Digital Rights Ireland CLG Privacy Notice

Version Tracking: Last update 22nd September 2019

This privacy notice tells you how we, Digital Rights Ireland Company Limited by Guarantee (DRI), will collect and use your personal data to provide our services of advocacy, representation per Article 80 of the GDPR and providing information to the public.

DRI takes privacy and data protection seriously and will always endeavour to reply to your queries as quickly as possible.

Who are we? Digital Rights Ireland is dedicated to defending Civil, Human and Legal rights in a digital age. We are based in Ireland, but aim to also have European and global impact.

What’s covered by this Privacy Notice?

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Where DRI processes personal data on its own behalf or where personal data is processed on its behalf, it is the Data Controller for all the data collected. Where DRI processes data on a 3rd party’s behalf, is the Data Processor for that 3rd party.

Why does DRI need to collect and store personal data?

In order for us to provide you with DRI’s services we need to collect personal data for correspondence purposes and/or for administrative purposes required by our legal obligations to you or others in representing data subjects under Article 80 of the GDPR. In any event, we are committed to ensuring that the information we collect and use is appropriate for the purposes for which it is collected. DRI is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make the DRI work for you.

If you are going to be contacted by us for marketing or communication purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s OK to do that.

  • In general we collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with DRI. We are committed to transparency in this.

Our legal bases for processing personal data are:

        • Article 6.1(b), GDPR, Contract

        • Article 6.1(a), GDPR, Consent

        • Article 6.1(c), GDPR, Legal Obligation

We do not process any special category personal data under Article 9, GDPR.

Will DRI share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to DRI in the course of dealing with you. We do this because there are some contractual services, such as maintaining our newsletter and other contact mailing lists, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with DRI’s procedures. If you would like an up-to-date register of all our third-party service providers, please contact us and we will be happy to provide it.

How will DRI use the personal data it collects about me?

DRI will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. DRI maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed for the minimum amount of time required to meet the purpose for which it was collected. DRI is required to retain certain information in accordance with the Law, such as staff information needed for company acts returns, income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual needs.

Can I find out what personal data DRI holds about me?

DRI at your request, can confirm what information we hold about you and how it is processed. If DRI does hold personal data about you, you have the right to request the following types of data about you:

  • The identity and the contact details of the person or organisation that has determined how and why to process your data (the Data Controller).

  • The purpose of the processing as well as the legal basis for processing.

  • If the processing is based on the legitimate interests of DRI or a third party, information about those interests.

  • The categories of personal data collected, stored and processed.

  • Recipient(s) or categories of recipients that the data is/will be disclosed to.

  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.

  • How long the data will be stored.

  • Details of your rights to correct, erase, restrict or object to such processing.

  • Information about your right to withdraw consent at any time.

  • How to lodge a complaint with the supervisory authority.

  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

  • The source of personal data if it wasn’t collected directly from you.

  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

You also have the right to make certain requests of us regarding your personal data. Each request will be assessed and acted upon as appropriate within the relevant statutory time limits.

What forms of ID will I need to provide in order to access this?

In certain circumstances DRI could ask for additional information and the following forms of ID when information on your personal data is requested:

  • A colour copy of a Passport, driving licence or other photo ID

  • A copy letter from a government office, bank or other institution addressed to you at your postal address

  1. Agreeing to these terms by entering into an agreement with DRI or by any other means is an unambiguous indication of your Consent to the processing outlined in it. By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for DRI to process both standard and sensitive types of personal data, but it must be explicitly given, your agreement to the terms set out in this Privacy Notice will suffice to demonstrate that consent.

  2. If we ask you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice or any accompanying contractual Terms and Conditions (as applicable) (or any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

  3. You may withdraw consent at any time by the following process: Please identify your role in relation to DRI (if you are a member, supporter, donor etc.), and the data you wish to withdraw consent to be processed.

  4. Most data held by DRI is not held solely on the basis of consent, and where there is an alternative legal basis- such as legal requirement or contract- withdrawing consent may not result in our immediate erasure of data being stored or processed.

  • DRI will pass on your personal data to certain third parties. DRI is an Irish corporate body, uses cloud services which may be accessed by DRI Directors or professional advisors in any part of the world.

Third country (non-EU)/international organisation

Safeguards in place to protect your personal data

MailChimp

Use of the EU’s Standard Contract Clauses and Privacy Shield

  • Retention periodDRI will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact contact@digitalrights.ie.

  • Your rights as a data subjectAt any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

        1. Right of access – you have the right to request a copy of the information that we hold about you.

        2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

        3. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

        4. Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

        5. Right of portability – you have the right to have the data we hold about you transferred to another organisation.

        6. Right to object – you have the right to object to certain types of processing such as direct marketing.

        7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

  • Where DRI are your Data Controller, you may make a request directly to the relevant privacy officer of the company using the email contact@digitalrights.ie.Where DRI are a Data Processor, and act on behalf of a data controller (such as a 3rd party partner company in a different country) any requests received by DRI will be passed on to the Data Controller.
 


  • ComplaintsIn the event that you wish to make a complaint about how your personal data is being processed by DRI (or third parties as described above), or how a complaint has been handled, you have the right to lodge a complaint directly to with our supervisory authority.

The details of Contacts for where DRI are the Data Controller:

Data Controller contact:

Postal address: Digital Rights Ireland CLG, 10 Castlehill, Bennetsbridge Road, Kilkenny.

Data Protection Authority:

Postal address: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2

Email: info@dataprotection.ie

Telephone: +353 57 8684800

ANNEX 1

Data Processed by or on behalf of DRI as Data Controller

Purpose

Legal Basis 2

Retention duration

Payroll

Article 6.2(b) Contract

Period of Employment + 6 years

Recruitment

Article 6.2(b) Contract

Period of Probation Employment

Employment (Contract)

Article 6.2(b) Contract

Period of Employment + 6 years

Bus Hire

Article 6.2(b) Contract

During Ongoing Relationship

School Placement of Students

Article 6.2(b) Contract

Period of Student attendance + 6 months

Host Placement of Students

Article 6.2(b) Contract

Period of Student attendance

Garda Vetting

Article 6.2(b) Contract

During ongoing Relationship