My Department’s contracts with the JobPath providers are in compliance with all relevant legislation and any information shared is contractually-based and necessary to provide an employment service. All contracts in place are governed by and construed in accordance with the laws of Ireland.
JobPath providers are contractually required to register with the Office of the Data Protection Commissioner as data processors and are legally bound to observe and adhere to data protection requirements.
Both contractors have undertaken regular independent audits of their data processes and procedures as part of these contractual obligations. In addition, the Office of the Data Protection Commissioner has conducted audits of each JobPath contractor. Employees of both contractors, and their subcontractors, are subject to the same data protection laws as Departmental staff.
Abintegro is a software package that is a job-seeking aid which has various tools and features, including a library of video tutorials, a CV builder, a cover letter building tool and advice on completing job applications. It is used by a wide range of universities, media broadcasters and companies (including several based in Ireland) and has been made available by Seetec to jobseekers, who are engaged with the JobPath service as a support for them in obtaining employment.
When a jobseeker registers with Seetec they are given access to a pre-populated Abintegro account. It is then up to the individual jobseeker to activate this account and once activated they will receive access to the range of services including a job alert system. The jobseekers use of the service is at their discretion and they can opt out of using this service at any time.
If a client chooses to create a CV this is then saved to their own personal email address and not on the Abintegro platform. Only the following data which is encrypted, is stored on the Abintegro platform, the client's name, email address, client ID number and separately the encrypted password. There is no unencrypted data stored outside of Ireland.
I am advised that in late 2017 an issue was raised concerning specifically the CV Builder element of the Abintegro software package and where relevant CV data was stored. Seetec were requested to remove the capacity to store CVs on the Abintegro platform and this functionality was replaced with CVs being stored on the jobseeker's personal email. Therefore, there was no impediment for Seetec in continuing to offer this tool to jobseekers on an optional basis.
I am not aware of any investigation being carried out by the Data Protection Commissioner in relation to this matter.
I trust that this clarifies the matter for the Deputy.