Privacy

PIER Data Protection Policy

Definitions

1. Data Protection Principles

PIER is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;

2. 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;

3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

4. 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;

5. 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

6. 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

1. This policy applies to all personal data processed by PIER.

2. The Executive Committee shall take responsibility for PIER’s ongoing compliance with this policy.

3. This policy shall be reviewed at least annually.

3. Lawful, Fair and Transparent Processing

1. To ensure its processing of data is lawful, fair and transparent, PIER shall maintain a Register of Systems (See Appendix)

2. The Register of Systems shall be reviewed at least annually.

3. Individuals have the right to access their personal data and any such requests made PIER shall be dealt with in a timely manner.

4. Lawful Purposes

1. All data processed by PIER will be done on the basis of consent when applying for annual membership

2. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.

3. 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 in PIER’s systems. 

5. Data Minimisation

1. PIER shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

1. PIER shall take reasonable steps to ensure personal data is accurate.

2. 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

1. To ensure that personal data is kept for no longer than necessary, users will be removed as requested or otherwise deemed appropriate by the Executive Committee.

2. Any member whose membership has expired by one year or more will have their account and all information relating to them stored by PIER permanently deleted in order to comply with GDPR. If a past member wishes to re-join PIER after their account has been permanently deleted they must create an entirely new account.

8. Security

1. PIER shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 

2. Access to personal data shall be limited to the Executive Committee who need access and appropriate security should be in place to avoid unauthorised sharing of information.

3. When personal data is deleted this should be done safely such that the data is irrecoverable.

4. Appropriate back-up and disaster recovery solutions shall be in place.

9. 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, PIER shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Office of the Data Protection Commissioner https://www.dataprotection.ie/docs/Data_Security_Breach_Code_of_Practice/1082.htm

END OF POLICY

Appendix 1: Register of Systems

1. How Personal information is collected

   1. Personal information is collected when members apply for membership via the PIER website

2. What personal information is collected?

   1. Name

   2. Email Address

   3. Postal Address

   4. Telephone Number

3. Why is the personal information stored?

   1. To provide information members have asked for

   2. To provide the emailing service members have requested from PIER on membership

   3. To request additional information from members

   4. To develop and improve PIER’s services, i.e. learn members’ interests in order to provide them with relevant information

4. Sharing of information

   1. PIER will not share, sell or otherwise make available member information to third parties without their express prior permission

5. Systems used to process personal data

   1. PIER website

   2. Email service provider (MailChimp), in accordance with their privacy policy and terms.