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
- 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
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
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
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
Right to Object
You may object to dlr Leisure processing your personal data if:- The grounds relate to your situation
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
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
