Privacy Policy and Notice

If you have any queries, please contact me either by email or telephone to discuss.

“Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any Personal Data is processed, who/which make independent decisions in relation to the Personal Data and/or who/which otherwise control that Personal Data.

For the purposes of the GDPR, ProPrivacy Consulting Limited is the data controller with regard to the Personal Data described in this Privacy Policy. ProPrivacy Consulting Limited is based in Ireland and offers business consulting services with a focus on data protection and privacy law.

Our Data Protection Coordinator can be contacted as follows:-
Telephone: +353 21 234 8890
Email: dataprotection@proprivacy.ie
Post: ProPrivacy Consulting Limited, Bridgetown, Castletownroche 

The purpose of this document is to provide you as our data subject with a statement regarding the Data Protection and Privacy practices and obligations of ProPrivacy Consulting Limited t/a ProPrivacy, [the Organisation] and an explanation of your rights as a data subject. This Notice applies to our business practices, our website (Websites), which are accessible from proprivacy.ie and proprivacyconsulting.ie (redirected) and its sub-domains, as well as any associated mobile applications (Mobile Apps) owned and controlled by the Organisation. As the Organisation is established in the Republic of Ireland, this document is written in the vein of Irish Data Protection Law, as ProPrivacy Consulting Limited falls under the jurisdiction of the Irish Data Protection Commission. This Privacy Policy and Notice sets out what Personal Data we collect and process about you in connection with the services and functions of the Organisation. We are not responsible for the content or the privacy notices for any websites to which we provide external links.

Laws that apply to us:
• General Data Protection Regulation (EU Regulation 679/2016)
• Irish Data Protection Act 2018
• Regulations flowing from DPA 2018
• Data Protection Acts 1988 as amended in 2003, sections not repealed
• ePrivacy Regulations 2011 implementing EU Privacy and Electronic Communications Directive 2002/58/EC on Privacy and Electronic Communications, otherwise known as ePrivacy Directive (ePD) 

Our practices as described here now may be changed, but any changes will be posted, and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review this Notice periodically to make sure that you understand how any personal information you provide will be used. We may also email you to let you know if and when we update this Notice to ensure you are informed.

Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.

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Data protection provides rights to individuals with regard to the use of their Personal Data by organisations, including our organisation. Irish and EU laws on data protection govern all activities we engage in with regard to our collection, storage, handling, disclosure and other uses of Personal Data.

Compliance with the data protection rules is a legal obligation. In addition, our compliance with the data protection rules helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal information.

The data protection rules that apply to us are currently contained in the Data Protection Acts 1988 and 2003 not repealed, the Data Protection Act 2018, in the ePrivacy Regulations 2011, the EU General Data Protection Regulation (EU Regulation 679/2016) (the “GDPR”) and in related legislation (together the “DPAs”).

We need to demonstrate accountability for our data protection obligations. This means that we must be able to show how we comply with the applicable Data Protection and Privacy Laws, and that we have in fact complied with the laws. We do this, among other ways, by our written policies and procedures, by building data protection and privacy compliance into our systems and business rules, by internally monitoring our data protection and privacy compliance and keeping it under review, and by acting if our representatives, including employees or contractors, fail to follow the rules. We also have certain obligations in relation to keeping records about our data processing.

All our representatives, which include employees and contractors, are required to comply with our Data Protection and Privacy Policy which inform this Privacy Policy and Notice when they process Personal Data on our behalf. We may disclose individuals’ information to trusted third parties for the purposes set out and explained in this document or as explained to you when we collect your data. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with applicable Data Protection and Privacy Laws and our Policies. We will not disclose personal information to any third party without your consent or on one of the grounds listed herein, except in incidences where an individual is potentially at risk or where the law requires it.

We aim to comply with the following principles found in Data Protection Law:

Lawfulness, fairness and transparency – Personal data must be processed lawfully, fairly and in a transparent manner.

Purpose Limitation. Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Data minimisation – Personal Data must be adequate, relevant and limited to what is necessary in relation to purposes for which they are processed.

Accuracy – Personal data must be accurate and, where necessary, kept up to date. Inaccurate Personal Data should be corrected or deleted.

Retention – Personal data should be kept in an identifiable format for no longer than is necessary.

Integrity and confidentiality – Personal data should be kept secure.

Accountability – Under the GDPR, we must not only comply with the above six general principles but we must be able to demonstrate that we comply by documenting and keeping records of all decisions.

Personal Data
We will collect personal data with you in accordance with the purposes outlined in this document.  This will be basic personal data used to facilitate a consultant/client type relationship usually your name and email address and from time to time billing information.  If you are a sole trader or partnership, we would consider your address to be personal data.

Special Category Personal Data
We will not collect special category data from you.

Criminal Conviction Data
We will not collect criminal conviction data from you.

Children’s Personal Data
If you would like to make use of our services and you are not yet 18 years old, we require that an adult is present when you register, if registration is required. Where consent is required to process your Personal Data as a child, we will obtain that consent from the adult who is authorised to give the consent on your behalf.  You must be at least 18 years old to create an account and engage in activities and transactions on our digital and social media. By creating an account or engaging in activities or transactions on our digital and social media, you affirm that you are at least 18 years old and are fully able to enter into and comply with our regular Terms of Use and this Privacy Policy. If we are notified or learn that a child has submitted Personal Data to us through our digital or social media without the correct permissions or consents, we will delete such Personal Data.

Directors and Employees of the Business
Directors and employees of ProPrivacy who are bound by confidentiality agreements will process personal data on behalf of the business.  

Service Providers
We may use trusted service providers who could be considered data processors, sub-processors or third parties. We need to have written agreements in place with all of our data processors and, before we sign each agreement, we need to have vetted and be satisfied with the processors data security. The agreements also need to contain specific clauses that deal with data protection. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with Irish and EU laws on data protection. Any such organisation or individual will have access to personal information needed to perform these functions but may not use it for any other purpose.

We use the following service providers in the course of our business:

Spiral Web Hosting
Google Analytics
Cookiebot
Microsoft (Office) 365 including Skype
Mailchimp

Surf Accounts
Wave Accounting (historic records)
Derek Madden and Co Accountants

Marie Ford Solicitor
PayPal
AIB

We may pass on your details if we are under a duty to disclose or share a Data Subject’s Personal Data in order to comply with any legal obligation, or in order to enforce or apply any contract with the Data Subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes reporting information about incidents (as appropriate) to the law enforcement authorities and responding to any requirements from law enforcement authorities to provide information and/or Personal Data to them for the purposes of them detecting, investigating and/or prosecuting offences or in connection with crime sentencing.

Other than the above, we will not disclose personal information to any third party without your consent except in incidences where an individual is potentially at risk or where the law requires it.

Currently, we do not engage in regular international transfers of data unless you are a client that resides outside of the EEA.  

We make use of MailChimp sparingly as MailChimp processes your data in the USA.  Mailchimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.

Depending on your choice of cookies, there may be one cookie that transfers data to the USA served from Google Analytics namely the "collect" cookie.  Google participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.

International Transfers
If we transfer your Personal Data out of the EEA, we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.

2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.

3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US.

Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.  As Profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.  As a responsible company, we do not use automatic decision-making or profiling.

We follow strict security procedures in the storage and disclosure of your Personal Data, and to protect it against accidental loss, destruction or damage. We take appropriate security measures against unlawful or unauthorised processing of Personal Data, and against the accidental loss of, or damage to, Personal Data. The data you provide to us is protected using modern encryption, intrusion prevention, and account access techniques. We have put in place procedures and technologies to maintain the security of all Personal Data from the point of collection to the point of destruction. We use third party vendors and hosting partners to provide the necessary hardware, software networking, storage, and related technology required to run our business. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves. We maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

Confidentiality means that only people who are authorised to use the data can access it.

Integrity means that Personal Data should be accurate and suitable for the purpose for which it is processed.

Availability means that authorised users should be able to access the data if they need it for authorised purposes. 

We have a documented data retention schedule. Generally, we will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for and for up to seven (7) years afterwards (for purposes related to Revenue requirements) or otherwise permitted by applicable laws. We may also retain your information during the period of time needed to complete our legitimate business operations, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. Where appropriate, you will be asked whether you wish to receive any marketing communications from us.

We will not share your Personal Data with any third party for marketing purposes. You may object to direct marketing by using the contact details herein to opt-out or make use of the opt-out links on communications.

Manage cookies for this site here.

Cookies
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. Most web browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. 

Technical Personal Data
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. We may gather technical information for security reasons. We will make no attempt to identify individual visitors, or to associate the technical details listed below with any individual. We will only use the technical information for statistical and other administrative purposes.

We may collect this technical information from you when you visit our website and accept cookies. This information may include standard information from you (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our website (such as the web pages viewed and links clicked). We do note that your IP address is considered personal data under the GDPR. 

Certain information in relation to web usage is revealed via our internet service provider who records some of the following data. Whilst we do not access this information regularly, the technical information may be used to inform our security measures, to allow us improve the information we are supplying to our users, to find out how many people are visiting our sites and for statistical purposes. The information we receive depends upon what you do when visiting our site:
The IP address you are using.
The date and time you access our site.
The pages you have accessed and the documents downloaded.
The previous Internet address from which you linked directly to our site.
The user agent used to accessed our site.

Situations may arise where it is necessary to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our organisation provided that the third party agrees to adhere to the terms of the Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. The Personal Data transferred will be limited to that which is absolutely necessary. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

By consenting, where this is the appropriate grounds, to our processing your Personal Data in line with this Privacy Policy you are giving us permission to process your Personal Data specifically for the purposes identified.

You may withdraw consent at any time by providing an unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify withdrawal of consent to the processing of Personal Data relating to you. If you have any queries relating to withdrawing your consent, please contact our Data Protection Coordinator using the contact details set out below.

Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.

Categories of Data Purpose/Activity Possible Lawful Basis for Processing
Name and Contact Details To manage our relationship with you as our customer, supplier, or contractor (a) Performance of a contract with you
(b) Necessary to comply with our legal obligation
Name and Contact Details Electronic account creation and/or management for e-learning purposes (a) Performance of a contract with you
(b) Necessary to comply with our legal obligation
Name and Contact Details To send you marketing material (a) Necessary for our legitimate interests (ensure sales continue)
(b) Consent
Name and Contact Details (and other personal data you might include in an email) To respond to requests or queries that you provide to us via email (a) Necessary for our legitimate interests (customer service)
(b) Necessary steps to prior to entering into a contract with you
Name and Contact Details Notifying you about changes to our terms or this policy where you may have signed up through MailChimp to receive such updates. (a) Necessary to comply with our legal obligation
(b) Consent
Name and Contact Details Asking you to leave a review or take a survey Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Name and Contact Details; IP Address To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
IP Address To use data analytics to improve our website, products/services, marketing and customer relationships and experiences Necessary for our legitimate interest (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Name and Contact Details To respond to your enquiry, feedback or complaint (a) Necessary to comply with a legal obligation
(b) Performance of a contract with you
Name and Contact Details (Invoices) To comply with our tax obligations Necessary to comply with a legal obligation.
Cookies (IP Address) Cookies can be managed on this link. (a) Necessary to comply with a legal obligation
(b) Consent

Under certain circumstances, by law you have the right to:

Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.

Request access to your personal information (commonly known as a “Data Subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.

We have appointed a Data Protection Coordinator to monitor compliance with our data protection obligations and with this policy and our related policies. If you have any questions about this policy or about our data protection compliance, please contact the Data Protection Coordinator.

Data subjects must make a formal request for Personal Data we hold about them or otherwise to exercise their data protections rights whether to make an access request or otherwise by contacting our Data Protection Coordinator who will respond to the request within 30 days.

We are obliged to comply with exceptions to your requests where laid out in law. Such exceptions relate to health data, disclosures that would be likely to cause serious harm to your physical or mental health or emotional condition and opinions given in confidence.

Our Data Protection Coordinator can be contacted as follows:-
Telephone: 021 234 8890
Email: dpc@proprivacy.ie
Post: ProPrivacy Consulting Limited, Bridgetown, Castletownroche

Your Right to Lodge a Complaint
You as the Data Subject have the right to complain at any time to a data protection supervisory authority in relation to any issues related to our processing of your Personal Data. As our organisation is located in Ireland and we conduct our data processing here, we are regulated for data protection purposes by the Irish Data Protection Commissioner.

You can contact the Data Protection Commissioner as follows:
Website: www.dataprotection.ie
Phone: +353 57 8684800 or +353 (0)761 104 800
Email: info@dataprotection.ie
Address: Data Protection Office – Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square Dublin 2. D02 RD28 Ireland 

This Policy has been approved and authorised by Philipa Jane Farley, Director of ProPrivacy Consulting Limited. 

Changelog
Original 20 June 2018
Updated 09 September 2018
Updated 05 March 2019
Updated 08 April 2019

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LET'S CONNECT

Philipa Farley is an Association of Data Protection Officers Member ProPrivacy is a Cork Chamber Member ProPrivacy is a Mallow Chamber Member Philipa Jane Farley is a Grow Remote Mallow Chapter Member

ProPrivacy Consulting Limited (t/a ProPrivacy) CRO Reg: 628639 VAT: 3547299MH Registered Office: Bridgetown, Castletownroche, Co. Cork
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