Security/Privacy Policy

Executive Edge Limited
2017 Orchard Avenue
Citywest Business Campus
Dublin D24 AXR0

 

1. Introduction

Executive Edge Limited (“Executive Edge”, “we”, “our” or “us”) is strongly committed to protecting the privacy and security of your personal data.

This Privacy Policy applies to your use of our website www.executiveedge.ie and sets out how we collect, use, store and protect personal data. If you do not agree with the data practices described in this Privacy Policy, please do not use the site. If you wish to withdraw your consent to the data practices described in this Privacy Policy and/or to the use of cookies on the site, please email info@executiveedge.ie.

This Notice has been developed to ensure our users feel confident about the privacy and security of personal data and to meet our obligations under the General Data Protection Regulation (EU) 2018, the ePrivacy Regulations 2011 and the EU Artificial Intelligence Act (EU) 2024.

We must comply with the data protection principles set down in Data Protection Law, and this Policy applies to all personal data collected, processed and stored by us through your use of the site.

Executive Edge is the data controller in respect of the personal data described in this policy.

 

2. How and What Personal Data We Collect

2.1 Personal Data Provided by Individuals

We may collect and store any of the following categories of personal data:

  • Identity and contact information: name, address, email address, telephone number
  • Professional information: CV/curriculum vitae, employment history, qualifications, education, skills and professional certifications
  • Links to professional profiles, including LinkedIn
  • References and referee contact details
  • Job preferences, salary expectations and career objectives
  • Financial information where required for employment placement (e.g. bank details, PPS number)
  • Any other information you choose to provide to us in the course of engaging with us, including uploading your CV and applying for jobs

2.2 Data Provided by Third-Party Sources

We may collect and store personal data from the following sources:

  • Publicly available professional profiles: we may source personal data from publicly available professional networking platforms, including LinkedIn, where this is relevant to our professional recruitment services
  • Referees: we may obtain references from individuals you have nominated, with your prior consent
  • Clients: our clients may provide us with your contact details in relation to recruitment

 

3. Legal Basis for Processing

We rely on the following legal basis under the General Data Protection Regulation in processing your personal data:

  • Consent (Article 6(1)(a)): where an individual has consented to their personal data being processed for specified purposes. You may withdraw your consent at any time.
  • Performance of a Contract (Article 6(1)(b)): where personal data is processed to the extent required to deliver the service requested.
  • Legitimate Interests (Article 6(1)(f)): where personal data is processed for the purpose of legitimate interests, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include the effective provision of recruitment services and human resources solutions, and ensuring the security of our systems and data.
  • Legal Obligation (Article 6(1)(c)): where personal data is processed in compliance with legal obligations. We may need to disclose your identity and other personal data to comply with a request from law enforcement, An Garda Síochána/PSNI, police or other government agencies or court order.

 

4. How We May Use Your Personal Data

We use your personal data to:

  • Deliver recruitment and human resources solutions services
  • Connect individuals with appropriate job opportunities
  • Share your profile with prospective employers
  • Keep you informed about roles and application updates
  • Manage and maintain our working relationship with you
  • Meet legal and regulatory requirements
  • Enhance our services and internal operations

It is notable that we may disclose your information to third parties only when you have authorised us to do so, it is a necessary part of the services we provide, or when there is a legal or statutory obligation to do so. Whenever we disclose information to third parties, we will only disclose the amount of personal information necessary to meet such business needs or legal requirements. Third parties that receive your information from us must satisfy us as to the measures taken to protect the personal data such parties receive, in accordance with the General Data Protection Regulation (2018) and as stated in this Privacy Policy. Appropriate measures will be taken to ensure that all such disclosures or transfers of your information to third parties are completed in a secure manner and pursuant to contractual safeguards.

 

5. Use of Artificial Intelligence and Automated Processing

Executive Edge uses artificial intelligence (AI) tools as part of our recruitment operations to assist with activities such as candidate matching, CV analysis, communications drafting and administrative processes.

In order to be transparent about our use of AI, the criteria below explain the scope of our use of such tools:

  • AI is an assistive tool: AI tools are used to support and enhance our consultants’ work. Our recruitment consultants retain oversight and final decision-making authority over all candidate-related decisions. AI outputs are reviewed by a human before any action is taken.
  • No solely automated decision-making: we do not use AI or automated processing to make decisions that produce legal effects or similarly significantly affect you without meaningful human involvement.
  • AI Act compliance: we are committed to complying with the EU AI Act, including the transparency obligations applicable to AI systems used in recruitment and employment contexts.
  • Data protection: where AI tools process personal data, this is done in accordance with the GDPR.

If you have any questions about our use of AI or wish to request further information about any automated processing that has been applied to your data, please contact our Data Protection Officer, Ciara Friel, by email at ciara@executiveedge.ie.

 

6. Sharing Your Personal Data

We may share your personal data with the following categories of recipients:

  • Clients and prospective employers: with your consent, we will share your CV and relevant personal data with clients for the purpose of specific recruitment assignments.
  • Service providers: we engage third-party service providers who process personal data on our behalf, including our CRM and applicant tracking system provider (TrackerRMS), IT support providers and cloud hosting providers. All such providers are bound by data processing agreements and are required to implement appropriate technical and organisational safeguards.
  • Professional advisers: we may share data with our legal, accounting and insurance advisers where necessary.
  • Regulatory bodies: we may disclose personal data where required by law, regulation or order of a court or regulatory authority, including the Data Protection Commission.

We will not sell your personal data to any third party, nor share it with any third party for their own marketing purposes.

 

7. International Data Transfers

In the course of providing our recruitment services, your personal data may be transferred outside the European Economic Area (“EEA”). This may occur in the following circumstances:

  • Where decision-makers within our client organisations are based outside the EEA and your data is shared with them in the context of a recruitment assignment
  • Where our third-party service providers (such as cloud hosting or CRM providers) process data on servers located outside the EEA
  • Where you have applied for a role that involves an employer or work location outside the EEA

Where personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place in accordance with the GDPR. These safeguards may include:

  • Adequacy decisions: transfers to countries that the European Commission has determined provide an adequate level of data protection
  • Standard Contractual Clauses (SCCs): we use the EU Commission-approved Standard Contractual Clauses as the primary transfer mechanism where no adequacy decision is in place
  • Your explicit consent: in limited circumstances, and where no other safeguard is available, we may seek your explicit consent to a specific transfer

You may request further information about the safeguards we have in place for international data transfers by contacting our Data Protection Officer, Ciara Friel, by email at ciara@executiveedge.ie.

 

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was originally collected and processed, and to comply with any applicable legal or regulatory obligations. In general, we retain personal data for a period of seven years.

Given that we operate within the field of HR, career management can be a long-term process, and individuals may return to the job market at different stages. We retain candidate data to support this ongoing relationship. In general, personal data is retained for up to seven years from your most recent interaction with our services, or from the date you provided consent, whichever is later. This retention period is regularly reviewed to ensure it remains appropriate.

At the end of the retention period, your data will be securely deleted or anonymised in accordance with our Data Destruction Policy. You may request deletion of your data at any time by contacting Ciara Friel by email at ciara@executiveedge.ie.

 

9. Your Rights

Under the GDPR, you have the following rights in relation to your personal data:

  • Right of access: you have the right to request a copy of the personal data we hold about you.
  • Right to rectification: you have the right to request that we correct any inaccurate or incomplete personal data.
  • Right to erasure: you have the right to request the deletion of your personal data in certain circumstances.
  • Right to restriction of processing: you have the right to request that we restrict the processing of your personal data in certain circumstances.
  • Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller.
  • Right to object: you have the right to object to processing based on legitimate interests or for direct marketing purposes.
  • Right related to automated decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.
  • Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Please submit all data requests to Ciara Friel by email at ciara@executiveedge.ie, providing as much detail as possible about your requirements so that we can process your request efficiently. We may ask you to supply identification before fulfilling your request, in order to verify your identity.

Once a valid request has been received, we will respond within one calendar month. In certain circumstances, this period may be extended by up to a further two months. If additional time is required, we will inform you within 30 days of receiving your request, explaining the reason for the delay. There is no charge for exercising your rights. However, where requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse the request, in accordance with the GDPR.

 

10. Right to Lodge a Complaint

If you are dissatisfied with how we have handled your personal data, you have the right to lodge a complaint with the Data Protection Commission:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28

Telephone: +353 (0)1 765 0100 / 1800 437 737
Email: info@dataprotection.ie
Website: www.dataprotection.ie

We would appreciate the opportunity to address your concerns before you approach the Data Protection Commission, so we kindly ask that you reach out to us first via email at ciara@executiveedge.ie.

 

11. Cookies and Website Analytics

Our website uses cookies to distinguish you from other users, to improve your browsing experience and to analyse how our website is used. When you first visit our website, you will be presented with a cookie consent banner. We will only place non-essential cookies on your device with your consent, in accordance with the ePrivacy Regulations 2011.

 

12. Review

This Notice will be reviewed and updated from time to time to consider changes in our legal requirements, practices or regulatory guidance. Any substantial changes will be posted to our website www.executiveedge.ie.

If any significant changes arise, we will take reasonable steps to inform you. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use and store personal data.