Employee Privacy Policy

EMPLOYEE PRIVACY STATEMENT

1. What does this Employee Privacy Statement cover?

This Privacy Statement explains how The K Club (“we”, “us” or “The K Club”) use Personal Data which we collect about our employees and other staff.

“Personal Data” is information about you or another individual, from which you or they are identifiable. Our aim is responsible handling of Personal Data and this Privacy Statement describes how we use Personal Data that we collect in the course of hiring employees. Personal Data may be provided to us by you directly or by a third party.

2. Personal Data we hold and lawful basis for processing Type of Personal Data

Contact information	Name, address, email and telephone number	Necessary for the performance of your employment contract
General information	Gender, marital and family status, date and place of birth, details of next of kin, employment contract, salary and benefit details	Legitimate interest in administering HR functions Necessary for the performance of your employment contract Necessary to comply with employment or social protection law Necessary to protect the vital interests of the data subject
Education and employment information	Educational background, employer details and employment history, skills and experience and references	Necessary for the performance of your employment contract Legitimate interest in determining the skill and experience of an employee
Government and other official identification numbers	PPS number or work permit number	Necessary for the performance of a contract Necessary for compliance with a legal obligation
Financial information and account details	Bank account number, or other financial account number and account details for processing of wages	Necessary for the performance of your employment contract
Sensitive information	Occupational health forms, sick notes	Necessary for the purpose of assessing the working capacity of the employee Necessary for the defence of a legal claim Necessary to comply with employment or social protection law obligations (Art(9)(b))
CCTV	CCTV images	Legitimate interest

 

3. Sensitive Personal Data

Sensitive or “special” categories of Personal Data include Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning an individual’s sex life or sexual orientation.

We only process data concerning health where required to assess your fitness for work and/or to process benefits (e.g. sick pay) and to ensure your safety while at work. Such data may also be processed in the context of legal proceedings or claims.

4. Sharing of Personal Data

In connection with the purposes described above, we will share your Personal Data with third parties (this may involve third parties disclosing Personal Data to us and us disclosing Personal Data to them).

Where we transfer any of your Personal Data to an entity outside the EEA not deemed to have an adequate level of protection under EU data protection law we will ensure that appropriate measures are in place to protect your Personal Data. These third parties may include: 

 

Types of Third Party	Examples
Our service providers	External third party service providers, such as security professionals, accountants, auditors, experts, lawyers and other professional advisors; IT systems, support and hosting service providers; banks and financial institutions that service our accounts and payroll providers.
Occupational health providers	External medical professionals.
Government authorities, purchasers and other third parties	Government or other public authorities (including, but not limited to, courts, regulatory bodies, law enforcement agencies, tax authorities and criminal investigations agencies).
	Third party participants in legal proceedings and their accountants, auditors, lawyers, and other advisors and representatives. A purchaser or prospective purchaser of a business of The K Club and their lawyers and accountants.

 

5. Monitoring communications

Where we have a reasonable belief that an employee is inappropriately using a work email account or work phone account, we reserve the right to check emails or records of phones calls to protect you, our organisation and IT infrastructure, and third parties.

6. Retention of Personal Data

We will keep Personal Data for as long as is necessary for the purposes for which we collect it. Generally this is seven years from the data of the expiration or termination of your employment. Where we hold Personal Data to comply with a legal or regulatory obligation, we will keep the information for at least as long as is required to comply with that obligation.

For further information about the period of time for which we retain your Personal Data, please contact us using the details below.

7. Personal Data Rights

The following is a summary of the data protection rights available to you in connection with our processing of your Personal Data. These rights may only apply in certain circumstances and are subject to certain legal exemptions under national law.

• Right of access to Personal Data: You have the right to receive a copy of the Personal Data we hold about you and information about how we use it.

• Right to rectification of Personal Data: You have the right to ask us to correct Personal Data we hold about you where it is incorrect or incomplete.

• Right to erasure of Personal Data: This right entitles you to request that your Personal Data be deleted or removed from our systems and records. However, this right only applies in certain circumstances.

• Right to restrict processing of Personal Data: You have the right to request that we suspend our use of your Personal Data.

• Right to data portability: This right allows you to obtain your Personal Data in a format which enables you to transfer that Personal Data to another organisation. You may have the right to have your Personal Data transferred by us directly to the other organisation, if this is technically feasible.

• Right to object to processing of Personal Data: You have the right to object to our use of your Personal Data in certain circumstances. However, we may continue to use your Personal Data, despite your objection, where there are compelling legitimate grounds to do so or we need to use your Personal Data in connection with any legal claims. This right also does not apply where we process your Personal Data where necessary for the performance of your employment contract or where necessary to comply with a legal obligation.

• Right to withdraw consent to processing of Personal Data: Where we have relied upon your consent to process your Personal Data, you have the right to withdraw that consent.

• Right to complain to the relevant data protection authority: If you think that we have processed your Personal Data in a manner that is not in accordance with data protection law, you can make a complaint to the Data Protection Commission.

If you wish to exercise your rights, please contact us using the details below.

8. Who to contact about your Personal Data

If you have any questions or concerns about the way your Personal Data is used by us, you can contact us by e-mail at: niall.ohagan@kclub.ie.

This Privacy Statement was last updated on 7th March 2023.

We review this Privacy Statement regularly and reserve the right to make changes at any time to take account