Friends From Ireland Data Protection Policy
The purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of Friends From Ireland. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003).
Information Collection. We may collect personal information including your name, address, email address, telephone or mobile number, user name and password, geolocation information, and, if you make a purchase on the Platform, your payment information, as well as non-personal information about your use of the Platform.
Information Use. We may use the information we collect from and about you for purposes including to provide you with Platform services, provide you with targeted offers and advertising on our site, other sites you may visit, and through other channels such as email, postal mail, or text message, and contact you when necessary.
Information Sharing. We may share the information we collect from and about you with our service providers, when necessary to protect our rights or comply with judicial process, and in aggregate or non-personally identifiable form.
Note: You must be 18 years or older to register as a customer of friendsfromireland.ie.
friendsfromireland.ie may use the information we collect from and about you for any of the following purposes:
1. To respond to your inquiries or requests, process and fill customer orders, verify your qualifications for certain products and services, process payments and prevent transactional fraud, provide delivery and other notifications, and contact and communicate with you;
2. To develop new products or services and to conduct analysis to enhance current products and services;
3. To provide you with customized Platform content, targeted offers, and advertising on the Platform, on other third-party sites or apps you may visit, or via email;
4. To contact you with information, newsletters and promotional materials from friendsfromireland.ie through various channels including but not limited to online, email, postal mail, and text message ;
5. To contact you when necessary;
6. To review the usage and operations of our Platform, improve our content, products, and services, or address problems with the Platform or our business;
7. To use your data in an aggregated non-specific format for analytical and demographic purposes;
8. To manage our telecommunications networks;
9. To protect the security or integrity of the Platform and our business; and
10. As otherwise described to you at the point of data collection.
Friends From Ireland must comply with the Data Protection principles set out in the relevant legislation. This Policy applies to all Personal Data collected, processed and stored by Friends From Ireland in relation to its staff, service providers and clients in the course of its activities. Friends From Ireland makes no distinction between the rights of Data Subjects who are employees, and those who are not. All are treated equally under this Policy.
The policy covers both personal and sensitive personal data held in relation to data subjects by Friends From Ireland. The policy applies equally to personal data held in manual and automated form.
All Personal and Sensitive Personal Data will be treated with equal care by Friends From Ireland. Both categories will be equally referred to as Personal Data in this policy, unless specifically stated otherwise.
This policy should be read in conjunction with the associated Subject Access Request procedure, the Data Retention and Destruction Policy, the Data Retention Periods List and the Data Loss Notification procedure.
Friends From Ireland as a Data Controller
In the course of its daily organisational activities, Friends From Ireland acquires, processes and stores personal data in relation to:
• Employees of Friends From Ireland
• Customers of Friends From Ireland
• Third party service providers engaged by Friends From Ireland
In accordance with the Irish Data Protection legislation, this data must be acquired and managed fairly. Not all staff members will be expected to be experts in Data Protection legislation. However, Friends From Ireland is committed to ensuring that its staff have sufficient awareness of the legislation in order to be able to anticipate and identify a Data Protection issue, should one arise. In such circumstances, staff must ensure that the Data Protection Officer is informed, and in order that appropriate corrective action is taken.
Due to the nature of the services provided by Friends From Ireland, there is regular and active exchange of personal data between Friends From Ireland and its Data Subjects. In addition, Friends From Ireland exchanges personal data with Data Processors on the Data Subjects’ behalf.
This is consistent with Friends From Ireland’s obligations under the terms of its contract with its Data Processors.
This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a Friends From Ireland staff member is unsure whether such data can be disclosed.
In general terms, the staff member should consult with the Data Protection Officer to seek clarification.
Subject Access Requests
Any formal, written request by a Data Subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible. Subject Access Requests can be made online here.
It is intended that by complying with these guidelines, Friends From Ireland will adhere to best practice regarding the applicable Data Protection legislation.
In the course of its role as Data Controller, Friends From Ireland may engage third party Data Processors to process Personal Data on its behalf. Friends From Ireland make every effort to only engage third party processors that understand their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Irish Data Protection legislation. Friends From Ireland do not give or sell personal data to 3rd parties.
Friends From Ireland may also receive personal data about you from Google Analytics, Bing, Lead Forensics, and Ruler Analytics.
Third-Party processors – Payments
IP addresses and Cookies
By visiting friendsfromireland.ie, Friends From Ireland may collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration and statistical purposes.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting our website our computer server recognises the cookie thereby giving us information about your last visit. These cookies help us to improve our website and help deliver a better and more personalised service. They enable us:
to estimate our audience size and usage pattern;
to store information about your preferences, and so allow us to customise our website according to your individual interests and make your usage of our website more enjoyable; and
to speed up searches.
For information on how to control your cookies click here.
As outlined in this policy, Friends From Ireland is committed to protecting your personal data. To prevent unauthorised access or disclosure of personal data under our control, Friends From Ireland has appropriate security management systems in place to safeguard the personal data we collect. Firewalls, intrusion detection and virus scanners are used on our website. Encryption (SSL) during transmission is also used on sections of our website where security is particularly important.
While Friends From Ireland make all reasonable efforts to protect personal data, no data transmission over the Internet can be guaranteed to be 100% secure. As a result Friends From Ireland cannot 100% ensure the security of any personal data you transmit to us so please be aware that you send personal data at your own risk. You acknowledge that Friends From Ireland is not responsible for any intercepted information sent via the Internet, and you hereby waive, release and discharge Friends From Ireland from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
Where Friends From Ireland have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not to share your password with anyone.
The Data Protection Principles
The following key principles are enshrined in the Irish legislation and are fundamental to the Friends From Ireland’s Data Protection policy.
In its capacity as Data Controller, Friends From Ireland ensures that all data shall:
… be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
The identity of the Data Controller (Friends From Ireland)
The purpose(s) for which the data is being collected
The person(s) to whom the data may be disclosed by the Data Controller
Any other information that is necessary so that the processing may be fair.
Friends From Ireland will meet this obligation in the following way.
Where possible, the informed consent of the Data Subject will be sought before their data is processed;
Where it is not possible to seek consent, Friends From Ireland will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
Where Friends From Ireland intends to record activity on CCTV or video, a Fair Processing Notice will be posted in full view;
Processing of the personal data will be carried out only as part of Friends From Ireland’s lawful activities, and Friends From Irelandwill safeguard the rights and freedoms of the Data Subject;
The Data Subject’s data will not be disclosed to a third party other than to a party contracted to Friends From Ireland and operating on its behalf.
…. be obtained only for one or more specified, legitimate purposes.
Friends From Ireland will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which Friends From Ireland holds their data, and Friends From Ireland will be able to clearly state that purpose or purposes.
….. not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by Friends From Ireland will be compatible with the purposes for which the data was acquired.
…. be kept safe and secure.
Friends From Ireland will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Friends From Ireland in its capacity as Data Controller.
Access to and management of staff and customer records is limited to those staff members who have appropriate authorisation and password access.
… be kept accurate, complete and up-to-date where necessary.
Friends From Ireland will:
ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. Friends From Ireland conducts a review of sample data every six months to ensure accuracy; Staff contact details and details on next-of-kin are reviewed and updated every two years.
conduct regular assessments in order to establish the need to keep certain Personal Data.
… be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
Friends From Ireland will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
… not be kept for longer than is necessary to satisfy the specified purpose(s).
Friends From Ireland has identified an extensive matrix of data categories, with reference to the appropriate data retention period for each category. The matrix applies to data in both a manual and automated format.
Once the respective retention period has elapsed, Friends From Ireland undertakes to destroy, erase or otherwise put this data beyond use.
… be managed and stored in such a manner that, in the event a Data Subject submits a valid Subject Access Request seeking a copy of their Personal Data, this data can be readily retrieved and provided to them.
Friends From Ireland has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
Your Legal Rights
Under certain circumstances you have rights under applicable data protection law in relation to personal data, namely:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data Friends From Ireland hold about you and to check that Friends From Ireland is lawfully processing it. Make a Subject Access Request here.
Request correction of the personal data that Friends From Ireland hold about you.
Request deletion of your personal data where there is no good reason for Friends From Ireland to continue to process it. (Note, Friends From Ireland may not always be able to comply with your request to delete personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.)
Object to processing of your personal data where Friends From Ireland are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Object where Friends From Ireland are processing your personal data for direct marketing purposes. In some cases, Friends From Ireland may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask Friends From Ireland to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where use of the data is unlawful but you do not want Friends From Ireland to erase it; (c) where you need Friends From Ireland to hold the data even if Friends From Ireland no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but Friends From Ireland need to verify whether there are overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. Friends From Ireland will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Withdraw consent at any time if and to the extent Friends From Ireland rely on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Friends From Ireland may not be able to provide certain services to you.
Data Subject Access Requests
As part of the day-to-day operation of the organisation, Friends From Ireland’s staff engage in active and regular exchanges of information with Data Subjects. Where a formal request is submitted by a Data Subject in relation to the data held by Friends From Ireland, such a request gives rise to access rights in favour of the Data Subject.
There are specific time-lines within which Friends From Ireland must respond to the Data Subject, depending on the nature and extent of the request. These are outlined in the attached Subject Access Request process document.
Friends From Ireland’s staff will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request. A Subject Access Request can be made here.
As a Data Controller, Friends From Ireland ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation.
Failure of a Data Processor to manage Friends From Ireland’s data in a compliant manner will be viewed as a breach of contract, and will be pursued through the courts.
Failure of Friends From Ireland’s staff to process Personal Data in compliance with this policy may result in disciplinary proceedings.
For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.
Data This includes both automated and manual data.
Automated data means data held on computer, or stored with the intention that it is processed on computer.
Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.
Personal Data Information which relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, Friends From Ireland refers to the definition issued by the Article 29 Working Party, and updated from time to time.)
Sensitive Personal Data A particular category of Personal data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s Sexual Orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.
Data Controller A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.
Data Subject A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.
Data Processor A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.
Data Protection Officer A person appointed by Friends From Ireland to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to Data Protection queries from staff members and service recipients
Relevant Filing System Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals, or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.
If you would like any further information, contact us here.