Killarney Telecom Group – Privacy Policy & Data Protection Notice Effective Date: May 2026
Killarney Telecom Group (KTL) is committed to protecting your personal data and processing it in a fair, transparent, and lawful manner in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, the Data Protection Act 2018, and other applicable laws including the EU Artificial Intelligence Act (Regulation (EU) 2024/1689).
This document explains how we collect, use, store, and protect your personal data if you are:
A job applicant or candidate (Connecting, Applying, Sourced, or Referred Candidate)
A Visitor to our Career Site
A current or former employee, worker, or contractor
1. Data Controller
Killarney Telecommunications Ltd Unit P, M7 Business Park Newhall, Naas Co. Kildare, Ireland
Data Protection Officer: Sinead Larkin, HR Manager Email: Sinead.larkin@ktl.ie Phone: 045 901030
We act as the data controller for all personal data processing activities described in this policy. All personal data is processed within the United Kingdom and Ireland only (data hosting in Ireland).
2. Data Protection Principles
We adhere to the following principles:
Process data fairly, lawfully, and transparently
Collect data only for specified, legitimate purposes
Ensure data is accurate and up to date
Keep data only as long as necessary
Process data securely and confidentially
3. What Personal Data Do We Process?
Visitors to our Career Site
Device and technical information (IP address, browser type, operating system, location data within UK/Ireland, usage statistics)
Job Candidates (Applicants)
Personal details (name, contact information, address, date of birth)
Application data (CV, cover letter, education, work history, references)
Interview notes, assessments, test results, salary expectations
Public professional profile information (e.g. LinkedIn)
Background check data (where applicable)
Communication records with us
Employees, Workers & Contractors
Personal details (name, address, date of birth, gender, contact numbers, photograph)
Next of kin / dependants and emergency contacts
Bank details, tax codes, PPSN / NIN
Employment details (job title, pay, hours, pension, contract terms)
Right to work documentation and driving licence (where relevant)
Performance, disciplinary, and grievance records
Sickness absence, leave records, and medical information
Training records
Criminal conviction data (where relevant to role)
CCTV footage and building access records
Special Category Data (e.g. health, racial/ethnic origin, religious beliefs, trade union membership) is only processed where necessary for employment obligations, equal opportunities monitoring, or with your explicit consent.
4. How We Collect Your Data
Directly from you – during recruitment, onboarding, or throughout employment.
From third parties – recruitment agencies, referees, former employers, background check providers, or public sources.
Automatically – via our Career Site or IT systems (e.g. CCTV, access control).
5. Legal Basis for Processing
We process your personal data on the following lawful bases:
Performance of contract – to fulfil your employment contract or consider you for a role.
Legal obligations – tax, right to work, health & safety, employment law compliance.
Legitimate interests – effective recruitment, running our business, managing performance, site security, and maintaining a talent pool.
Explicit consent – for certain sensitive processing (you may withdraw this at any time).
Vital interests or public interest – where applicable.
6. Purposes of Processing
For Candidates:
Assessing your suitability for current and future roles
Communicating with you about vacancies
Conducting interviews, assessments, and reference checks
Improving our recruitment process
For Employees:
Managing the employment relationship (payroll, benefits, performance, training)
Complying with legal obligations
Site security and access control
Business planning and legal claims
7. Data Retention
Candidates & Visitors We retain your personal data for up to 12 months from your last interaction or the last time we considered you for a role. At the end of the 12-month period, we will email you asking whether you wish us to:
If you do not respond within the specified timeframe (usually 30 days), we will treat this as your implied agreement for us to retain your data for another 12 months on the basis of our legitimate interest in maintaining an active talent pool. You can request deletion at any time.
Employees, Workers & Contractors We retain your data for the duration of your employment plus additional periods required by law (examples: basic personal and payroll data 3–6 years after employment ends, accident records 10 years, etc.). We delete data securely when it is no longer needed.
8. Sharing Your Personal Data
We share data only where necessary:
Internally with relevant departments (HR, Payroll, Line Managers)
With service providers (payroll, recruitment platforms, IT, benefits providers, background check providers)
With third parties for site access (e.g. client sites requiring Garda vetting)
Where legally required (courts, regulators, tax authorities)
In the event of a business sale or merger
All third parties are required to maintain appropriate security and comply with data protection law. We do not share your data outside the UK and Ireland.
9. International Transfers
Killarney Telecom Group does not transfer your personal data outside the United Kingdom and Ireland.
10. Your Rights
You have the following rights:
Right to be informed
Right of access (Subject Access Request)
Right to rectification
Right to erasure (“right to be forgotten”)
Right to restrict processing
Right to object to processing (including legitimate interest processing)
Right to data portability
Right to withdraw consent (where applicable)
Rights relating to automated decision-making and profiling
To exercise any of these rights, please contact Sinead Larkin at Sinead.larkin@ktl.ie or 045 901030. We will respond to your request within one month (or as required by law).
11. Automated Decision Making, AI & the EU AI Act
Killarney Telecom Group takes human oversight and human decision-making very seriously in all stages of our recruitment process. We are committed to ensuring that every candidate receives fair and personalised consideration.
EU AI Act Notice (Regulation (EU) 2024/1689): We use Artificial Intelligence (AI) tools in our recruitment process, which are classified as high-risk AI systems under the EU AI Act (Annex III, point 4) because they support recruitment, candidate screening, filtering, and evaluation. You are therefore subject to the use of a high-risk AI system when applying for roles with us.
We may use AI tools and other automated systems only as a support tool to assist our recruitment team. Specifically, AI may be used to:
Categorise and summarise CVs
Perform initial keyword and criteria-based screening
Help rank or group applications to improve efficiency
Important:
AI is never used to automatically reject candidates or make any final hiring decisions.
Every single application we receive is reviewed by a member of our recruitment team. A human recruiter will always assess your full application, supporting documents, and overall suitability.
All significant decisions — such as whether to progress you to interview, offer you a role, or place you on hold — are made by human recruiters with meaningful human oversight.
This approach ensures fairness, transparency, and that every candidate is given proper human consideration, in line with both the EU AI Act and GDPR requirements.
We use AI purely to help our team manage high volumes of applications more effectively, allowing them to focus their time on properly evaluating each candidate. By being transparent about our use of AI, we aim to help you make an informed decision when applying.
You have the right to request information about any automated processing of your data, including details of the AI systems used, and to object to it. For more details, please see the “Your Rights” section above.
12. Security & Complaints
We implement appropriate technical and organisational measures to protect your data.
If you have any concerns about how we process your data, please contact Sinead Larkin in the first instance. You also have the right to lodge a complaint with the relevant supervisory authority:
