Data Protection and Privacy 2018

Introduction

The purpose of the Military Heritage of Ireland Trust CLG, (hereafter referred to as “the Trust”),  Data Protection and Privacy Policy is to protect the rights, privacy and personal information of individuals in accordance with the Data Protection Acts, 1988 – 2018, and the European Union’s General Data Protection Regulation (GPDR) which became effective from 25th of May 2018.

For more information on GDPR visit the EUs’site:   http://www.arosuite.com/tracking/Link.aspx?MessageID=121116829&LinkID=508864

In addition to routine governance, the Trust’s Data Protection and Privacy Policy also covers the Trust’s website and Trust’s Flicker Channel.

Use of Personal Data

Committed to transparency and protection, the Trust collects, retains, and uses personal data for the following purposes:

  • Governance of the Trust,
  • Administration of membership and annual subscriptions, and
  • Response to research queries regarding military heritage.

Collection of Personal Data

Personal data is obtained from voluntary membership application forms, and in respect of the Trust’s Directors, Company Registration Office forms.  Personal data may also be offered by individuals researching aspects of military heritage.  Likewise, external actors may provide personal data to the Trust.  As the Trust does not employ individuals, the retention of associated personal data does not pertain.  Personal data may include:

  • Members: Name, Address, Email Address, Phone Number, Occupation and Interests in Military Heritage,
  • Directors: As per Members, plus, nationality and Company Directorships,
  • Researchers: Name, Address, Phone Number and Email Address, and
  • External Actors: Name, Address, Phone Number and Email Address.

Members or individuals availing of the Trust’s website Pay Pal process for the payment of donations are reminded that the Trust does not have access to personal data used in such transactions.   Link to Pay Pal Privacy Statement – https://www.paypal.com/ie/webapps/mpp/ua/privacy-full

External Actors 

In order to advance its governance and objectives, the Trust securely maintains names and contact details of external actors such as  IT providers, Public Relations Agencies, Publishers, Auditors, Legal Advisors, Government officials, military personnel, Veterans’ Associations, Regimental Associations, museums, persons running heritage societies, academics and guest lists.

Disclosure of Personal Data

The Trust will not disclose personal data to third parties outside the European Economic Area.  With the exception of the following, the Trust will not disclose personal data to third parties:

  • Regulatory authorities, such as the Companies Registration Office,
  • The Trust’s Auditor in respect of the Directors and Company Secretary,
  • The Department of An Taoiseach in order to recommend invitations for the Annual National Commemoration Ceremony, containing the names and addresses of its members.
  • The commander of a military installation in order to facilitate entry to that installation, which is hosting a Trust activity, and
  • Those providing an administrative service to the Trust, in respect of the Chairman and Company Secretary.

 Principles for Data Protection and Privacy Management 

The Trust:

  • Obtains the personal data fairly, for the purposes as described above.
  • Treats personal data with the highest standards of security and confidentiality
  • Uses and discloses such data only in the circumstances necessary for the purposes for which it collects the data.
  • Processing of personal data is by consent and the right to withdraw consent.
  • Whether in paper files, or on IT systems, the Trust keeps data secure within its offices, in order to ensure that no unauthorised person has access to it.
  • Keeps records as accurate, complete and as up-to-date as possible.
  • Does not ask for, nor keep any data not required, for its purposes.
  • Retains personal data only for as long as is necessary for the satisfactory performance of the Trust’s functions.
  • The retention period of the personnel data of lapsed members, including Directors, is two years.
  • Takes account of and adheres to all statutory retention requirements such as provided for in taxation legislation.
  • Will give, on request, a copy of a particular’s personal data held by the Trust.
  • The Trust does not maintain personal data of individuals accessing its website.

 Queries on Military Heritage Matters

 In order to respond to requests for information on military heritage, the Trust securely retains personal data such as name, address and telephone of those seeking such information.  Personal data will be redacted from any correspondence retained by the Trust, following the closure of the actual query.

The Trust securely archives correspondence which could be of value in dealing with subsequent queries.  Should the archived correspondence be used for academic research, such correspondence will not include the originator’s personal information.

The Trust provides sources for information, e.g. websites, regarding deceased personnel of the Defence Forces and other Armed Forces, to assist people who are seeking to find out information relating to relatives and individuals military service.  In line with the Data Protection Acts, the Trust does not provide service particulars, or other information, on living, serving or former military personnel.

Trust’s Website

The content of the Trust’s website is for general information purposes only.  The posting of personal data on the website is by consent, e.g. nominal roll of former and current Directors, Company Secretary and Legal Advisor, and winners of the Military Heritage Annual Award (2010 – 2017).  Personal data of individuals posted on the website’s news and event calendar are already within the public domain.

The Trust will never attempt to identify a user of its website, or to associate a user’s technical data to a particular individual.

Apart from personal data volunteered through the Trust’s website’s Contact Us Section, or through its email server, the Trust does not collect, or retain, any personal information arising from these activities.

Such personal data will not be provided to third parties, other than those working with the Trust on normal Trust business.  The personal data will only be used by the Trust in accordance with the purpose for which the data was provided, and will only be retained for as long as required for that purpose.

The Trust will not process any such personal data without permission, save in cases where the Trust is required by law to do so.

The Trust avails of the Google Analytics Suite for statistical purposes, such as compiling reports for the Board of Directors meetings and the Annual General Meeting, on its website activity.

Arising from the GDPR, as the website is accessed by users in the European Economic Area, the Trust accepts, as appropriate, the data processing terms of conditions associated with the collection mechanism of the Google Analytics Suite products.

Users to the Trust’s website should be aware that, as in the case of all websites, the user’s web browser will avail of cookies (text files) to identify a user’s website activity.  In the case of the Trust, the associated cookies (text files) are solely from Google Inc.

The retention of user technical information such as IP addresses, arising from the Trust’s Google Analytics Suite will be stored by Google Inc in the United States for a period of 12 months, which is a period determined by the Trust.  The Trust will not disclose user technical information to third parties.

Google Inc will not associate a user’s IP address to any other Google data.  However, when required by law, Google may transfer such information to a third party.

Email Consent

Individuals receiving emails from the Trust can withdraw consent by contacting the Data Protection Officer or Controller.  Email: secretary@militaryheritage.ie

Individual Photographs

Where appropriate, individual photographs posted on the Trust’s website will have prior consent.

Photographs from an official photographer, accredited by the event organiser, may be posted on the Trust’s website or on the Trust’s Flickr Account.  The Trust assumes that photographs taken by accredited photographers have the prior consent of the individual present at such events.  Link to Flickr Privacy Policy:  – https://policies.oath.com/ie/en/oath/privacy/products/flickr/index.html

Individuals whose photographs are posted on the Trust’s website or on the Trust’s Flickr Channel can withdraw consent by contacting the Trust’s Data Protection Officer or Controller. Email:      secretary@militaryheritage.ie

Exercising Rights

 The Trust’s membership, including its Directors, has several rights regarding the usage of personal data.

These include the right to ascertain how your personal data is used, the right in certain circumstances to have your personal data is deleted or its usage restricted, the right to have incorrect personal data  to be corrected and updated, and the right to withdraw consent for the usage of your personal data.

Should you wish to exercise any of your personal data rights, the Trust’s contacts details are available below.

You also have the right to complain to the Data Protection Commission:

Telephone: 00 353 (0) 761 104 800

Lo Call: 1890 252 231

Email: info@dataprotection.ie

Postal Address: Canal House, Station Road, Portarlington, R32 AP23, Co Laois.

 Annual Audit

An annual Data Protection and Privacy audit will be conducted in respect of each year ending
31 December, and will be presented to the Board of Directors at its subsequent meeting.

Supervisory Authority

  • Data Controller: The individual appointed by the Trust’s Board of Directors as the Company Secretary.
  • Data Protection Officer: The individual appointed by the Trust’s Board of Directors as the Assistant Company Secretary.

Data Protection and Privacy Queries or Complaints

Queries or complaints in connection with the processing of personal data can be lodged by:

  • Post: The Military Heritage of Ireland Trust CLG, The Registry, McKee Barracks, Blackhorse Avenue, Dublin 7.
  • Email: secretary@militaryheritage.ie