publicly available professional contact information; and
other relevant professional information.

Our lawful basis for appropriate professional candidate sourcing will generally be our legitimate interests in providing effective recruitment and executive search services to clients and identifying potentially relevant professional opportunities for individuals.

Before relying on legitimate interests, we consider whether the processing is necessary and whether our interests are overridden by your rights and freedoms.

You have the right to object to processing based on legitimate interests.

INFORMATION OBTAINED INDIRECTLY – ARTICLE 14 GDPR

Where we obtain personal data about you from somewhere other than directly from you, we will provide the privacy information required under Article 14 GDPR where applicable.

This will ordinarily be provided:

within a reasonable period and at the latest within one month of obtaining the information;
if we communicate with you before then, at the time of our first communication; or
where the information is to be disclosed to another recipient before then, no later than when the information is first disclosed,

subject to the exemptions permitted by law.

Where we contact you proactively about an opportunity, we will generally direct you to this Privacy Notice or otherwise make appropriate privacy information available to you.

You may ask us where we obtained your professional information.

TEMPORARY WORKERS, AGENCY WORKERS AND CONTRACTORS

Where Clark employs, engages, assigns or administers a temporary worker, agency worker or contractor, we may need additional information.

This can include:

PPS Number;
tax information;
Revenue-related information;
payroll information;
bank account details;
rates of pay;
timesheets;
hours worked;
holiday information;
statutory leave;
pension information where applicable;
employment or assignment contracts;
assignment details;
workplace;
start and end dates;
attendance information;
absence information;
emergency contact information;
next-of-kin details where appropriate;
health and safety information;
workplace accident or incident information;
right-to-work information;
work permit information;
identity documentation where legally required; and
information required to comply with employment, taxation, social welfare or other statutory obligations.

This information is used to establish and administer the employment or assignment relationship and to comply with our legal obligations.

CLIENT AND PROSPECTIVE CLIENT INFORMATION

Where you represent or work for a client or prospective client, we may process:

name;
job title;
employer;
professional contact details;
professional profile;
information concerning your role;
recruitment requirements;
job descriptions;
candidate requirements;
correspondence;
meeting notes;
interview arrangements;
candidate feedback;
placement information;
contractual information;
commercial discussions;
invoicing or account contact information; and
information regarding your organisation’s relationship with Clark.

We use this information to provide recruitment services, administer our relationship, communicate with you and appropriately develop our business.

REFERENCES

Where appropriate to a recruitment process, we may obtain references.

Information may include:

referee name;
employer;
position;
professional contact information;
relationship to the candidate;
dates of employment;
role information; and
relevant information contained within a reference.

We generally seek references at an appropriate stage of the recruitment process.

Where you provide another person’s details as a referee, you should ensure that it is appropriate for you to provide those details.

SPECIAL CATEGORY PERSONAL DATA

Certain information receives additional protection under GDPR.

This includes information concerning:

racial or ethnic origin;
political opinions;
religious or philosophical beliefs;
trade union membership;
genetic information;
biometric information used for unique identification;
health;
sex life; and
sexual orientation.

Clark does not seek special category personal data unless there is a legitimate and lawful need to process it.

Special category information may arise in areas such as:

reasonable accommodations;
disability-related requirements;
occupational health;
health and safety;
workplace accidents;
statutory leave or absence;
employment administration; or
equality-related matters where lawfully processed.

Where special category personal data is processed, Clark will identify both:

an appropriate lawful basis under Article 6 GDPR; and
an applicable condition under Article 9 GDPR,

together with any additional requirements arising under Irish law.

Access will be limited to those who legitimately require the information.

REASONABLE ACCOMMODATIONS

Clark is committed to supporting individuals who require reasonable accommodations to participate fully in recruitment processes, meetings or interviews.

Where you tell us that an accommodation is required, we seek to collect only the information necessary to understand and facilitate that accommodation.

Where information needs to be communicated to a prospective employer or another party involved in the recruitment process, we seek to minimise the information disclosed.

Where possible, we will communicate what accommodation is required, rather than disclose unnecessary information concerning an underlying medical condition or disability.

CRIMINAL CONVICTION AND OFFENCE INFORMATION

Where criminal conviction, offence, vetting or similar information is relevant to a particular position, we will process such information only where:

it is necessary and proportionate;
there is an appropriate legal basis;
processing is authorised by applicable Union or Irish law; and
appropriate safeguards are applied.

Such information will not be requested routinely where it is not necessary for the relevant role or legal requirement.

PURPOSES AND LAWFUL BASES

We do not rely upon consent as a blanket lawful basis for recruitment processing.

Depending on the activity, Clark may rely on contract, legitimate interests, legal obligation, consent, vital interests or another basis permitted by law.

Our main activities can be summarised as follows.

Processing activity	Main purpose	Typical lawful basis
Candidate registration	Providing recruitment services	Contract / steps prior to contract; legitimate interests
Candidate applications	Assessing and managing applications	Contract / steps prior to contract; legitimate interests
Candidate sourcing	Identifying potential candidates	Legitimate interests
Executive search	Researching and approaching suitable professionals	Legitimate interests
Talent and market mapping	Understanding relevant talent markets	Legitimate interests
Candidate matching	Identifying relevant vacancies and candidates	Legitimate interests; contract where applicable
Candidate communication	Managing recruitment relationships	Contract; legitimate interests
CV/profile submission	Introducing candidates to clients	Contract / steps prior to contract; legitimate interests as appropriate
Interviews and feedback	Managing recruitment processes	Contract; legitimate interests
Candidate assessments	Supporting recruitment evaluation	Contract; legitimate interests; consent where appropriate
References	Verifying relevant professional information	Legitimate interests; contract; consent where appropriate
Temporary worker administration	Managing employment and assignments	Contract; legal obligation
Payroll	Paying workers and complying with statutory requirements	Contract; legal obligation
Tax and Revenue requirements	Statutory compliance	Legal obligation
Right-to-work/work permits	Establishing lawful eligibility to work	Legal obligation; contract
Health and safety	Protecting workers and complying with law	Legal obligation; vital interests where applicable
Client relationship management	Providing and administering services	Contract; legitimate interests
Recruitment process outsourcing	Delivering outsourced recruitment services	Contract; legitimate interests; or processor instructions where applicable
Accounting and invoicing	Financial administration	Contract; legal obligation; legitimate interests
Legal claims	Establishing, exercising or defending claims	Legitimate interests; legal obligation
IT and information security	Protecting systems and information	Legitimate interests; legal obligation where applicable
Fraud prevention	Protecting Clark and others	Legitimate interests; legal obligation where applicable
Quality and compliance	Maintaining standards and governance	Legitimate interests; legal obligation where applicable
Business-to-business marketing	Developing relevant professional relationships	Legitimate interests and applicable electronic marketing rules
Marketing requiring consent	Sending communications where consent is required	Consent
Website analytics/non-essential cookies	Understanding website use	Consent where required

The precise lawful basis depends on the circumstances.

Where legitimate interests are relied upon, we consider the necessity and proportionality of the processing and its potential impact on individuals.

INFORMATION REQUIRED FROM YOU

Some information is optional. Other information may be necessary for Clark to provide a service, enter into a contract or comply with the law.

For example, we may need:

contact information to provide recruitment services;
relevant employment and qualification information to assess suitability;
identity or work-authorisation information where required;
PPS, tax and bank information to employ and pay temporary workers; or
other information required by employment, taxation or regulatory requirements.

Where providing information is a statutory or contractual requirement, or necessary to enter into a contract, we will seek to make this clear where appropriate.

If required information is not provided, we may be unable to:

progress an application;
represent you for a role;
make or administer a placement;
employ or assign you as a temporary worker;
process payroll; or
provide the relevant service.

SHARING CANDIDATE INFORMATION WITH CLIENTS

Introducing candidates to prospective employers is a fundamental part of recruitment.

Depending on the circumstances, information supplied to clients may include:

CV;
candidate profile;
relevant professional experience;
skills;
qualifications;
salary expectations;
notice period;
availability;
recruiter assessment;
interview information; and
other information genuinely relevant to assessing suitability.

For normal candidate-led recruitment, we generally engage with the candidate concerning the relevant opportunity before formally presenting them to a prospective employer.

Different processes may apply to legitimate executive search, confidential search, talent mapping or anonymised market research activities.

Clark seeks to ensure that personal data is not disclosed unnecessarily.

WHO WE MAY SHARE INFORMATION WITH

Where appropriate and lawful, personal data may be shared with categories of recipient including:

prospective employers;
existing clients;
hiring organisations;
hiring managers;
client HR teams;
organisations to which temporary workers or contractors are assigned;
payroll and payment service providers;
pension or benefits providers where applicable;
recruitment technology and CRM providers;
IT and cloud service providers;
communication and productivity technology providers;
website and hosting providers;
job boards;
recruitment advertising services;
professional networking platforms;
assessment or psychometric service providers;
appropriate background or verification providers;
accountants;
auditors;
insurers;
legal advisers;
professional consultants;
certification or quality auditors where applicable;
government departments;
Revenue;
regulatory bodies;
law enforcement agencies;
courts;
the Data Protection Commission; and
other recipients where required or permitted by law.

Where a provider processes personal data on our behalf, we require appropriate contractual and data protection protections.

Clark does not sell candidate personal data.

RECRUITMENT PROCESS OUTSOURCING AND MANAGED SERVICES

Clark may provide Recruitment Process Outsourcing (“RPO”), managed recruitment, payroll or other outsourced services.

Our role under data protection law can differ depending on the service.

In some circumstances Clark determines why and how personal data is processed and acts as a controller.

In other circumstances, Clark processes information on documented instructions from a client and acts as a processor.

A client may also independently act as a controller for personal information processed in connection with its own recruitment or employment activities.

Where Clark acts as a processor, the relevant client’s privacy information may also apply.

PSYCHOMETRIC, BEHAVIOURAL AND OTHER ASSESSMENTS

Clark may provide or facilitate psychometric, behavioural, competency, skills, aptitude, occupational or other assessments where appropriate.

Where assessments are used, we seek to ensure that individuals understand:

why the assessment is being carried out;
what information is being assessed;
how the results are intended to be used;
who will receive relevant results;
the role of the assessment within the recruitment process; and
any relevant rights.

Assessment results should generally support rather than replace appropriate human assessment and professional judgement.

Where an independent assessment provider is involved, its privacy information may also apply.

ARTIFICIAL INTELLIGENCE AND TECHNOLOGY-ASSISTED PROCESSING

Clark may use technology, including artificial intelligence-enabled functionality, to support appropriate aspects of recruitment and business administration.

Depending on the tools in use, technology may assist with activities such as:

administration;
searching information;
recruitment research;
candidate sourcing;
document processing;
summarising information;
drafting;
workflow management;
scheduling;
identifying potentially relevant information;
candidate or vacancy matching;
analysis; and
operational efficiency.

The fact that technology assists a process does not remove Clark’s responsibility for protecting personal data.

Where personal data is processed through AI-enabled tools, we seek to ensure:

an appropriate lawful basis exists;
only relevant information is used;
confidentiality and security are considered;
output is appropriately reviewed;
risks of inaccurate or biased output are considered;
appropriate human oversight is maintained; and
applicable GDPR and EU Artificial Intelligence Act requirements are addressed.

Clark does not treat an AI-generated output, score, recommendation, summary or assessment as inherently correct simply because it has been generated by technology.

Where AI is used to support recruitment decisions, appropriate professional and human judgement should remain an important part of the process.

PROFILING AND AUTOMATED DECISION-MAKING

Recruitment necessarily involves assessing whether professional experience, skills and other relevant characteristics correspond with the requirements of a position.

Clark may therefore use personal data to assess factors including:

professional experience;
skills;
qualifications;
seniority;
sector experience;
location;
salary expectations;
career preferences;
availability; and
potential suitability for a position.

Technology may assist recruiters in searching, filtering, organising or identifying potentially relevant information.

Unless we specifically inform you otherwise, Clark does not intend to make decisions producing legal effects or similarly significant effects upon candidates solely through automated processing without appropriate human involvement.

If Clark implements processing that falls within Article 22 GDPR, we will provide the additional information and safeguards required by law.

Where applicable, these may include rights to:

obtain human intervention;
express your point of view; and
contest a decision.

INTERNATIONAL DATA TRANSFERS

Clark uses modern technology and service providers to operate its business.

Some service providers or their supporting infrastructure may process personal data outside Ireland or the European Economic Area.

Where personal information is transferred outside the EEA, Clark will ensure that an appropriate lawful transfer mechanism is available.

Depending on the circumstances, this may include:

a European Commission adequacy decision;
European Commission Standard Contractual Clauses;
appropriate supplementary measures;
another legally recognised transfer mechanism; or
a permitted derogation in limited circumstances.

We assess relevant suppliers and transfer arrangements as appropriate.

You may contact us for further information about safeguards applying to relevant transfers.

HOW LONG WE KEEP PERSONAL DATA

Clark does not retain personal data indefinitely.

We retain information only for as long as reasonably required for the purpose for which it was collected and for legitimate legal, contractual, regulatory and business requirements.

The applicable period will depend on factors including:

the nature of the information;
the purpose for which it is held;
whether you continue to engage with Clark;
whether you are an active or potentially relevant candidate;
whether a recruitment process remains active;
whether a placement or employment relationship exists;
applicable employment requirements;
applicable tax, payroll or financial-record requirements;
statutory requirements;
contractual obligations;
potential or actual legal claims;
relevant limitation periods;
regulatory requirements; and
legitimate requirements to demonstrate how a recruitment or employment process was managed.

Candidate records

Candidate records may be retained for an appropriate period while Clark continues to provide recruitment services or considers that the individual’s professional background may reasonably be relevant to future opportunities.

Candidate records are subject to periodic review and data minimisation.

Executive search information

Professional information gathered through executive search or market mapping will be retained only for a period proportionate to the relevant search, future legitimately relevant recruitment activity and associated legal or business requirements.

Placement records

Records concerning placements may be retained for an appropriate period to:

administer the placement;
provide aftercare;
manage contractual obligations;
administer replacement or rebate arrangements;
maintain necessary records; and
establish, exercise or defend legal claims.

Temporary worker, payroll and employment records

Records required for employment, payroll, taxation, pensions, financial accounting and statutory compliance will be retained for the periods required under applicable law and for relevant limitation or legal-claim periods.

Client records

Relevant client records may be retained for the duration of the relationship and for an appropriate period afterwards for contractual, financial, legal, regulatory and legitimate relationship-management purposes.

Assessments

Assessment information will be retained only for as long as reasonably required for the relevant recruitment, development or related purpose, subject to legal and contractual requirements.

Marketing records

Marketing information may be retained while a legitimate professional relationship or appropriate marketing purpose continues.

Where you opt out, we may retain limited suppression information so that your preference continues to be respected.

Legal and compliance records

Information may be retained for longer where necessary in connection with:

actual or anticipated litigation;
regulatory investigations;
audit;
fraud prevention;
insurance;
statutory requirements; or
establishment, exercise or defence of legal claims.

Information no longer required will be deleted, anonymised or securely disposed of in accordance with Clark’s data retention procedures.

ACCURACY AND DATA MINIMISATION

We seek to maintain accurate and relevant information.

Please tell us where information we hold about you is inaccurate or has materially changed.

Candidates should avoid supplying information that is not relevant to recruitment.

Unless specifically required and lawfully requested, CVs should generally not contain unnecessary information such as:

PPS Numbers;
bank details;
passport copies;
detailed medical information;
religious beliefs;
political opinions;
sexual orientation;
unnecessary family information; or
other sensitive information irrelevant to assessing professional suitability.

SECURITY

Clark maintains appropriate technical and organisational safeguards designed to protect personal data against:

unauthorised access;
unauthorised disclosure;
accidental loss;
destruction;
alteration;
misuse; and
unlawful processing.

Measures may include, as appropriate:

access controls;
authentication;
permissions management;
secure systems and cloud infrastructure;
device security;
password controls;
security monitoring;
backups;
staff training;
confidentiality obligations;
privacy and security policies;
supplier due diligence;
processor agreements;
incident response procedures; and
ongoing review of controls.

Access to personal information is restricted according to legitimate business need.

PERSONAL DATA BREACHES

Clark maintains procedures to identify, assess, manage and document personal data breaches.

Where a breach is likely to result in a risk to individuals’ rights and freedoms, we will notify the Data Protection Commission where required by law.

Where a breach is likely to result in a high risk to affected individuals, we will also communicate with those individuals where required.

WEBSITE AND COOKIES

When you use www.clark.ie, we may process technical information such as:

IP address;
browser information;
device information;
dates and times of access;
pages visited;
referring source;
cookie identifiers; and
information concerning interaction with the website.

Some cookies are necessary for the operation of the website.

Other cookies or similar technologies may be used for analytics, functionality or marketing only where permitted by applicable law.

Where consent is required for non-essential cookies, they should not be placed or accessed before appropriate consent has been obtained.

Further information is contained in our separate Cookie Policy.

JOB BOARDS, LINKEDIN AND THIRD-PARTY PLATFORMS

Individuals may interact with Clark through third-party platforms such as:

LinkedIn;
job boards;
recruitment websites;
assessment platforms; or
other professional services.

These organisations may independently determine how they process information obtained directly through their platforms.

Their own privacy notices may therefore apply in addition to this Privacy Notice.

Once information is received and processed by Clark, our processing is governed by this Privacy Notice and applicable data protection law.

MARKETING AND PROFESSIONAL COMMUNICATIONS

Where permitted by law, we may communicate with existing or prospective business contacts regarding:

recruitment services;
market information;
relevant professional updates;
events;
salary information;
newsletters; or
other Clark services.

We will comply with applicable GDPR and electronic marketing requirements.

You may object to direct marketing or unsubscribe from marketing communications at any time.

Opting out of marketing does not prevent us from contacting you regarding:

an active application;
a recruitment process;
a role being discussed with you;
an assignment;
payroll;
employment;
a contractual matter;
an existing service relationship;
a legal or regulatory issue; or
another communication that is not direct marketing.

YOUR DATA PROTECTION RIGHTS

Subject to the conditions and limitations contained in applicable law, you may have the following rights.

Right of access

You can ask whether we process your personal data and request access to personal data held about you.

Right to rectification

You can ask us to correct inaccurate personal data or complete incomplete information.

Right to erasure

You may ask us to delete personal data in certain circumstances.

This right is not absolute. Clark may be entitled or required to retain certain information for legitimate legal, contractual, regulatory or other purposes.

Right to restriction

You may have the right to require us to restrict particular processing in certain circumstances.

Right to data portability

Where the legal requirements apply, you may have the right to receive certain personal data in a structured, commonly used and machine-readable format or ask for it to be transferred to another controller.

Right to object

Where processing is based upon legitimate interests, you may object on grounds relating to your particular situation.

We will consider any objection in accordance with applicable data protection law.

You have the right to object at any time to processing for direct marketing purposes.

Right to withdraw consent

Where our processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Rights concerning automated decision-making

Where Article 22 GDPR applies, you may have rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.

EXERCISING YOUR RIGHTS

You can make a data protection request by contacting:

Email: hello@clark.ie

or writing to:

Data Protection Contact
Clark Recruitment Ltd / Clark Executive Ltd
The Atrium
John’s Lane
Naas East
Naas
Co. Kildare
W91 YA2W
Ireland

Please provide enough information for us to identify you and understand your request.

We may request reasonable proof of identity where necessary to protect personal information from unauthorised access, alteration or deletion.

We will respond within the timeframe required by applicable data protection law.

In most cases, GDPR requires us to respond without undue delay and ordinarily within one month, subject to the provisions permitting an extension for complex or numerous requests.

Where we cannot fully comply with a request, we will explain the reason where required by law.

COMPLAINTS

If you have concerns regarding how Clark processes your personal data, we encourage you to contact us first so that we can investigate and address the matter.

You also have the right to lodge a complaint with the Irish supervisory authority:

Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland

Website: www.dataprotection.ie

Depending on your circumstances, you may also have the right to contact another competent EEA supervisory authority.

THIRD-PARTY WEBSITES

Our website or communications may contain links to independent third-party websites.

Clark does not control how independent third parties process personal data.

You should review the relevant organisation’s privacy information before providing information directly to it.

CORPORATE RESTRUCTURING

If Clark is involved in a merger, acquisition, reorganisation, financing, transfer or sale of all or part of its business, relevant information may be disclosed to professional advisers and appropriate prospective parties where lawful.

Any such disclosure will be subject to appropriate confidentiality and data protection requirements.

Where a successor organisation assumes responsibility for relevant personal data, the information may be transferred as part of the business transaction where lawful.

LEGAL CLAIMS, INVESTIGATIONS AND REGULATORY MATTERS

Clark may process, retain or disclose personal information where necessary to:

obtain legal advice;
establish, exercise or defend legal claims;
manage litigation;
comply with a court order;
respond to a lawful request from law enforcement;
cooperate with a regulator;
investigate suspected fraud or wrongdoing;
meet insurance requirements;
protect the rights or safety of Clark or another person; or
comply with other applicable legal requirements.

CHILDREN AND YOUNG PEOPLE

Clark’s services are primarily directed to people of working age.

Where we legitimately provide recruitment or employment services involving an individual under the age of 18, we will take account of their age and apply appropriate additional safeguards.

We do not intentionally seek unnecessary personal information relating to children.

PRIVACY BY DESIGN, IMPACT ASSESSMENTS AND GOVERNANCE

Clark considers data protection when introducing or materially changing systems, suppliers or processing activities.

Where required, we undertake a Data Protection Impact Assessment or another appropriate risk assessment.

This is particularly relevant where processing may involve:

new technologies;
significant profiling;
special category information;
systematic monitoring;
large-scale personal data;
potentially significant automated processing; or
other processing likely to present a high risk to individuals.

We also seek to maintain appropriate:

processing records;
supplier governance;
retention procedures;
legitimate-interest assessments;
security controls;
data subject request procedures;
breach-management procedures; and
staff awareness and training.

AI GOVERNANCE IN RECRUITMENT

Clark recognises that the use of artificial intelligence within recruitment requires particular care because recruitment activities can materially affect people’s employment opportunities.

When assessing or implementing AI-enabled systems, we will consider, as applicable:

the purpose for which the system is being used;
its impact upon candidates;
GDPR requirements;
EU Artificial Intelligence Act requirements;
data minimisation;
accuracy;
transparency;
fairness;
discrimination and bias;
accessibility;
human oversight;
information security;
confidentiality;
supplier governance;
record keeping;
risk assessment;
Data Protection Impact Assessment requirements; and
appropriate monitoring.

Where an AI system is subject to additional obligations because of how it is classified or used under applicable law, Clark will take appropriate steps to comply with those obligations.

CHANGES TO PURPOSE

We will use personal data for the purposes for which it was collected and for compatible purposes permitted by law.

If we intend to use personal data for a materially different purpose, we will consider whether that further processing is lawful and, where required, provide additional privacy information before commencing that processing.

CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice where necessary because of:

changes to our services;
changes in how we process personal data;
changes to technology;
changes to suppliers;
changes to applicable legislation;
regulatory guidance; or
improvements to our privacy practices.

The latest version will be made available through www.clark.ie and will identify the date on which it was last updated.

Where a change materially affects individuals or how their personal data is processed, we will take appropriate steps to communicate the change where required.