CCM Recruitment International (“CCM”) is a group of companies first established in Ireland (CCM International Limited) on February 1988. CCM later expanded its business to Australia (CCM Recruitment International Pty Ltd) and is ultimately owned by MIMS Pte Ltd (based in Singapore). The core business of CCM is the provision of recruitment services placing candidates on a permanent or contract basis to healthcare institutions across the globe.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Policy
This Policy aims to give you information on how CCM collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter OR our services.
It is important that you read this Policy together with any other notices or forms we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices or forms and is not intended to override them.
CCM is the controller and responsible for your personal data (collectively referred to as “CCM”, “we”, “us” or “our” in this Policy). We will let you know which entity will be the controller for your data when you engage the services with with us. CCM International Ltd is the main controller and responsible for this website.
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
If you have any questions about this Policy or our privacy practices, please contact our Data Protection Coordinator in the following ways:
Postal address: 63 Gardiner Street Lower, Dublin 1, D01P6K0, Ireland.
Telephone: +353 1 836 6092
You have the right to make a complaint at any time to the Ireland Data Protection Commission (“IDPC”) (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
Changes to the Policy and your duty to inform us of changes
We keep our Policy under regular review. This version was last updated on 14 July 2021. Historic version can be obtained by contacting us. 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.
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, gender and other information as contained in your resume submitted to us.
Contact Data includes address, postal address (if different), email address and telephone numbers.
Financial Data includes bank account and payment card details.
Technical Data includes internet protocol (IP) address, 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.
Response Data includes your 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.
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
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 recruitment/placement services). In this case, we may have to cancel the service or contract you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you (i) apply for our services; (ii) subscribe to our services or newsletters; (iii) complete a survey or (v) give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from analytics providers such as Google based outside EU region;
Contact, and Financial Data from providers of technical, payment and delivery services;
Identity and Historical Data from pre-employment screening and background checking organisations; and
Identity Data from your past educators and employers, referees, relevant education authorities LinkedIn and social media sites.
HOW ARE 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 we need to perform the contract we are about to enter into or have entered into with you and/or to provide recruitment services to you.
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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
· provide you with work finding services;
· communicate with you;
· enable you to upload your CV and apply for jobs;
· personalise your experience by creating a candidate profile;
· provide you with interviewing and salary advice; and
· send you direct marketing for the purposes of informing you about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices. We also run targeted and relevant banner advertising on our website and within your social networks to present you and people like you with jobs and content that we believe will be of interest.
· to provide recruitment services to you;
· to communicate with you;
· to get feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services;
· to maintain our business relationship with you;
· to answer your enquiries when you contact us;
· to fulfil contractual obligations to you;
· to establish, exercise or defend legal claims; and
· for direct marketing purposes.
Note that 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 grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will get your expressed opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties 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.
Please be aware that in some circumstances we may need to retain some information to ensure all of your preferences are properly respected. For example, we cannot erase all information about you where you have also asked us not to send you marketing material. Otherwise, we would delete your preference not to receive marketing material.
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 get 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.
DISCLOSURES OF YOUR PERSONAL DATA
We will also share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
Internal Third Parties as set out in Section 10 – Glossary.
External Third Parties as set out in the Section 10 – Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
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 your personal data for specified purposes and in accordance with our instructions.
We share your personal data with healthcare institutions based outside of the EEA. This will involve transferring your data outside the EEA. Some of the healthcare institutions and the external third parties providing services to CCM are based outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a certain degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will ensure the agreement with the healthcare institution contained the necessary confidentiality and data privacy protection regulations clauses (as data protection laws outside the EEA may not provide an equivalent level of protection to EEA data protection laws)
Where we use certain service providers, we may use specific contracts approved for use in the EEA which give personal data the same protection it has in the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 on a need to know basis. 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS section below for further information.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee 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.
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 aim 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.
Internal Third Parties – Other companies in the CCM Group [acting as joint controllers or processors] and who are based in Australia and provide IT and system administration services and undertake leadership reporting.
External Third Parties
Service providers [acting as processors] based outside of EU region (United States) and in EU region who provide IT and system administration services.
Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based outside of EU region who provide consultancy, banking, legal, insurance and accounting services.