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Processing of (personal) data by the entity in charge of the online application process

Football Association of Ireland
Applicant and Recruitment Privacy Notice


Version 1.0 | September 2026 | Review date: September 2027

 

1. About this notice

The Football Association of Ireland ("FAI", "we", "us" or "our") respects your privacy and is committed to protecting your personal data.
This Applicant and Recruitment Privacy Notice explains how we collect, use, share, retain and protect personal data about individuals who apply for employment or other roles with the FAI.
It applies to:
  • applicants for permanent, fixed-term, temporary and casual employment;
  • applicants for internships and work placements;
  • candidates introduced by recruitment agencies or search firms;
  • individuals who submit speculative applications or expressions of interest;
  • individuals being considered for a role through an executive-search or similar process; and
  • where relevant, referees and other individuals whose personal data is provided as part of a recruitment process.
This notice should be read together with any other privacy information provided to you during a particular recruitment process.
Providing this notice does not form part of any contract of employment or other contract.

2. Who is responsible for your personal data?

The Football Association of Ireland is the data controller responsible for the personal data described in this notice.
Football Association of Ireland, National Sports Campus, Abbotstown, Dublin D15 X8PD
 
The FAI has appointed a Data Protection Officer (DPO). You can contact the DPO atcdatamanager@fai.ie


3. Personal data we may collect

The personal data we collect will depend on the role for which you are being considered and the stage reached in the recruitment process. It may include:
  • your name, address, telephone number and email address;
  • your CV, cover letter and application form;
  • employment history and previous roles;
  • education, professional qualifications, training and professional memberships;
  • skills, experience and other information relevant to the role;
  • salary information, salary expectations and notice period;
  • information about your availability to commence employment;
  • interview notes and interview-panel assessments;
  • scoring, shortlisting and selection records;
  • results of recruitment assessments, presentations, tests or exercises;
  • correspondence between you and the FAI concerning your application;
  • references and information supplied by referees;
  • information provided by a recruitment agency or executive-search provider;
  • information necessary to establish your identity and entitlement to work in Ireland;
  • information concerning potential conflicts of interest;
  • information required to comply with safeguarding requirements;
  • Garda vetting information where vetting is legally or otherwise properly required for the role;
  • information concerning a disability or health condition where this is relevant to a request for reasonable accommodation during the recruitment process;
  • equality, diversity or monitoring information where we have a lawful basis for collecting it; and
  • any other information you choose to provide that is relevant to your application.
We may also create personal data during the recruitment process, including interview notes, panel assessments, scores, recommendations and records of recruitment decisions.
We ask candidates not to provide personal data that is not relevant to the recruitment process.

4. Where we obtain your personal data

We normally obtain personal data directly from you. We may also receive personal data from:
  • recruitment agencies;
  • executive-search firms;
  • referees nominated by you;
  • previous employers, where appropriate and lawful;
  • professional, educational or regulatory bodies;
  • Garda vetting processes where applicable;
  • publicly available professional sources, such as professional registers or business networking platforms, where it is appropriate and proportionate to consult them;
  • FAI employees or officers involved in identifying potential candidates for a role; and
  • service providers involved in the administration of the recruitment process.
Where information is obtained from another source, we will process it only where we have an appropriate lawful basis for doing so.

5. How and why we use your personal data

We process applicant personal data only where there is a lawful basis under applicable data protection law. Our principal recruitment processing activities are set out below.
Processing activityPurposePrincipal lawful basis
Receiving and reviewing applicationsTo assess your suitability for a role and administer your applicationArticle 6(1)(b) GDPR - taking steps at your request before entering into a contract; and, where appropriate, Article 6(1)(f) - legitimate interests
Shortlisting and interviewingTo evaluate your experience, skills, qualifications and suitabilityArticle 6(1)(b) and/or Article 6(1)(f)
Interview notes, scoring and panel assessmentTo operate a consistent, accountable and fair recruitment processArticle 6(1)(b) and Article 6(1)(f)
Recruitment assessments or exercisesTo assess capabilities relevant to the positionArticle 6(1)(b) and Article 6(1)(f)
Communicating with candidatesTo arrange interviews, request information and communicate recruitment decisionsArticle 6(1)(b)
ReferencesTo verify relevant information and assess suitabilityArticle 6(1)(b) and/or Article 6(1)(f)
Verification of qualifications or professional statusTo confirm that candidates meet the requirements of a roleArticle 6(1)(b), Article 6(1)(c) where legally required, and/or Article 6(1)(f)
Right-to-work checksTo comply with immigration and employment-law requirementsArticle 6(1)(c) - compliance with a legal obligation
Safeguarding and Garda vettingTo comply with applicable safeguarding and vetting requirements and assess eligibility for relevant rolesArticle 6(1)(c) and other applicable legal bases
Conflicts-of-interest checksTo identify and appropriately manage actual or potential conflictsArticle 6(1)(f) and, where applicable, Article 6(1)(c)
Reasonable accommodationsTo facilitate participation in recruitment by candidates who require appropriate accommodationsArticle 6(1)(c) and applicable Article 9 conditions
Recruitment complaints or legal claimsTo investigate concerns, demonstrate the integrity of the process and establish, exercise or defend legal claimsArticle 6(1)(f), Article 6(1)(c) where applicable, and Article 9(2)(f) where special-category data is relevant
Record keeping and governanceTo demonstrate fair and accountable recruitment and comply with governance and legal requirementsArticle 6(1)(c) and/or Article 6(1)(f)
Where we rely on legitimate interests, those interests may include:
  • recruiting appropriately qualified individuals;
  • operating fair and effective recruitment processes;
  • maintaining appropriate records of recruitment decisions;
  • protecting the FAI's legal position;
  • ensuring organisational integrity and good governance; and
  • ensuring that appointments are appropriate having regard to the nature of the role.
We will not rely on legitimate interests where your rights and interests override those interests.

6. We do not rely on your application as consent

Submitting an application to the FAI does not constitute consent to the processing of your personal data.
Most recruitment processing is necessary in order to take steps at your request before potentially entering into an employment contract, to comply with legal obligations or for legitimate interests connected with the recruitment process.
Where we do rely on your consent for a particular optional activity, we will make this clear and you may withdraw that consent at any time.
Withdrawal of consent does not affect processing that took place lawfully before consent was withdrawn.

7. Special-category personal data

Certain personal data receives additional protection under the GDPR. This includes information concerning health, disability, racial or ethnic origin, religious or philosophical beliefs, trade-union membership and sexual orientation.
We will process special-category personal data only where it is necessary, proportionate and permitted by law.
For example, we may process limited health or disability information:
  • where you request a reasonable accommodation for an interview, assessment or other part of the recruitment process;
  • where processing is necessary to comply with employment-law obligations; or
  • where necessary in connection with the establishment, exercise or defence of legal claims.
Where Article 9 GDPR applies, we will identify and rely upon an appropriate Article 9 condition in addition to an Article 6 lawful basis.

8. Equality and diversity information

Where the FAI collects equality or diversity information as part of recruitment monitoring, we will explain why that information is being collected and whether providing it is optional.
Where practicable, equality-monitoring information will be kept separate from information used by the recruitment decision-makers and used for statistical, monitoring or reporting purposes rather than for deciding whether to appoint an individual.
Information will be aggregated or anonymised where this is appropriate.

9. Garda vetting, safeguarding and criminal-offence information

Some FAI positions involve work or activities for which Garda vetting is required under the National Vetting Bureau (Children and Vulnerable Persons) Acts 2012 to 2016 or under other applicable safeguarding requirements.
Where this applies, the requirement will normally be identified during the recruitment process.
The FAI does not undertake criminal-record or Garda vetting checks as a routine requirement for every position. Such checks will be undertaken only where they are necessary and legally or appropriately justified having regard to the nature of the position.
Information concerning criminal convictions and offences is subject to Article 10 GDPR and the Data Protection Act 2018. The FAI will process such information only where permitted by law and subject to appropriate safeguards.
Access to Garda vetting information will be limited to individuals who require it for legitimate safeguarding, recruitment or legal purposes.

10. References

Where references are required, we will normally inform you before contacting your referees.
We may use reference information to:
  • verify employment history or professional experience;
  • assess suitability for a role;
  • verify qualifications or professional standing; and
  • identify any material issue relevant to the proposed appointment.
Referees should provide only information that is relevant, accurate and appropriate for the purpose of the reference.

11. Recruitment systems, technology and automated 
decision making

The FAI may use electronic recruitment, HR, document-management or other technology systems to administer recruitment processes.
These systems may assist with activities such as:
  • receiving and organising applications;
  • recording candidate information;
  • scheduling interviews;
  • supporting shortlisting or administration;
  • recording assessment information; and
  • maintaining recruitment records.
The FAI does not make recruitment decisions based solely on automated processing where the decision would produce legal effects or similarly significantly affect a candidate, unless such processing is expressly permitted by law and appropriate information and safeguards are provided.
Where artificial intelligence, automated screening, profiling or candidate-ranking tools are used in a way that materially influences a recruitment process, the FAI will provide candidates with appropriate additional information about that processing where required.
Final appointment decisions remain subject to appropriate human consideration
.

12. Who may receive your personal data?

Your personal data will be shared only where necessary and appropriate.
Within the FAI, it may be accessed by:
  • members of the People & Culture/HR function;
  • the recruiting manager;
  • members of an interview or selection panel;
  • relevant members of senior management;
  • Legal, Governance, Safeguarding or other specialist functions where their involvement is necessary;
  • IT personnel where technical support is required; and
  • other personnel with a legitimate need to participate in the recruitment or approval process.
We may also share information with external organisations including:
  • recruitment agencies and executive-search providers;
  • recruitment or HR technology providers;
  • assessment providers;
  • occupational health providers where relevant;
  • professional or educational bodies;
  • referees;
  • external legal or professional advisers;
  • insurers where appropriate;
  • An Garda Síochána or the National Vetting Bureau where applicable;
  • statutory, regulatory, funding or governmental bodies where disclosure is required or appropriately justified; and
  • other service providers acting on our behalf.
Where a third party processes personal data on our behalf, we require it to provide appropriate data-protection and security safeguards.

13. International transfers

Some of the technology and service providers used by the FAI may process personal data outside Ireland or the European Economic Area.
Where personal data is transferred outside the EEA, the FAI will ensure that an appropriate lawful transfer mechanism is in place where required. This may include:
  • a European Commission adequacy decision;
  • the European Commission Standard Contractual Clauses;
  • another legally recognised transfer mechanism; and
  • supplementary safeguards where appropriate.
You may contact the DPO if you would like further information about the safeguards applicable to a particular transfer.

14. How long we keep recruitment information

The FAI applies retention periods designed to ensure that personal data is not kept for longer than necessary.

Unsuccessful applicants

If your application is unsuccessful, the FAI will ordinarily retain the personal data relating to that recruitment process for 12 months from the date on which the recruitment competition or process concludes.
This period enables the FAI to:
  • respond to queries concerning the recruitment process;
  • investigate any concerns or complaints;
  • demonstrate that the recruitment process was properly conducted; and
  • establish, exercise or defend potential legal claims.
At the end of the retention period, the information will be securely deleted or anonymised unless there is a lawful reason requiring particular information to be retained for longer.

Successful applicants

If you are appointed, information relevant to your employment will be transferred to your employee record and retained in accordance with the FAI's employee privacy notice and applicable retention schedule.
Recruitment information that is not required as part of your employment record will not be retained unnecessarily.

Garda vetting and safeguarding information

Garda vetting, safeguarding or other particularly sensitive information may be subject to separate legal or regulatory retention requirements. Such information will be retained only for so long as is necessary and lawful for the relevant safeguarding, regulatory or legal purpose.

Complaints or legal proceedings

Where a complaint, dispute, investigation or legal proceeding is ongoing or reasonably anticipated, relevant information may be retained beyond the normal 12-month period for so long as reasonably necessary to resolve that matter.

15. Future vacancies and talent pools

The FAI will not automatically retain an unsuccessful application indefinitely for possible future vacancies.
If we wish to retain your details specifically for future employment opportunities beyond the recruitment process for which you applied, we will tell you and, where appropriate, seek your consent.
Where you agree to inclusion in an FAI talent pool, your information will ordinarily be retained for no more than 12 months, unless a different period is clearly communicated to you.
You may ask to be removed from a talent pool at any time by contacting recruitment@fai.ie.

16. Is providing your personal data mandatory?

Certain information is necessary if the FAI is to assess and progress your application.
For example, we generally require sufficient information about your experience, skills and qualifications to determine whether you meet the requirements of the role.
At a later stage, you may also be required to provide information necessary to:
  • verify your identity;
  • demonstrate your entitlement to work;
  • verify qualifications;
  • obtain necessary references;
  • comply with applicable Garda vetting or safeguarding obligations; or
  • satisfy other legal requirements relating to the proposed position.
If you do not provide information that is reasonably required for these purposes, the FAI may be unable to progress your application or make or confirm an appointment.
Where information is optional, we will seek to make that clear.

17. Security of your information

The FAI uses appropriate technical and organisational measures designed to protect personal data against:
  • accidental or unlawful destruction;
  • loss;
  • alteration;
  • unauthorised disclosure; and
  • unauthorised access.
Access to recruitment records is limited according to role and business need.
We also require service providers processing recruitment information on our behalf to implement appropriate contractual, organisational and technical safeguards.

18. Your data-protection rights

Depending on the circumstances and the legal basis on which your information is being processed, you may have the right to:
  • obtain confirmation as to whether we process your personal data;
  • request access to your personal data;
  • request correction of inaccurate or incomplete personal data;
  • request deletion of personal data in certain circumstances;
  • request restriction of processing in certain circumstances;
  • object to processing based on legitimate interests;
  • receive certain personal data in a structured, commonly used and machine-readable format where the right to data portability applies;
  • withdraw consent where processing is based on consent; and
  • exercise rights relating to certain automated decision-making.
These rights are subject to conditions and exemptions under applicable data-protection law and do not apply in every circumstance.
For example, the right to erasure will not require the FAI to delete information that it is legally required to retain or information that is necessary for the establishment, exercise or defence of legal claims.
To exercise your rights, contact:
FAI Data Protection Officer
 Email: datamanager@fai.ie
We may need to verify your identity before acting on a request.

19. Complaints

If you have a concern about how the FAI has used your personal data, we encourage you to contact the FAI Data Protection Officer in the first instance so that the matter can be considered.
You also have the right to make a complaint to the Irish Data Protection Commission.
Further information is available at www.dataprotection.ie.

20. Changes to this notice

The FAI may update this Applicant and Recruitment Privacy Notice from time to time to reflect changes in law, guidance, recruitment practices, technology or the way in which we process candidate information.
The current version will be made available through the FAI website and/or recruitment platform.
Where a change would materially affect an ongoing recruitment process, we will provide additional information to affected candidates where appropriate.

Contact us

Questions about this notice or the FAI's processing of recruitment information should be directed to:
Data Protection Officer
Football Association of Ireland
Email: datamanager@fai.ie
For operational recruitment queries, please contact:
People & Culture / Recruitment
 Email: recruitment@fai.ie

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.