1. Data Privacy & Protection Principles
- 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 processed by us
- Our data protection officer shall take responsibility for our ongoing compliance with this policy
- This policy shall be reviewed at least annually
- We have registered with the Irish Data Protection Commission [DPC] as an organisation that processes personal data.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, we shall maintain a record or processing actitivies (ROPA)
- The ROPA shall be reviewed at least annually
- Individuals have the right to access their personal data free of charge and any such requests made to us shall be dealt within the statutory 28 day period.
4. Lawful purposes
- All data processed by us must be done on one of the following lawful basis: consent, contract, legal obligation, vital interests, public task or legitimate interests (see DPC guidance for more information).
- We shall note the appropriate lawful basis in the ROPA.
- 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 should be clearly available and systems should be in place to ensure such revocation is reflected accurately on carltondesign.ie technologies 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.
- Data will not be retained beyond 7 years in any instance unless legal hold/proceedings take precedence.
- 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 controls will 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. (i.e. FIPS standard)
- 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 people’s rights and freedoms 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 the affected individuals, we will inform those individuals within 72 hours as required by the breach notification rules.
10. Information Sharing
In order to provide you with a service, it maybe necessary to share your data from enquiry forms and emails with CRM providers for the purposes of sales tracking and recording. We ensure that these processors are GDPR compliant and data is retained in EU data centres at all times.
11. Contact Information
Our Data Protection Officer is Paul Rogers whose email address is [email protected] and whose address is 37 The long Avenue, Dundalk, Co Louth, A91F5X8.