1. Introduction
As part of any recruitment process, Forward Emphasis collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect, use, and store that data, and to meeting our data protection obligations under the General Data Protection Regulation (GDPR).
2. Who is the Data Controller?
Forward Emphasis is the data controller for all personal data you submit as part of your job application. This means we determine how and why your personal data is processed, even when the data is collected via third-party recruitment platforms.
3. What Information Do We Collect?
We may collect the following types of personal data during the recruitment process:
• Name, address, and contact details (email and phone number);
• CV/resume and covering letter;
• Employment history, qualifications, skills, and experience;
• Details of your right to work in the Republic of Ireland;
• Responses to application or screening questions;
• Information obtained during interviews or assessments;
• Disability status, if disclosed, to enable reasonable accommodations;
• Publicly available professional profiles (e.g., LinkedIn), where relevant to the role.
4. Use of The Access Group Recruitment Platform
We use a recruitment technology solution provided by The Access Group, which includes:
• Access Volcanic, a recruitment website platform used to advertise jobs and collect applications;
• Access PeopleXD, an internal recruitment and HR system used to manage applicant data through the recruitment lifecycle.
These systems are pre-integrated modules within a unified platform, meaning that your data submitted through Volcanic is securely transferred and managed in PeopleXD for processing by our recruitment team.
The Access Group acts as a data processor on behalf of Forward Emphasis. Appropriate contractual safeguards are in place to ensure that your data is processed securely and in accordance with GDPR.
5. Where is Your Data Stored?
Your data is stored securely in data centres operated by The Access Group. These data centres are located within the European Economic Area (EEA). If any data is transferred outside the EEA, appropriate safeguards (such as Standard Contractual Clauses) are in place.
6. Website Cookies and Tracking
The Volcanic platform may use cookies and tracking technologies to improve functionality and user experience. Please refer to [Volcanic’s Cookie Policy] for more information.
7. Why Do We Process Your Data?
We process your data to:
• Manage the recruitment process;
• Assess your suitability for a role;
• Contact you regarding your application;
• Comply with legal obligations (e.g., right to work checks);
• Make reasonable adjustments for candidates with disabilities;
• Retain suitable candidates for future roles (with your consent);
• Keep appropriate records of the recruitment process.
Our legal bases for processing include:
• Legitimate interest – to evaluate and recruit suitable candidates;
• Legal obligation – to verify employment eligibility;
• Performance of a contract – to take steps at your request prior to entering into employment.
8. Who has access to your data?
Your information may be accessed by:
• Our HR and recruitment teams;
• Hiring managers involved in the recruitment process;
• Internal IT support (only as necessary for system functionality).
We may also contact referees or confirm qualifications if you are offered a role. We do not share your data with third parties for marketing or unrelated purposes.
9. How Do We Protect Your Data?
We have implemented appropriate technical and organisational measures to secure your data against unauthorised access, alteration, disclosure, or destruction. Access to applicant data is limited to those who need it for legitimate recruitment purposes.
10. How Long Do We Keep Your Data?
• If your application is unsuccessful, we will retain your data for 12 months from the end of the recruitment process.
• If your application is successful, your recruitment data will be retained in line with our employee privacy policy.
11. Your Rights
Under GDPR, you have the right to:
• Access the data we hold about you;
• Request correction of inaccurate or incomplete data;
• Request erasure of your data, under certain circumstances;
• Object to processing based on our legitimate interests;
• Withdraw your consent at any time, where consent is used as the legal basis.
To exercise your rights, contact:
dataprotection@forwardemphasis.ie
If you believe your data rights have been violated, you have the right to lodge a complaint with the Data Protection Commissioner:
12. Is Providing Data Mandatory?
You are not legally required to provide personal data. However, failure to provide essential information may prevent us from progressing your application.