SuMi TRUST

Privacy Statement

Website Privacy Notice

Last Update: July 2022

Introduction

This data protection notice provides information about the ways in which Sumitomo Mitsui Trust (Ireland) Limited, SMT Fund Services (Ireland) Limited and SMT Trustees (Ireland) Limited (“SMT”, “we” or “us”) collects and uses personal data which has been collected during your visit to our website.  SMT can receive the personal data directly from individuals or indirectly from another party such as a recruitment agency.

For the purposes of data protection legislation, the Data Controller of your personal data is the relevant SMT entity that your personal data has been provided to as follows:

Sumitomo Mitsui Trust (Ireland) Limited, SMT Fund Services (Ireland) Limited, SMT Trustees (Ireland) Limited

Address:  Block 5, Harcourt Centre

Harcourt Road, Dublin 2

D02 DR52

Ireland

E-mail:   privacy@sumitrustgas.com

Telephone:  00353 1 603 9900

  1. What Personal Data We Hold

Personal Data is typically collected by us when you visit the ‘Services’, ‘Careers’, ‘Client Access’ or ‘Contact Us’ pages on our website.

When you visit the ‘Services’ and ‘Contact Us’ pages we may process:

  • your email address; and
  • any other information that you provide us.

 

When you visit the ‘Client Access’ page we may process:

  • your username; and
  • your password (which is not visible to us).

 

When you send us your CV via the ‘Careers’ page and/or we receive your CV and application from third party recruiters or e-recruiters we may process:

  • Your name, address, telephone number(s) and email address
  • Details of qualifications, skills, experience and employment history
  • Details of current immigration status
  • Salary expectations
  • Job applications made by you
  • Your interests and preferences
  • Any additional information contained in a candidate’s C.V. (such as referee information), disclosed at interview or otherwise provided to SMT during the recruitment process.

 

  1. How we collect Personal Data

When you visit the ‘Services’, ‘Client Access’ or ‘Contact Us’ pages of our website you may give us your personal data by interacting with us. You may also provide us with personal data during the use of our services.

Additionally, we may receive personal data when you send us your C.V. directly by post or email,  via the ‘Careers’ section, from our recruitment partners (including e-recruiters) when you visit third party recruitment platforms.  When you submit a CV for a position in SMT that has been advertised on third party websites you should also pay close attention to the privacy notices of those service providers.  We encourage you to review each third party site’s privacy notice before disclosing any personal information.

  1. How we use Personal Data

SMT use data collected from you by visiting this website for the purposes for which it was collected.  SMT may also use the data to:

  • Administer and operate this website, process any requests you make via the website or respond to any requests made via the ‘Services’, ‘Careers’, ‘Client Access’ or ‘Contact Us’ pages.
  • Engage with recruitment partners.
  • Process your data where the data was collected through the ‘Careers’ section of our website.
  • Decide whether to enter into a contract of employment with a particular candidate and may also process certain data to ensure that it is complying with its legal obligations. SMT has a legitimate interest in processing personal data during the recruitment process and in keeping records of the process in order to manage the recruitment process, to assess and confirm a candidate’s suitability for employment and decide to whom to offer a particular role.
  • Interact with you via email or phone calls.
  • We may also need to process candidates’ data to respond to and defend against legal claims.

Once an offer of employment has been made to (and been accepted by) a candidate, that candidate’s personal data will be provided and SMT may also contact previous employers named by that candidate as referees for the purpose of obtaining employment references.

  1. Lawful Basis for processing

Performance of a contract with you: the processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.  For example, we process your data to assess your knowledge and experience in order to give you an opportunity to work with us.

Legal Obligation: In circumstances where it’s our legal obligation to disclose or share your data in order to comply, pursuant to a legal request, subpoena or other legal processes, or to enforce or apply the company’s terms and conditions (https://www.sumitrustgas.com/terms-and-conditions/) and other agreements, including for billing and collection purposes; or to protect the rights, property, or our safety, or others. This may include exchanging information with other authorities for the purposes of fraud protection.

Legitimate interest: The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data, which overrides those legitimate interests. For example, for our legitimate interest of maintaining a file with your personal data for administration purposes.

Before we process your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law), we make sure we consider and balance any potential impact on you and your rights before we process your personal data.

  1. Disclosure

We will not disclose any Personal Data to any third party, except as follows:

For the purposes of considering candidates who have submitted their CV via the ‘Careers’ section of the website, or who applied to any open position we advertised on third party websites/platforms, we may disclose personal data to:

  • Third parties, where required or permitted by law to do so which may include our recruitment service providers and statutory bodies including the Revenue Commissioners.
  • To other business areas and/or affiliates within the SMT corporate structure (both within the EEA and to third countries outside of the EEA), including to our head office in Japan where we feel that this is necessary or required.
  • Legal advisors or other agencies (where applicable).
  • Relevant public authority (where applicable).
  • Supervisory authorities in other EEA Member States for the purpose of performance of their functions.

SMT requires all third parties to respect the security and confidentiality of personal data disclosed to them. Third-party service providers may only process such personal data for specified purposes and in accordance with our instructions.  We do not allow our third-party service providers to use your personal data for their own purposes unless they are deemed to be controllers in their own right.

  1. How long we keep your information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, and for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and also the applicable legal requirements.

For example, when you send us your CV via the ‘Careers’ page and/or we receive your CV and application from our third party recruiters or e-recruiters we retain candidates’ personal data for 12 months.

  1. Cross-Border Data Transfers

 

The Personal Data and other information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), for example where we are asked to share your CV with our affiliates, including to our head office in Japan, where we feel that this is necessary or required .

To comply with applicable data protection law, we have implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for personal data transferred to countries outside the EEA where an adequate level of protection is not already guaranteed.

  1. What are your rights?

If your personal data is processed by us, you have certain rights in relation to that data, which are outlined in summary form below. SMT may require further information from you before we can respond to your request. The scope of certain rights may be subject to restrictions or exceptions provided for under data protection legislation.

  • The right to access;

You have the right to receive a copy of the personal data we hold about you as well as information about how it is used. We may charge you for this if the request is manifestly unfounded or excessive. We shall respond as soon as reasonably possible and at the latest within 30 days from the date of your request;

  • The right to rectification;

You have the right to ask us to correct personal data we hold about you where it is incorrect or incomplete.

  • The right to erasure;

This right entitles you to request the erasure of your personal data from our systems and records. However, this right applies only in certain circumstances (e.g. where we no longer need the personal data for the purpose for which we collected it or where your consent to process your personal data has been obtained and you withdraw such consent to our use of your personal data and where there is no other legal basis for continuing to use it).  Certain restrictions to this right may be exercised by us for example for the establishment of, exercise of, or defence against, legal claims.  Furthermore, we may need to comply with a legal obligation which requires processing by law to which we are subject.

  • The right to restrict processing;

This right entitles you to restrict the processing of your personal data by us where for example the data we hold is inaccurate, the processing unlawful or where we no longer need to hold that data for the original purpose. Where this right is exercised, we are still permitted to store your personal data but other use of the data is prohibited, save in certain limited circumstances. Where we have legitimate grounds not to restrict the processing of your data we will inform you of our decision before any action is taken.

  • The right to object to processing;

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.

  • The right to data portability;

This right allows you to obtain your personal data in a format that enables you to transfer that personal data to another organisation where the organisation is processing your personal data on the basis of consent or on the fulfilment of a contract and if processing is carried out by automated means.  You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.

  • The right Relating to Automated Decision Making and Profiling

You have the right not to be subject to a decision based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. We are not currently making any automated decisions.

  1. Modifications of this Privacy Notice

We may revise this privacy notice occasionally by publishing a new version on our website. You may choose to check this page on a regular basis to note any changes to this privacy notice.

  1. Data Protection Responsibility

Any queries or complaints regarding our use of your personal data and / or the exercise of individual rights should be addressed to us at privacy@sumitrustgas.com.

  1. Right to Complain to Data Protection Commission

You have the right to lodge a complaint with the Data Protection Commission (DPC) via their website www.dataprotection.ie if you think that we have not processed your personal data in accordance with data protection legislation.