1. Data Privacy & Protection Principles
We are committed to processing your data in accordance with principles outlined in Article 5 of GDPR. These principles aver that we must take due care with your data and limit our use to what’s necessary for collection and retention. The full text of article 5 principles can be viewed by clicking on the button below.
- Data we collect must be processed lawfully, fairly and in a transparent manner in relation to individuals;
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
- This policy applies to all personal data [PII] held by us and on our behalf by Data Processors.
- Our Data Protection Officer shall take responsibility for our ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- We are registered with the Data Protection Commission [DPC] as an organisation that processes personal data.
3. Lawful, fair and transparent processing
- To ensure processing of your data is lawful, fair and transparent, we maintain a “Record of Processing Activities” ROPA.
- The ROPA shall be maintained and reviewed at least annually.
- Individuals have the right to access their personal data free of charge in an accessible electronic format.
- Such requests, known as Data Subject Access Requests or DSAR’s made to us shall be provided within 28 days of receipt. (*exceptions may apply)
4. Lawful purposes
- As required by GDPR, all data processed by us is conducted on lawful basis. This basis includes the following four categories; Consent, Contract, Legal Obligation & Legitimate Interests (see DPC guidance for more information).
- This lawful basis is recorded in our record of processing activities.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately on our systems.
5. Data minimisation
- We shall ensure that personal data processing safeguards are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- We shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- We shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this will be done safely such that the data is irrecoverable. (e.g. FIPS standard compliant)
- Strong authentication (MFA) will be used for administrators of personal data on our systems
- Personal data stored and transmitted on our systems will be encrypted using the latest encryption standards.
- Appropriate back-up and disaster recovery solutions shall be in place.
9. Data Breach
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, We shall promptly assess the risk to your data and if appropriate report this breach to the DPC (more information on the DPC website).
In instances where where a breach is likely to result in a high risk to your personally, we will inform you within 72 hours as required by the breach notification rules.
10. Contact Information
Our Data Protection Officer is [John Smith] whose email address is [email protected] and whose address is [XYZ].