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Privacy Policy

What is the Purpose of this Privacy Statement?

dlr Leisure’s Privacy Statement refers to our commitment to our compliance to data protection legislation including the Irish Data Protection Acts and the EU General Data Protection Regulation.

Who does this Privacy Statement refer to?

This policy refers to all parties (job candidates, employees, clients, contractors, suppliers and other parties etc.) whose personal data is processed by us.

Who must follow this Privacy Statement?

Employees of dlr Leisure must follow this policy. Contractors, consultants, partners and any other external entity are also required to comply.

What data is included?

As part of our services, we need to obtain and process data. This data includes any offline physical data or online data that makes a person identifiable such as names, addresses, usernames and passwords, IP addresses, any online identifier, CCTV, digital footprints, photographs, social security numbers, financial data etc. It also may include one or more factors specific to the physical, physiological, genetic, mental, cultural or social identity of that person.

Types of Personal Data

Ensure your organisation has provided all the relevant information applicable from this table below:

Demographic Data

Legal Basis: Contractual Necessity

Retention Period: —

Purpose: For employment purposes

Name, surname, date of birth

Contact Details

Legal Basis: Contractual Necessity

Retention Period: —

Purpose: For employment purposes

Home landline, personal/work mobile, postal address, personal/work email

Financial Data

Legal Basis: Contractual Necessity

Retention Period: —

Purpose: To process payroll

Start date, pay type, job title, salary, payroll no., PPS no., bank details, etc.

Digital Identifiers

Legal Basis: Legitimate Interests

Retention Period: 1–3 months depending on backups

Purpose: To control information inbound to the service and outbound to the internet

IP, MAC, metadata, cookie IDs, advertising IDs, pixel tags, account handles

Social Media

Legal Basis: Legitimate Interest

Retention Period: —

Purpose: —

Twitter, Facebook, LinkedIn, Pinterest, Instagram, Snapchat

Special Categories Data

Legal Basis: Contractual Necessity

Retention Period: —

Purpose: For payment purposes

Trade union membership

Government Identifiers

Legal Basis: Legitimate Interest

Retention Period: —

Purpose: For processing payroll

Personal public service number

Other

Legal Basis: Legitimate Interest

Retention Period: Yearly

Purpose: To process out of pocket expenses

Car registration, insurance policy, motor tax/NCT, indemnity letters

How dlr Leisure collects your data

We collect this data in a transparent way and only with the full knowledge of interested parties. Once this information is available to dlr Leisure, the following rules apply:
  • Accurate and kept up-to-date
  • Collected fairly and for lawful purposes only
  • Processed on the basis of either a valid contract, consent, legal compliance or legitimate interest
  • Protected against any unauthorized access or illegal processing by internal or external parties
Our data will not be:
  • Communicated to any unauthorized internal or external parties
  • Stored for more than a specified amount of time
  • Transferred to organizations, states or countries outside the European Economic Area without adequate safeguards being put in place as required under Data Protection law
Where consent is relied upon as a basis for processing of any personal data, you will be presented with an option to agree or disagree with the collection, use or disclosure of personal data. Explicit consent will be required for the processing of any special category and/or data belonging to a person under the age of 16.

What are the 7 principles we comply to?

  • Lawful, Fair and Transparent – Ensuring valid obtaining and processing of personal data
  • Purpose Limitation – Ensuring data is kept for one or more specified, explicit and lawful purposes
  • Data Accuracy – Ensuring the data processed is accurate, complete and up-to-date
  • Data Minimisation – Ensuring the data processed is adequate, relevant and not excessive
  • Storage Limitation – Ensuring personal data is kept for no longer than necessary
  • Integrity and Confidentiality – Ensuring the safety & security of data
  • Accountability – Ensuring correct records are maintained

Disclosure of Data

Your personal information may be processed by other organizations on our behalf for the purposes outlined above. We may disclose your information to the following:
  • Revenue, Social Welfare, Data Protection Commission
  • Outsourced employment law advisors, auditors, pension brokers & trustees
  • Financial institutions, debt collectors, consultants, IT providers
  • Couriers, shredding company, security company, printing company
  • Accountants/auditors, insurers, partners, associates, agents or subcontractors
  • Possible successors to our business
We may disclose your data for internal administrative purposes or personal data processing within a group of undertakings. Some parties may reside outside the European Economic Area. If so, your data will be treated to the same standards adopted in Ireland. We may also disclose your data for crime prevention or detection, to protect the interests of dlr Leisure or others, or if required to do so by law.

Information We Provide Before Processing

Prior to processing any data, dlr Leisure will always provide the following:
  • Which of your data is collected
  • How dlr Leisure processes your data
  • The purpose for processing
  • Who has access to your information
  • Provisions in case of lost, corrupted or compromised data
  • Your rights related to modification, erasure, reduction or correction

Rights

Right to Erasure

You have the right to have your personal data deleted without undue delay if:
  • The personal data is no longer necessary in relation to the purpose(s) for which it was collected/processed
  • You are withdrawing consent and there is no other legal ground for processing
  • You object to the processing and there are no overriding legitimate grounds
  • The personal data has been unlawfully processed
  • The personal data must be erased so that dlr Leisure is in compliance with a legal obligation
  • The personal data was collected in relation to the offer of information society services with a child
If your data was made public, dlr Leisure will take reasonable steps to inform processors of your request for erasure. If it was disclosed to third parties, we’ll notify them where possible and confirm this to you where appropriate.

Right to Data Portability

You may receive your data in a structured, commonly used, machine-readable format if:
  • Processing is based on consent
  • Processing is carried out by automated means
We can transfer your data to a service provider of your choice upon written instruction, if technically feasible. However, we may refuse this if we process your data for public interest or official authority purposes. We will redact third-party data if necessary to protect others.

Right to Object

You may object to dlr Leisure processing your personal data if:
  • The grounds relate to your situation
We will stop processing unless we demonstrate compelling legitimate grounds or it's for legal claims. For direct marketing, you may object at any time. You may also exercise your objection via technical specifications within information society services.

Right to Restriction of Processing

You may restrict processing of your personal data if:
  • You contest its accuracy
  • You prefer restriction over erasure where processing is unlawful
  • We no longer need the data but require it for legal defence
  • You're waiting for our legitimate interest review following objection
If we’ve disclosed data to third parties, we’ll notify them of the restriction unless it’s impossible or requires disproportionate effort. We’ll also inform you if a restriction is lifted.

Right to Rectification

If data we hold is inaccurate, we will rectify it without delay and confirm. If disclosed to third parties, we’ll ask them to rectify and notify you of whom it was shared with.

Right to Withdraw Consent

You may withdraw consent at any time where processing is based on it. Processing prior to withdrawal remains lawful.

Right to Lodge a Complaint

You can lodge a complaint with the Data Protection Commission regarding any processing by dlr Leisure of your personal data. It’s simple and free — write to the Commission detailing:
  • The organisation/individual involved
  • Steps you've taken to resolve your concern
  • The response received
  • Any correspondence or supporting evidence
The Commission will investigate the matter on your behalf.

Contact

Contact us at [email protected]

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