We, Career Craft Consulting (T/A Budding), with offices at the Guinness Enterprise Centre, Dublin 8 explain in this policy how we collect, manage and store your personal data through our website, online platform and mobile devices in accordance with the EU General Data Protection Regulation. We are committed to safeguarding the privacy of Career Craft Consulting (T/A Budding) platform users. Your personal data, for the purposes of this policy, relates to any information relating to an identified or identifiable person.
The information relates only to the Budding platform and website, and does not include information collected by means of other media, such as offline, by telephone or by emails that you send us.
This policy applies where we are acting as a data controller with respect to the personal data of Career Craft Consulting (T/A Budding) platform users; in other words, where we determine the purposes and means of the processing of that personal data.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like your information to be shared with a third party. You can access the privacy controls through the Account Settings menu.
In this policy, "we", "us" and "our" refer to Career Craft Consulting (T/A Budding). References to SHINE refer to the proprietary Budding model which incorporates Strengths, Hard-Skills and Knowledge, Interests, Nature and Essence. This is profile information which you fill in to indicate where you work strengths and preferences lie or the attributes you deem most appropriate for the role. An individual or candidate account refers to an account set up by an individual that would like to manage their career through our services or to make their profiles visible to employers. An employer account refers to an account set up for the purposes of finding suitable candidates to fill a role.
This document was created using a template from SEQ Legal (https://seqlegal.com).
In the next section we set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2. Personal Data We Collect
There is some information which we need in order to effectively run our services. This includes the collection of account data and profile data, without which, we will be unable to provide a service to you. The legal basis for collecting this data will be legitimate interest.
2.1. We may process data about your use of our website and services ("usage data"). The usage data may include geographical location, browser type and version, 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. The source of the usage data is our analytics tracking system, which is currently Google Analytics. The data which is collected will be of aggregate source and you will not be personally identifiable. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is legitimate interest and you will see information on managing your cookies in Section 15.
2.2. We may process your account data ("account data").The account data includes your name, email address and telephone number. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is legitimate interest and consent. You will be asked to consent to make this information visible to employers at such time as you are ready.
2.3. We may process your information included in your personal profile on our website ("profile data"). The profile data includes your name, educational/work status, telephone number, email address, profile pictures, gender, driver license status, work permit status, country/county of residence, job preferences, languages, work experiences, strengths, qualifications, interests, behavioural type, motivators, career preferences and ‘evidence’ details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is legitimate interest and consent. You will be asked to consent to make this information visible to employers at such time as you are ready.
2.4. At some point, it may be possible to connect to our site via a social network site such as Facebook or LinkedIn. In this case we will be notified that you have authorized this site to share information with us and this information could include profile information, birthdays, work experience, email addresses etc. The information that we would collect in these instances would depend on your privacy settings with that site, and so you are advised to consult directly with them should you have any queries.
2.5. We may process your personal data [that are provided in the course of the use of our services] ("service data"). The service data may include your profile, work or SHINE information, your career suggestions, employer matches or challenges responded to. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. You will be asked to consent to make this information visible to employers at such time as you are ready.
2.6. We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent or responding to queries.
2.8. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely your interest in the proper administration of our website and business.
2.9. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.10. We may process information contained in or relating to any communication that you send to us ("correspondence data") and may respond to communications initiated by you. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely, the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. How We Use Your Information
The information which we use is necessary in order to be able to provide our services to you or for the following reasons:
3.1: To register you on our site as a new subscriber. For this, we ask for your Name, Email Address and Gender and Organisation Name (if you are an accessing the site as an employer) and to consent that you are over 16 years of age. We need this information to fulfil our contract with you.
3.2: To collect information regarding your career/ role preferences and profile. We use this information to match you with appropriate careers (if you are accessing the site as a candidate), and to employers (if you are accessing the site as a candidate) / candidates (if you are accessing the site as an employer), should you choose to make your information visible. This data includes identity information, profile preferences and selections, contact details and possibly financial details. We need this information in order to fulfil our contract with you.
3.3. In order to manage our relationship with you which may include requesting that you complete an occasional survey or following up on your journey, or notifying you about changes to our terms of policy. The information we may process could include identity data, contact information, profile information or preferences regarding marking and communications information. We need this information in order to fulfil our contract with you, to ensure our records are up to date or to comply with legal obligations.
3.4. As part of our service we may administer challenges for you to complete, such as parts of your profile to update. Sometimes there may be prize draws associated with this. For this we may need to process your identity data and contact information, profile, account, usage or service data and marketing and communications preferences. We need this information to fulfil our contract with you and for legitimate business interests.
3.5: In order to protect our business and website or platform we may need to process your data for the purposes of troubleshooting, data testing, maintenance, support and reporting. For this we may need your identity and profile, account, usage or service data, contact information and technical details of usage. We may need this information to comply with legal obligations or for legitimate business interests.
3.6: To deliver relevant content or to measure the effectiveness of ads we show you. For this we may need to process your identity and contact information, profile, account, usage or service data, marketing and communications preferences and/or technical information. We need this information for legitimate business interests.
3.7: We may use data analytics to improve the website or enhance the experience of how you interact with us. For this we may need to process your technical or usage and service information for the purposes of legitimate business interests.
3.8: To commercialise data we may collect aggregate information for statistical purposes. This data that will not identify you personally and may include profile, account, usage or service data or technical usage. We need this information for legitimate business interests.
3.9: If you opt-in for marketing, or to read our blog or media content, or if you have requested marketing information from us we may use your identity, contact technical, profile, account, usage or service data
4. 4. Providing your personal data to others
4.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3. We may disclose aggregated data, such as information pertaining to SHINE choices and career matches and/or company/candidate interest, that does not identify you personally.
4.4. We may disclose your personal data to our service providers including web-servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners etc. The agreements that we have with third-party suppliers will be subject to strict privacy / confidentiality policies.
4.5. When you set up an individual / candidate account, insofar as you consent, we may disclose your contact details, profile information, work-experience and evidences to third party employers that constitute a match so that they may contact you about relevant roles. This could be any one of a range of employers on our system, depending upon their suitability to you. Employers will be unable to view any of your details until you authorise the visibility of your profile. Once your profile is complete, you will be prompted to make it visible if you would like. An employer will be unable to personally identify you and you will not be placed in the candidate pool for a given employer until you have actively decided to apply for that role. Even when your profile is visible, employers will be unable to view your personal details (name, gender, photograph, telephone number and email address), until such time as you have been shortlisted. The legal basis for this processing is consent.
4.6. When you set up an employer account, we may disclose your Job role, company information, matching SHINE data and other work-related information which you provide to us, to prospective candidates that meet your eligibility criteria. This could be any range of candidates on our system, depending upon their suitability to you. Candidate’s will be unable to view any of your details until you process the activation of your job.
4.7. Once you engage in a relationship with employers [if you are a candidate] or with candidates [if you are an employer], you will be able to continue an ongoing dialogue through the Budding system. Once a relationship / dialogue / transfer of information is moved to another system, (eg psychometric testing), Career Craft Consulting will no longer have a responsibility for that data, and instead, that information will become the responsibility of that third-party, and subject to their policy. Anything information which you share as a candidate or an employer through that open dialogue messaging system is at your discretion. This data will not be processed by Career Craft Consulting.
4.8. The legal basis for this processing is legitimate interest or the fulfilment of a contract with you or consent and you may change your preference at any time in the ‘Account Settings’ menu. You have the right to withdraw consent at any time by emailing us at firstname.lastname@example.org .
4.9. Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.11. In the case of company / assets sale, your data may be transferred subject to compliance with the law and acceptance of the acquiring company and its affiliates of the privacy terms accepted by you.
4.12. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.1. Transfers of data to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection_en.
5.2. The hosting facilities for our website are situated in using Amazon AWS. Information on data storage can be found here: https://aws.amazon.com/about-aws/global-infrastructure. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection_en
5.3. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.1. Personal data that we process for any purpose or purposes shall kept for as long as you are interested in our services or as long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. By law, we must keep your candidate data for six years after you seek to be a subscriber of our system. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can't identify you.
6.2. Under GDPR legislation, you have the right to be forgotten. If you are an individual user / candidate you can delete your account by going to the ‘Account Settings’ menu and clicking on the ‘Delete Account’ button. If you are an employer, you can submit a request to us in writing, asking that we erase your details. When you close your account with us, you will no longer have access to the details which you submitted to us. We reserve the right to keep any information in a closed account in our archives that we deem necessary to comply with our legal and statutory obligations.
8. Data Storage and Protection
8.1. You may enter the system as a school student, third-level student or experienced hire. If you are a school student or an experienced hire there will be no option to make your details available for the purposes of finding work and your details will not be visible to employers. To access or use the Platform you must be 16 years of age or older and, if under 18 or the age of majority in your jurisdiction, your use of Platform must be under the supervision of a parent or guardian or other responsible adult.
Further information pertaining to AWS compliance can be found here https://aws.amazon.com/compliance/.
8.2. We take your security very seriously and employ a range of measures to safeguard the information we collect about you. However, given the nature of internet services, it is never possible to completely eliminate risks to security. You are responsible for creating a unique password and for keeping your username and password secret. Your password should be revealed to nobody, including Budding staff (we cannot access this information).
9.1. We may update this policy from time to time by publishing a new version on our website.
9.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3. We may notify you of changes to this policy by email or through the private messaging system on our website.
10. Your rights
10.1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at EU 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
10.2. We may withhold personal information that you request to the extent permitted by law.
10.3. You may instruct us at any time not to process your personal information for marketing purposes.
10.4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or/and we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11. Your rights
11.1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
11.2. Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
11.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting the budding candidate page when logged into our website.
11.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
11.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
11.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
11.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
11.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
11.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
11.10. To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
11.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11.13. You may exercise any of your rights in relation to your personal data [by written notice to us] OR [by [methods]][, in addition to the other methods specified in this Section 8].
12. About cookies
12.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13. Cookies that we use
[additional list items]
14. Cookies used by our service providers
14.3. We may publish Google AdSense interest-based advertisements on our website.
The relevant cookies are: crumb, recentredirect, CART, hasCart, SiteUserInfo, SiteuserSecureAuthToken, Commerce-checkout-state, squarespace-popup-overlay, squarespace-announcement-bar.
15. Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
16. Our details
16.1 This website is owned and operated by Career Craft Consulting.
16.2 We are registered in the Republic of Ireland under registration number 582467, and our registered office is at the Guinness Enterprise Centre, Taylors Lane, Dublin 8.
16.3 Our principal place of business is at Guinness Enterprise Centre, Taylors Lane, Dublin 8.
16.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form; http://www.budding.ie/contact/
(d) by email, using email@example.com