Privacy Policy

VOCATION RELOCATION LIMITED trading as Virtual Career Training Internships is a Company incorporated under Irish law with Company Number 498063 having its registered office at 19 White Street, Cork (the ”Company”). We are fully compliant with the General Data Protection Regulation (“GDPR”) and all applicable legislation made in the Republic of Ireland thereunder. The purpose of this policy is to explain how our organisation uses the personal data we collect from you when you use our website and services. This privacy policy sets out how the Company uses and processes any information which you give to us. We respect your privacy and are committed to protecting your personal information.

Our Data Protection Representative is Kathy O’Dwyer who can be contacted at GDPR@careertraining.ie.

What data do we collect?

Our Company collects the following data:

Interns and prospective Interns

We collect personally identifiable information which third party partners provide to us in respect of certain Interns and potential Interns including:

• Name
• Address
• Email address
• Telephone number
• Professional qualifications
• CV
• Employment history

Third Party Partners and Internship providers

We collect personally identifiable information which Third Party Partners and Intern providers may provide to us including the following:

• Name
• Address
• Telephone Number
• Tax Details (including PPS number, Income Tax Number of VAT number, as appropriate)
• Email address
• Telephone number
• Professional qualifications
• Licences
• Registrations

We may also obtain certain sensitive personal data from our Data Subjects with their consent, and in particular, medical information where appropriate, and where necessary for performance of our obligations and provision of our services. Where such information is provided, the information will be shared only where necessary taking into account the nature of the information provided and the proposed services. Sensitive data will not be retained for any longer than necessary for the performance of the Contract with the Company. We will not disclose sensitive personal data without your consent, reliance of the contractual obligations, specifically authorised or required by law, protection of the vital interest of the Data Subject or of any other natural person or where necessary for the establishment, exercise or defence of legal claims. We will ensure that processing of sensitive personal data is carried out in compliance with the GDPR at all times.

Who are our Data Subjects?

The Company has identified its Data Subjects as:

• Interns and prospective interns
• Third Party partners and Internship providers and their staff, servants or agents.

How do we collect your Data?

The Company collects data from our data subjects and process it in the provision of our services as a career training internship provider.

We will collect data from our interns, prospective interns and third-party partners and internship providers through our website, by email, by post and verbally. We will collect such data in the context of our contract with the third-party partners to enable us to provide internships to their students and prospective students. We will also collect data from our internship providers in certain circumstances to enable us to provide the internship services.

We will collect data to enable us to perform the Contract between us and to comply with our legal and statutory obligations. We will collect personal data via application forms, questionnaires, documents required for completion of the internship together with any personal data obtained from correspondence, telephone calls, emails, details through visits to our website, publicly available information including social media and through use of browser cookies. The Company will primarily collect data by way of direct production of same. On occasion we may also receive your data indirectly via publicly available information including social networking sites.

We will operate as data controller in respect of personal data supplied to us. We may also act as data processor in certain circumstances in the provision of internship services. We will have in place an appropriate data sharing agreement with our third-party partners in either event.

How will we use your Data?

Our Company collects your data so that we can perform the services of a career training internship provider offered by our business.

Interns and prospective interns

Our Company collects your Data so that we can:

• Process your application for an internship
• Source an appropriate internship taking into account your qualifications and skills
• Process your registration for an internship with our third-party internship providers
• To enable you and us to manage your account in the provision of those services
• To contact you with internships and opportunities which may be of interest to you
• To engage with you and respond to any requests which you may have
• To improve our level of service
• For general marketing purposes which are in the legitimate interest of our business
• To process payments in connection with same if applicable
• To meet our legal, contractual and statutory obligations (including, defence of legal claims, if applicable)

Third party partners and Internship providers

We will collect data and use and process that information which you provide to us for the following purposes:

• To enable us to perform our contractual obligations with you
• To correspond with you
• To process payments to you in accordance with our contractual obligations
• To meet our legal and statutory responsibilities including bringing and defending of legal claims, if applicable.
• To process your registration as an Internship provider
• To process your registration as an Educational Institution seeking internships for its students
• To enable us to correspond with you and to manage your account for the provision of these services
• To contact you with opportunities and special offers for our services which may be of interest
• To engage with you or respond to any requests which you may have
• To correspond with you and to conduct administration of the Internship services
• To improve our level of services
• For general marketing purposes which are a legitimate interest of our business

Basis of processing Data

The Company will process data on behalf of natural persons comprising their interns, prospective interns, third party partners and internship providers and will ensure that your data is processed in a lawful, clear and transparent manner at all times for a specific and legitimate purpose. The Company relies on the following legal basis for the processing of data.

• Processing necessary for the performance of a Contract
• Processing necessary for the compliance with a legal or statutory obligation
• To protect the vital interest of a Data Subject
• With the consent of the Data Subject for one or more specific and legitimate purposes.
• Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller
• Processing necessary for the purposes of the legitimate interest pursued by the Controller or a third party except where such interest is overridden by the fundamental rights and freedoms of the Data Subject.

Where we rely on the legitimate interest of the Company for the processing of the personal data, we will take all reasonable measure to ensure that the interests of the Data Subject are protected. The legitimate interests of the Company in this context include direct marketing, prevention of fraud and information system security.

We will rely on our legitimate interests as a company to process your data for direct marketing purposes. We consider it to be a legitimate interest of our company in promoting its services, products and in the administration operation of our business. Any such processing will not be carried out where such interest is overridden by the rights and freedoms of the Data Subject. In all direct marketing communications, we will give an unsubscribe option. A Data Subject can unsubscribe at any time.

We will only rely on consent as the basis for processing in limited circumstances. Where consent is utilised as the basis for processing, such consent can be withdrawn at any time. In that event, we will cease processing your data, unless there is a separate basis upon which we can rely to process your data, such as same being necessary for the performance of the contract between us or necessary for us to comply with our legal and statutory obligations.

How do we store your Data?

The Company securely stores your data at 19 White Street, Cork. We will ensure the appropriate, technical and organisational measures are put in place commensurate with the level of security required for the data held on your behalf. We will use all appropriate and reasonable measure to ensure integrity and confidentiality of the personal as maintained at all times. We have carried out a risk assessment in the processing of personal data and put in place measures to mitigate those risks to include IT security measures, anti-virus software, spire walls, data back-ups, encryption technologies, physical security measures and staff training.

Marketing

Our Company would like to send marketing information to you about the opportunities, internships, interns, products and services which we think will be of relevance to you. We will always give you an option to unsubscribe from our marketing list, please contact Kathy O’Dwyer at GDPR@careertraining.ie if you wish to unsubscribe from our marketing list. You have a right to object to our processing your data for direct marketing purposes at any stage.

Sharing of Personal Data

It may be necessary for us to share your personal data with third parties to enable us to comply with our legal, contractual and statutory obligations. We will need to share the personal data collected from our data subjects with third parties to enable us to perform the contract for provision of such services. The sharing of data shall continue for the duration of the Internship to enable us to carry out administration of any internship provided. We may also need to share the data of our data subjects to conduct the administration and completion of the Internship Services. We will never provide your data to third parties for marketing purposes. We may need to share your financial information for the purposes of payments required in order to comply with our contractual obligations. We may also share your data with our professional advisors where necessary including lawyers, bankers, auditors and insurers who provide professional services necessary for the operation of the business of the company.

We may process data with certain parties outside of Europe where necessary to provide our services. Where we do so, we will ensure that such processing is carried out in accordance with the GDPR and that there are appropriate safeguards in place to protect the data subject.

Data Retention

The Company will keep your data for no longer than necessary for the purpose for which the data was provided taking into account the basis for processing the data. The retention periods are as follows:

Intern Contact Information (name, address, email address, telephone number):

One year after the completion of the training internship (or most recent internship as appropriate) in the case of an intern. In respect of a prospective intern, we will retain data for one year following the initial enquiry.

Third party Partner and Internship provider information including, name, address, email address and telephone number

Two years after first contact with the provider or two years after completion of the most recent training internship, whichever is the longer.

Financial Information (including credit card information):

One month after completion of the internship in respect of interns, prospective interns, third party partners and internship providers or one month after the last payment is made, whichever is the longer.

Personal Injury, accidents, damage, property or other loss sustained by any third party in the course of its relationship with the Company:

Three years following the date of the alleged incident or in the event that the party is a minor, three years after the minor reaches the age of 18 years. In the event that proceedings are issued or any notification of a claim is made, then the Company may retain the data for as long as may be necessary until the proceedings have been concluded.

Data Law Compliance records:

Records in relation to our compliance with Data Law and GDPR will be kept for a five-year period

Revenue Commissioners, Collector General, Companies Acts legislative provisions:

Six years rolling retention of records to enable compliance with legislative provisions.

Breach of Contract related records:

Six years from the date of the alleged breach and in the event that proceedings are issued, the Company may retain the data for so long as may be necessary until the proceedings have been concluded.

Rights of Data Subject

You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

• Right to access data – you have the right to request a copy of the personal data that we hold about you together with other information about our processing of that personal data.
• Right to rectification – you have the right to request that any inaccurate data that is held about you is corrected or if we have incomplete information you may request that we request that we update the information such that it is complete.
• Right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as a right to be forgotten.
• Right to restrict processing or object to processing – you have the right to request that we no longer process your personal data for particular purposes or object to our processing of your personal data for a particular purpose
• Right to data portability - you have the right to request us to provide you or a third party with a copy of your personal data in a structured commonly used readable format.
• Right to object to processing – you have the right to object to processing of data under certain conditions.
If you wish to exercise any of the rights set out above, please contact Kathy O’Dwyer at . We ask that you ensure that all data which you furnish to us is kept accurate and up to date at any stage. We cannot be held responsible for your failure to provide us with up-to-date information.

If we were processing personal data on the basis of your consent, you may withdraw consent at any time. This does not affect the lawfulness of processing which should take place prior to its withdrawal.

You can object to the processing of your personal data for direct marketing purposes at any stage. If you are unhappy with how we process your personal data, we ask that you contact us so that we can rectify the situation. You may lodge a complaint with the Supervisory Authority of the Irish Supervisory Authority of the Data Protection Commission.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through Cookies or similar technology. For further information visit Allaboutcookies.org. Our Company uses Cookies in a range of ways to improve your experience on the website including:

• Keeping you signed in
• Understanding how you use our website

You can set your browser not to accept Cookies. In certain cases, however, if you decline to accept Cookies certain of our website features may not function as a result.

Automated decision-making and profiling

We do not use personal data for the purposes of automated decision-making or profiling.

Changes to this Privacy Notice

Our privacy notice may change from time to time. Any change to the Statement we post on this page. Please check back frequently to see how many updates or changes to our private policy have been implemented. If you do not agree to these changes or any of the terms of this policy, please do not continue to use this website to submit personal information.

Last update: 8 December 2020