ICE Group Privacy Policy

1. Who We Are

ICE Group is a group of related companies, including ICE Group Business Services, KT Business Skills, Career Paths and ICE Workforce. We provide recruitment, HR, training, payroll, interpreting and related services to a wide range of clients.

2. Data Controller

ICE Group, including ICE Group Business Services, KT Business Skills, Career Paths and ICE Workforce, acts as the data controller for the personal data processed in connection with our recruitment, training, Interpreting and payroll services.

3. Our Commitment to Data Protection and Quality

We are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR), all applicable EU and Irish data protection laws, and the principles of ISO 9001 quality management. This policy explains how we collect, use, share, and protect your personal data.

4. Lawful Basis for Processing and Consent

We process your personal data on one or more of the following lawful bases:

  • To perform our contractual obligations to you or to take steps at your request prior to entering into a contract
  • To comply with legal and regulatory obligations
  • For our legitimate interests in providing and improving our services
  • On the basis of your explicit consent, where required

You may withdraw your consent at any time by contacting us at gdpr@icegroup.ie.

5. Categories of Data Subjects and Data Collected

We collect and process personal data relating to:

  • Recruitment candidates and agency workers (e.g., CVs, contact details, work history, proof of identity, references, test results, health information, IP address, CCTV/web interview footage)
  • Learners, students, and trainees (e.g., contact details, date of birth, PPS number, course/programme, attendance, certification results, financial details, photo, CCTV footage)
  • Clients, employers, and host companies (e.g., contact details, records of communications, agreements)
  • Staff (e.g., employment records, attendance, performance, payroll information)
  • Suppliers (e.g., contact and financial details)
  • Referees and emergency contacts (e.g., contact details provided by other data subjects)
  • Other individuals whose data is provided to us in the course of our services

6. Use of Third-Party Applications and Digital Tools

To deliver our recruitment, training, and payroll services, we use a variety of third-party applications and platforms, such as Indeed, LinkedIn, JobAdder, and others. As our business evolves, we may add new digital tools to support our operations. The types of personal data shared with these third parties may include candidate information, training records, and payroll details, depending on the service provided.

Each third-party provider is contractually required to comply with GDPR and relevant data protection laws. The lawful basis for sharing your data with these providers may include legitimate interest, contractual necessity, or your explicit consent, as appropriate. For details on how these third parties process your data, please refer to their respective privacy policies.

7. Marketing Communications

We may use your email address or phone number to send you information about upcoming events, services, special offers, or other updates relevant to the services we provide. You will always have the opportunity to opt out of receiving these marketing communications at any time, either by using the unsubscribe link in our emails or by contacting us directly.

Our email marketing is managed through a reputable provider that offers secure data processing and straightforward opt-out options. If we change our email marketing provider, we will ensure that any new provider maintains the same standards of data protection and opt-out functionality.

Your personal data will only be used for marketing purposes in accordance with applicable data protection laws and the services we provide to you. We do not share, sell, or rent your information to third parties for marketing purposes.

8. Recording and Transcription of Meetings and Interviews

We may record or transcribe meetings and interviews for documentation, quality assurance, and compliance purposes. These activities are conducted exclusively using our enterprise systems (such as Microsoft Teams), which are configured to meet GDPR requirements for security, access control, and data protection.

Recording or transcription by participants or third-party tools (including AI assistants) is not permitted without prior written consent from the meeting organiser. This policy ensures that all personal data is processed securely and in accordance with EU data protection laws. If you have any concerns or wish to request access to or deletion of a recording or transcript, please contact us using the details provided below.

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal, regulatory, or contractual obligations. Retention periods may vary depending on the nature of the data and the context in which it was provided. In some cases, such as government contracts, data may be retained for up to 14 years as required by law.

10. Industry-Specific Processing

As a provider of recruitment, training, and payroll services, we process personal data such as candidate applications, employment records, training participation, and payroll information. Our data processing activities are tailored to the needs of individuals and organisations seeking employment, training, or payroll support.

11. Sharing Your Information

We will only share your information as appropriate with:

  • Our clients, where it is an agreed part of our service
  • Prospective employers, to assist them in their hiring processes
  • Individuals and organisations who hold information related to your reference or application to work with us (e.g., past employers, educational establishments, awarding bodies, employment agencies)
  • Tax, audit, or other regulatory authorities where legally required
  • Third-party outsourced IT and data management providers, under appropriate processing agreements
  • Outsourced service providers, under stringent data protection contractual requirements
  • Clients overseas (outside the EU) only where you have expressed an interest in working in another country
  • Pitman Training Group (UK) when you are a Pitman Training Student
  • New owners and their advisers in the event of a merger or acquisition (with notice to you)
  • To comply with any legal obligation or to enforce/apply our Terms of Business

12. International Data Transfers

If we transfer your personal data outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses or other lawful transfer mechanisms, to protect your data in accordance with GDPR requirements.

13. Automated Decision-Making and Profiling

We do not currently use automated decision-making or profiling that produces legal or similarly significant effects for individuals. While we may use automation to support certain processes (such as initial CV screening), all hiring decisions and other significant actions will always involve human review.

Should our practices change in the future, we will update this policy and provide you with meaningful information about the logic involved and the potential consequences.

14. Statutory or Contractual Requirements

In some cases, the provision of personal data is a statutory or contractual requirement (for example, to comply with employment law or to enter into a contract for services). If you do not provide the required information, we may be unable to provide our services or fulfil our legal obligations, which could affect your employment prospects or access to training.

15. Your Rights Under GDPR

As an individual whose data we process, you have the right to:

  • Confirm the information we hold about you
  • Modify, update, or delete your information (to request deletion, email gdpr@icegroup.ie)
  • Object to or restrict certain types of processing
  • Request data portability
  • Withdraw your consent at any time (where processing is based on consent)
  • Lodge a complaint with a supervisory authority (see below)
    To exercise your rights, we may ask you to verify your identity or provide more information about your request. In some circumstances, we may decline your request where legally permitted, and we will explain why.

16. Right to Lodge a Complaint

If you have concerns about how we process your personal data, you have the right to lodge a complaint with the Data Protection Commission (DPC):
Data Protection Commission
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Phone: +353 57 868 4800 / +353 761 104 800
Email: info@dataprotection.ie
Website: https://www.dataprotection.ie/

17. Opt-Out and Communications

If you no longer wish to be registered with us, you can let us know at any time by emailing gdpr@icegroup.ie and we will remove your details.

You may also opt out of job alerts and relevant news by emailing nomorenews@icegroup.ie or clicking the unsubscribe link in our communications.

18. ISO 9100 Accreditation and Quality Management

ICE Group is accredited to ISO 9100 standards. We are committed to continuous improvement and quality management in all aspects of our business, including data protection and privacy.

19. Policy Review and Updates

We review this privacy policy regularly and update it as necessary to reflect changes in our services, legal requirements, or best practices. The latest version will always be available on our website.

20. Contact Us

For any privacy-related queries or to exercise your rights, please contact us at:
Email: gdpr@icegroup.ie

Consent Statement:

By providing us with your information, you indicate your consent for ICE Group to collect and process your personal details as outlined in this privacy policy.