Privacy Statement

Version 1.02 (Reviewed September 2024)

1. Who we are

English Education Ireland’s Privacy Statement refers to our commitment to our compliance to data protection legislation including the Irish Data Protection Acts and the EU General Data Protection Regulation.

Throughout this document “we”, “us”, “our”, and “ours” refers to English Education Ireland.

2. How to contact us

There are many ways you can contact us, including by phone, email, and post. More details can be seen on www.englisheducationireland.ie

3. What happens if we make changes to this notice

Where changes to this Privacy Statement occur, the updated version will be published on our website and where appropriate/possible communicated directly to individuals through a communication channel such as email and/or our social media.

Current version Reference – V1.02 September 2024

4. Who do we collect data about

We collect and process your personal data only when such data is necessary in the course of providing our services to you. This personal data includes any offline physical data or online data that makes a person identifiable.

We process data for the following groups of individuals where it is necessary:

• Garda Vetting Applicants
• Event and Training Participants
• Educational Partners
• Potential candidates for employment
• Contractors and Suppliers
• Next of Kin

We are the controller for the personal information we process, unless otherwise stated.

5. What types of your data do we collect

You directly provide us with most of the data we collect. We collect data and process data when you:

• Apply for Garda Vetting through our organisation
• Provide a service to our organisation
• Register for an Event and/or Training Session hosted by our organisation
• Voluntarily complete a survey or provide feedback
• Use or view our website via your browser’s cookies

As part of our services to you, we may need to obtain and process personal data as required where necessary to provide our services such as:

A. Garda Vetting Applicants

Your name, date of birth, email, phone number, job title, addresses (current and previous), criminal record if appropriate to disclose. Applicants may be required to supply additional documents to confirm personal identity – e.g. Passport, Driving licence, Utility Bill

B. Event and Training Participants

Your name and business contact details, work email, signature, phone number, job role.

C. Educational Partners

Your name and business contact details (work- address, email, phone), Signatures, Health and Safely reporting if required.

D. Potential candidates for employment

Your name and contact details (i.e. address, home and mobile phone numbers, email address), CV, and covering letter, Interview assessment details, Any information you provide to us by email, telephone or during an interview, Details of your referees.

E. Contractors and Suppliers

Your name (and your employees names when required) and business contact details (work- address, email, phone (and your employees names when required), Brief statement of duties, Job classification, Start date and contracted price, Registered Directors details as publicly available on the Company’s registration Office, Signatures, Details of your referees, CCTV if on site, Health and Safely reporting if required, Due Diligence compete of supplier pre commencement of services.

F. Next of Kin

Name, Relationship, Telephone

6. When do we receive your data from a third party

Where is it necessary for the service provided, we may receive your data indirectly from the following sources:

• An affiliate organisation that submits Garda Vetting Applications on your behalf through English Education Ireland.
• Appointed Referees provided by you

7. What are the legal bases we process your data

We collect your data based on the following legal basis:

Consent

Where you have explicitly agreed to us processing your information for a specific reason such as:

• Garda Vetting
• Marketing (see section 14)
• Any individual
• Photograph or videos for publication at events
• Cookie (see cookie policy)
• Parental Consent

If you’re under 18 years old, your parent or guardian needs to provide consent for us to use your information.

Right to withdraw consent at any time

Where consent is relied upon as a basis for processing of any personal data, you will be presented with an option to agree or disagree with the collection, use or disclosure of personal data. Once consent is obtained, it can be withdrawn at any stage.

Contract

Processing is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Compliance

The processing is necessary for compliance with a legal obligation we have such as keeping records for revenue or tax purposes or providing information to a public body or law enforcement agency; we may be required to process certain data to carry out our obligations under social security or social protection law. We may also disclose your information if required to do so by law.

Where it is necessary and proportionate, we may allow authorised people to see our records (which may include information about you) for reporting, compliance and auditing purposes.

Legitimate interest

Processing is necessary for the purposes of a legitimate interest pursued by us to safeguard the safety and security of our employees, property, IT systems and devices, buildings, information located or stored on the premises, and assets, and those of service providers, consultants, and advisors that assist us in carrying out its functions. The processing is necessary for the establishment, exercise or defence of legal claims. The processing of Garda vetting Applications on behalf of third-parties is essential to the safeguarding of minors and vulnerable persons studying or working in the English Language Education sector in Ireland.

We may also disclose your information for the prevention and detection of crime and to protect the interests of us or others. To inform recruitment decisions taken about appointments and new hires. To operate our business generally and manage and administer our services to language schools, educational partners, suppliers and potential candidates and provide surveys (see Section 15).

8. What happens if you do not provide us with the data if legal basis is consent or contract

Where lawful basis is a statutory or contractual requirement, if you are obliged to provide the personal data, failure to provide this information may result in us being unable to provide our services to you or obtain your services.

9. What is the purpose (s) for processing your data

We process your data to provide this service.

You agree that any data you provide to us will be true, complete, and accurate in all respects and you agree to notify us immediately of any changes to it. We will only collect personal information from or about you which is necessary for the following purposes:

• To provide this website to you and respond to your queries
• To comply with all relevant law
• To manage your safety and security while you are on our premises
• To facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders
• To investigate, exercise or defend legal claims or other claims of a similar nature.

10. What you need to do when you provide us with other individuals information data

If you are providing personal information on behalf of a third party, you must ensure that the third party receives a copy of this Privacy Statement before their personal information is shared with us.

You do not need to provide this Privacy Statement in the following situations:

• the individual already has the information
• obtaining or disclosure such information is expressly laid down in the law to which English Education Ireland must comply and which provides appropriate measures to protect the individual’s legitimate interests
• where the personal data must remain confidential subject to an obligation of professional secrecy regulated by law.

11. How we protect your data

We collect this data in a transparent way and only with the full knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

• Accurate and kept up to date
• Collected fairly and for lawful purposes only
• Processed by us based on either a valid contract, consent, legal compliance or legitimate interest
• Protected against any unauthorised access or illegal processing by internal or external parties.

Our data will not be:

• Communicated to any unauthorised internal or external parties
• Stored for longer than required for the purpose obtained
• Transferred to organisations, states, or countries outside the European Economic Area without adequate safeguards being put in place as required under Data Protection Law.

Our commitment to protect your data:

• Restrict and monitor access to sensitive data
• Develop transparent data collection procedures
• Train employees in data protection and security measures
• Build secure networks to protect online data from cyberattacks
• Establish clear procedures for reporting privacy breaches or data misuse
• Establish data protection practices (e.g., document shredding, secure locks, data encryption, frequent backups, access authorisation etc.).

12. How our third-party providers protect your data

We only engage with third-party service providers who provide sufficient guarantees to protect your data following our instructions and are bound by a data processing agreement.

13. How we use your information as a member for Marketing

As part of improving our service to you, from time to time, we would like to inform you of services, and/or promotional offers available from us. We may wish to use different means when sending such marketing communications.

We can reach out to you with this information in all sorts of ways:

• by e-mail
• post
• telephone

We may share your data with third parties’ software and marketing providers so that they may send you messaging on our behalf.

Opt in

Where you have consented to marketing by opting in to marketing, we will send you marketing.

You have a right to notify us free of charge at any time that you wish to refuse such marketing by writing to us at our address at the top of this document or by using the “opt-out” options in any marketing message we send you.

14. How we use your information for Surveys

We would like the opportunity to understand your experiences with us and to monitor the performance and effectiveness of our delivery of services to you. We would like to assess the quality of our member services and offerings to external partners. From time to time, we may conduct satisfaction surveys. Where we do so, we rely on the lawful processing of legitimate interest to enhance our service delivery. A withdrawal option will be provided in all survey communication thereafter.

15. Who we share your information with

Your personal information may also be processed by other organisations on our behalf for the purposes outlined above. We may disclose your information where necessary to the following:

Garda National Vetting Bureau, Revenue, Social Welfare, Government Departments, Data Protection Commission, Enterprise Ireland, Tourism Ireland, Failte Ireland, legal advisors, business advisors, financial and leasing institutions, law enforcement, debt collectors, IT providers, couriers, shredding company, security company, CCTV company, administration services, accountant/auditors, insurers, recruitment agents, marketing consultants or subcontractors and to possible successors to our business.

16. How long will we hold your information

We will only retain personal data for as long as necessary for the purposes for which it was collected as required by law or regulatory guidance to which we are subject or to defend any legal actions.

17. Unsolicited and Solicited CV’s

Using email to communicate

Any information you send to English Education Ireland via email is sent via an unsecured email link. Due to the nature of the Internet, there is a possibility that unsecured (unencrypted) email could be intercepted and read by third parties. English Education Ireland assumes no responsibility for interception of confidential information (including in a CV) that you send in an unsecured (unencrypted) email message.

Right to Hire

Any employment agency, person or entity that submits an unsolicited Curriculum Vitae (CV) to English Education Ireland does so with the understanding that English Education Ireland will have the right to hire that applicant at its discretion without any fee owed to the submitting employment agency, person or entity.

Application for an unsolicited job

If you are interested in applying for an unsolicited job within English Education Ireland you may provide us with your CV. We will then match your qualifications and experience to the position you applied for, or any other current job opportunity. If your profile corresponds to our requirements, we will contact you.

Application for a solicited job

If you are interested in applying for a solicited job within English Education Ireland you may provide us with your CV. We will then match your qualifications and experience to the position you applied for, or any other current job opportunity. If your profile corresponds to our requirements, we will contact you.

Verification

Verification checks are required for specific roles and will be identified in the job advertisement where relevant. Verification checks such as:

• Reference checks
• Proof of Identity
• Proof of Residency
• Proof of the Right to Work
• Garda Vetting (only in limited circumstances)
• Background checks (state clearly what will be conducted e.g.)
• Verifying qualifications with educational establishments
• Checking medical history for working capacity of the employee for the relevant job
• Checking professional social media profiles
• Deletion and rectification of your personal data

Personal data processed because of unsolicited job applications, where the job applicant is not offered a job, will be deleted after the rejection of application has been sent to the job applicant, unless the job applicant accepts the storage for a longer period.

Sensitive personal data

English Education Ireland endeavours not to collect “sensitive personal data” via CV’s. By “sensitive personal data” is meant personal data relating to race or ethnic origin, political opinions, religious or philosophical beliefs, membership of trade unions, or health or sex life. If you make unsolicited sensitive personal data available to us (for example, by including this on a C.V.), you are required to provide explicit consent for English Education Ireland to process this data.

Please do not provide your date of birth, your age or your PPS number on your CV.

18. Processing your information outside the EEA

Some third parties we share your data with may reside outside the European Economic Area (which currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein). If we do this, your information will be treated to the same standards adopted in Ireland and include the following data protection transfer mechanisms:

• Model Clauses (also known as Standard Contractual Clauses) are standard clauses in our contracts with our service providers to ensure that any personal data leaving the EEA will be transferred in compliance with EU data-protection law. Copies of our current Model Clauses are available on request.
• Transfers to countries outside the EEA which have an adequate level of protection as approved by the European Commission (such as the United Kingdom).
• Transfers permitted in specific situations where a derogation applies as set out in Article 49 of the GDPR. For example, where it is necessary to transfer information to a non-EEA country to perform our contract with you.

How to exercise your information rights?

• You have the right of access to your personal data
• You have the right to rectification to any errors of your personal data
• You have the right to erasure of your personal data
• You have the right to restriction of processing
• You have the right to data portability
• You have the right to know if any automated decision’s are made about you
• You have the right to object
• You have the right to compliant to the Data Protection Commission