Graphite HRM is the Data Controller for any personal data that you supply to us as part of the services you are contracted to receive from us. As our client, you are our data subject.
Our address is: Graphite HRM, Block W, East Point Business Park, Alfie Byrne Road, Dublin 3
Telephone 01 886 0350 Email email@example.com
What personal data we collect
The personal data collected depends on how you use our website. You can browse the site, you can fill in forms on the website to request information or quotes from us, download documents from us, or you can subscribe to our emails, and other activities. The Group’s websites collect personal data to provide these services.
We collect information about you when you instruct us to provide advice; visit our website; subscribe to our newsletters or to receive our publications; apply for employment with us; attend one of our seminars; and engage in business dealings with us.
What we do with your personal data
When you visit our website, a record of your visit is made. This data includes your device’s IP address. That data is used completely anonymously, in order to determine the number of people who visit our website and the most frequently used sections of the site. This enables us to continually update and refine the site. If you use any forms on the website to send an email to us, a record will also be made of your email address and your telephone number.
The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.
|What we do||Our legal basis under GDPR|
|Use the personal data that you provide on our web forms and questionnaires||Article 6(1)(b) – when you provide us with your personal data, for instance to obtain a quote for our services, this is a necessary step to take at the request of the data subject prior to entering into a contract|
|Provide our core services of health and safety, employment law advice, employment documentation and legal services||Article 6(1)(b) – this is necessary for the performance of a contract with you, our data subject|
|Provide our online services platforms – Bright HR, hronline, Business Safe Online||Article 6(1)(b) – this is necessary for the performance of a contract with you, our data subject|
|Contact you regarding the services we provide||Article 6(1)(f) – we need to contact you for our legitimate interests so that we can gather more information for the provision of our services, or to deliver those services most effectively|
|Retain your data under our data retention policy after your contract has expired||Article 6(1)(f) – we need to retain your personal data for only as long as necessary under the law to protect our legitimate interests|
|Where you require us to make Reasonable Adjustments to enable you to attend a meeting or interview, we may require further information from you.||Article 9(2)(a) of GDPR (explicit consent). If this includes information about your physical or mental health, such information (being sensitive personal data, Special Category data), will only be used by us, with your explicit consent, to assess your eligibility for Reasonable Adjustments. We will not share or disclose it to others. You can withdraw your consent as anytime by contacting us. Please note that we may not be able to process your request for Reasonable Adjustments if you do this.|
The following table sets out the categories of personal data that we obtain.
|Name, postal address, email address, website, identification number, location data, online identifier – these are classed as personal data||This data is provided by you on our web forms and questionnaires, either to obtain a quote from us, subscribe to one of our newsletters, request a service from us or as part of the provision of your existing contractual services. This data may be provided if you apply for a job opportunity in the Group.|
|Special categories of personal data are racial or ethnic origin, political opinions, sex life, sexual orientation, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying a natural person, or data concerning health||This data is provided by you on our web forms and questionnaires, most regularly in relation to the utilisation of our Health Assured service, EAP service, or is provided when seeking advice and support from our employment advice, employment consultancy, HRFace2Face and legal services.|
We may collect, hold, use and disclose the information collected to compile statistical data and to; maintain our database; develop/improve our website; respond to any email enquiries; notify you of any upcoming marketing, training or other events that you have opted in to; provide you with publications; manage quality control; manage systems administration; attend to compliance issues; provide you or your organisation with advice and determine suitability for employment.
We will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent unless otherwise authorised, required or permitted under the Irish law. The Group does not sell your data to third parties.
If you no longer wish to receive information about our services, please send an email to firstname.lastname@example.org, advising that you do not wish to receive further information.
Will we disclose your data?
Personal data will only be disclosed on a confidential basis to external service providers so that they can provide services such as financial or administrative services in connection with the operation of our business; and to any person (where necessary) in connection with their services, such as law enforcement, regulatory authorities, partners or advisors; or to companies within the Peninsula Group in the EU.
The handling of these operations is governed by a data processing contract between us and our external service provider, ensuring a commitment to the principals of the GDPR and the Data Protection Act 2018. We ensure external service providers are only authorised to use personal data for the limited purposes specified in our agreement with them.
How long we keep your personal data
Personal data from our data subjects is retained in line with our data retention policy. The Group keeps most data for seven years, which covers the six years by law in which we have to keep certain information for a minimum of six years plus the current year. Personal data that is no longer necessary to be kept under the Group’s data retention policy will be deleted. Under the Group’s data retention policy, there are certain exemptions in relation to financial data and health data. A copy of the Group’s data retention policy can be made available upon request.
You have the following rights in relation to personal data held on you by the Group:
- The right to be informed about how personal data is used – (this notice).
- The right to access a copy of personal data that the Group holds about you.
- The right to rectification of any errors in personal data held by the Group.
- The right to erasure of any personal data.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights in relation to automated decision making including profiling.
If you wish to learn more about these rights and how they operate, please look at the DPC’s website https://www.dataprotection.ie.
The Group does not operate any automated decision making systems.
You have a right to request a copy of the personal data that we hold about you. If you would like a copy of some or all of your personal data please email email@example.com. Proof of your identity will be required for security purposes.
If you think your data rights have been breached, you are able to raise a complaint with the Data Protection Commissioner. You can contact the Data Protection Commissioner by post at Canal House, Station Road, Portarlington, R32 AP23 Co. Laois or by telephone on 1890 252 231 (Locall) or +353 57 8684800
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