Data Protection Policy
1           PURPOSE 
The purpose of our Data Protection and Privacy Policy is to outline how we deal with any personal data you provide to us while visiting our website and throughout the course of various interactions pre, post and during your membership with County Tipperary Chamber of Commerce. By joining County Tipperary Chamber of Commerce and/or by visiting this website, you are accepting the terms of this Data Protection and Privacy Policy. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites. Naturally, if you are not happy with this policy you should not use this website and you should inform the Member Relations Team at County Tipperary Chamber of Commerce immediately, as this may affect how the Chamber interacts with you as an individual and a member. This policy establishes an effective, accountable and transparent framework for ensuring compliance with the requirements of the GDPR.
 
2           SCOPE 
This policy applies to all County Tipperary Chamber of Commerce Volunteers, employees and all third parties responsible for the processing of personal data on behalf of County Tipperary Chamber of Commerce.
 
3           POLICY STATEMENT 
County Tipperary Chamber of Commerce respect your right to privacy and will not collect any personal information about you on this website without your clear permission. Any personal data that you volunteer to County Tipperary Chamber of Commerce, if retained, will be held on secure servers and will only be used to better our service offering.
County Tipperary Chamber of Commerce is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.
This policy sets forth the expected behaviours of County Tipperary Chamber of Commerce employees, volunteers and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to a County Tipperary Chamber of Commerce member (i.e. the data subject).
 

3.1. Governance 
3.1.1.     Data Protection OfficerTo demonstrate our commitment to data protection, and to enhance the effectiveness of our compliance efforts, County Tipperary Chamber of Commerce has appointed a Data Protection Officer. The Data Protection Officer operates with independence and is supported by suitability skilled individuals granted all necessary authority. The Data Protection Officer reports to County Tipperary Chambers Board of Directors. The Data Protection Officer’s duties include:

• Informing and advising County Tipperary Chamber of Commerce and its volunteers and employees who carry out processing pursuant to data protection regulations, national law or European Union based data protection provisions;
• Ensuring the alignment of this policy with data protection regulations, national law or European Union based data protection provisions;
• Providing guidance with regards to carrying out Data Protection Impact Assessments (DPIAs);
• Acting as a point of contact for and cooperating with Data Protection Authorities (DPAs);
• Determining the need for notifications to the Data Protection Commission as a result of County Tipperary Chamber’s current or intended personal data processing activities;
• Making and keeping current notifications to the Data Protection Commission as a result of County Tipperary Chamber’s current or intended personal data processing activities;
• The establishment and operation of a system providing prompt and appropriate responses to data subject requests;
• Informing directors of County Tipperary Chamber’s of any potential corporate, civil and criminal penalties which may be levied against County Tipperary Chamber’s and/or its employees for violation of applicable data protection laws.

Ensuring establishment of procedures and standard contractual provisions for obtaining compliance with this Policy by any third party who:

• provides personal data to County Tipperary Chamber’s;
• receives personal data from County Tipperary Chamber’s;
• has access to personal data collected or processed by County Tipperary Chamber’s.

3.1.2.     Data Protection by Design

To ensure that all data protection requirements are identified and addressed when designing new systems or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing. County Tipperary Chamber’s must ensure that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Data Protection Officer, for all new and/or revised systems or processes for which it has responsibility. The subsequent findings of the DPIA must then be submitted to the CEO for review and approval. Where applicable, the Information Technology (IT) department, as part of its IT system and application design review process, will cooperate with the Data Protection Officer to assess the impact of any new technology uses on the security of personal data.

3.1.3.     Compliance MonitoringTo confirm that an adequate level of compliance that is being achieved by County Tipperary Chamber’s in relation to this policy, the Data Protection Officer will carry out an annual data protection compliance. Each audit will, as a minimum, assess:

• Compliance with policy in relation to the protection of personal data, including:
• The assignment of responsibilities.
• Raising awareness.
• Training of employees.
• The effectiveness of data protection related operational practices, including:
• Data subject rights.
• Personal data transfers.
• Personal data incident management.
• Personal data complaints handling.
• The level of understanding of data protection policies and privacy notices.
• The currency of data protection policies and privacy notices.
• The accuracy of personal data being stored.
• The conformity of data processor activities.
• The adequacy of procedures for redressing poor compliance and personal data breaches. The Data Protection Officer, in cooperation with key business stakeholders from County Tipperary Chamber’s, will devise a plan with a schedule for correcting any identified deficiencies within a defined and reasonable time frame. Any major deficiencies and good practice identified will be reported to, monitored and shared by the County Tipperary Chamber’s board of Directors.

3.2. Data Protection Principles
County Tipperary Chamber’s has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of personal data:
Principle 1: Lawfulness, Fairness and Transparency. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. This means, County Tipperary Chamber’s must tell the data subject what processing will occur (transparency), the processing must match the description given to the data subject (fairness), and it must be for one of the purposes specified in the applicable data protection regulation (lawfulness).
Principle 2: Purpose Limitation. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. This means County Tipperary Chamber’s must specify exactly what the personal data collected will be used for and limit the processing of that personal data to only what is necessary to meet the specified purpose.
Principle 3: Data Minimisation. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This means County Tipperary Chamber’s must not store any personal data beyond what is strictly required.
Principle 4: Accuracy. Personal data shall be accurate and, kept up to date. This means County Tipperary Chamber’s must have in place processes for identifying and addressing out-of-date, incorrect and redundant personal data.
Principle 5: Storage Limitation. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. This means County Tipperary Chamber’s must, wherever possible, store personal data in a way that limits or prevents identification of the data subject.
Principle 6: Integrity & Confidentiality. Personal data shall be 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. County Tipperary Chamber’s must use appropriate technical and organisational measures to ensure the integrity and confidentiality of personal data is maintained at all times.
Principle 7: Accountability. The Data Controller shall be responsible for and be able to demonstrate compliance. This means County Tipperary Chamber’s must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible.

3.3.    Data collection
3.3.1.     Data Sources
Personal data should be collected only from the data subject unless one of the following apply:

• The nature of the business purpose necessitates collection of the personal data from other persons or bodies.
• The collection must be carried out under emergency circumstances in order to protect the vital interests of the data subject or to prevent serious loss or injury to another person.

If personal data is collected from someone other than the data subject, the data subject must be informed of the collection unless one of the following apply:

• The data subject has received the required information by other means.
• The information must remain confidential due to a professional secrecy obligation
• A national law expressly provides for the collection, processing or transfer of the personal data.

Where it has been determined that notification to a data subject is required, notification should occur promptly, but in no case later than:

• One calendar month from the first collection or recording of the personal data
• At the time of first communication if used for communication with the data subject
• At the time of disclosure if disclosed to another recipient.

3.3.2.     Data subject consentCounty Tipperary Chamber’s will obtain personal data only by lawful and fair means and, where appropriate with the knowledge and consent of the individual concerned. Where a need exists to request and receive the consent of an individual prior to the collection, use or disclosure of their personal data, County Tipperary Chamber’s is committed to seeking such consent. The Data Protection Officer, in cooperation with other relevant business representatives, shall establish a system for obtaining and documenting data subject consent for the collection, processing, and/or transfer of their personal data.

3.3.3.     Data subject NotificationCounty Tipperary Chamber’s will, when required by applicable law, contract, or where it considers that it is reasonably appropriate to do so, provide data subjects with information as to the purpose of the processing of their personal data. When the data subject is asked to give consent to the processing of personal data and when any personal data is collected from the data subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:

• The data subject already has the information;
• A legal exemption applies to the requirements for disclosure and/or consent. The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Data Protection Officer. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

3.3.4.     External Privacy NoticesEach external website provided by County Tipperary Chamber’s will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.

3.4. Data Use
3.4.1.     Data processing
CountyTipperary Chamber’s uses the personal data of its contacts for the following broad purposes:

• The general running and business administration of County Tipperary Chamber’s;
• To provide services to County Tipperary Chamber’s member.
• The ongoing administration and management of customer services.

County Tipperary Chamber’s will process personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, CountyTipperary Chamber’s will not process personal data unless at least one of the following requirements are met:

• The data subject has given consent to the processing of their personal data for one or more specific purposes.
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
• Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
• Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, in particular where the data subject is a child).

3.4.2.     Special Categories of DataCounty Tipperary Chamber’s will only process special categories of data (also known as sensitive data) where the data subject expressly consents to such processing or where one of the following conditions apply:

• The processing relates to personal data which has already been made public by the data subject.
• The processing is necessary for the establishment, exercise or defence of legal claims.
• The processing is specifically authorised or required by law.
• The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.
• Further conditions, including limitations, based upon national law related to the processing of genetic data, biometric data or data concerning health.

In any situation where special categories of data are to be processed, prior approval must be obtained from the Data Protection Officer, and the basis for the processing clearly recorded with the personal data in question. Where special categories of data are being processed, County Tipperary Chamber’s will adopt additional protection measures.

3.4.3.     Data Quality
County Tipperary Chamber’s will adopt all necessary measures to ensure that the personal data it collects and processes is complete and accurate in the first instance, and is updated to reflect the current situation of the data subject. The measures adopted by Tipperary Chamber’s to ensure data quality include:

• Correcting personal data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the data subject does not request rectification.
• Keeping personal data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.
• The removal of personal data if in violation of any of the data protection principles or if the personal data is no longer required.
• Restriction, rather than deletion of personal data, insofar as:
  • a law prohibits erasure.
  • erasure would impair legitimate interests of the data subject.
  • the data subject disputes that their personal data is correct, and it cannot be clearly ascertained whether their information is correct or incorrect.

3.4.4.     Digital Marketing
As a general rule County Tipperary Chamber’s will not send promotional or direct marketing material to a member Contact through digital channels such as mobile phones, email and the Internet, without first obtaining their consent.

3.5. Data Retention
To ensure fair processing, personal data will not be retained by County Tipperary Chamber’s for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed. The length of time for which County Tipperary Chamber’s need to retain personal data is set out in County Tipperary Chamber’s ‘Data Retention Policy’. This takes into account the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All personal data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.

3.6. Data Protection
County Tipperary Chamber’s will adopt physical, technical, and organisational measures to ensure the security of personal data. This includes the prevention of loss or damage, unauthorised alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. A summary of the personal data related security measures is provided below:

• Prevent unauthorised persons from gaining access to data processing systems in which personal data are processed.
• Prevent persons entitled to use a data processing system from accessing personal data beyond their needs and authorisations.
• Ensure that personal data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.
• Ensure that access logs are in place to establish whether, and by whom, the personal data was entered into, modified on or removed from a data processing system.
• Ensure that in the case where processing is carried out by a Data Processor, the data can be processed only in accordance with the instructions of the Data Controller.
• Ensure that personal data is protected against undesired destruction or loss.
• Ensure that personal data collected for different purposes can and is processed separately.
• Ensure that personal data is not kept longer than necessary

3.7. Data subject Requests
The Data Protection Officer will establish a system to enable and facilitate the exercise of data subject rights related to:

• Information access.
• Objection to processing.
• Objection to automated decision-making and profiling.
• Restriction of processing.
• Data portability.
• Data rectification.
• Data erasure. If an individual makes a request relating to any of the rights listed above

County Tipperary Chamber’s will consider each such request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. Data subjects are entitled to obtain, based upon a request made in writing/email to: kmclaughlin@idpaa.eu
 
 
3.8. Data Protection Training
County Tipperary Chamber’s will provide regular Data Protection training and procedural guidance for their staff and volunteers.

3.9. Data Transfers
County Tipperary Chamber’s may transfer personal data to internal or third-party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant data subjects. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. third countries), they must be made in compliance with an approved transfer mechanism. County Tipperary Chamber’s may only transfer personal data where one of the transfer scenarios list below applies:

• The data subject has given Consent to the proposed transfer.
• The transfer is necessary for the performance of a contract with the data subject
• The transfer is necessary for the implementation of pre-contractual measures taken in response to the data subject’s request.
• The transfer is necessary for the conclusion or performance of a contract concluded with a third party in the interest of the data subject.
• The transfer is legally required on important public interest grounds.
• The transfer is necessary for the establishment, exercise or defence of legal claims.
• The transfer is necessary in order to protect the vital interests of the data subject

 
3.10.              Complaints handling
Data subjects with a complaint about the processing of their personal data, should put forward the matter in writing to the Data Protection Officer. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Data Protection Officer will inform the data subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the data subject and the Data Protection Officer, then the data subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.

3.11.              Breach Reporting
Any individual who suspects that a personal data breach has occurred due to the theft or exposure of personal data must immediately notify the Data Protection Officer providing a description of what occurred. Notification of the incident can be made via e-mail, by calling, or by using the independent whistleblowing line: 0872681891 The Data Protection Officer will investigate all reported incidents to confirm whether or not a personal data breach has occurred. If a personal data breach is confirmed, the Data Protection Officer will follow the relevant authorised procedure based on the criticality and quantity of the personal data involved. For severe personal data breaches, County Tipperary Chamber’s Board of Directors will initiate and chair an emergency response team to coordinate and manage the personal data breach response.
 
4           REVIEW
This policy will be reviewed by the Data Protection Officer every three years, unless there are any changes to regulations or legislation that would enable a review earlier.

5           RECORDS MANAGEMENT
Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised Tipperary Chamber’s recordkeeping system.
All records relevant to administering this policy and procedure will be maintained for a period of 5 years.
 
6           APPROVAL AND REVIEW DETAILS
 
Approval and Review                                         Details
Approval Authority                                             Board of Management
Data Protection Officer                                    Kevin McLaughlin
 Next Review Date                                               21/3/2021
 
Approval and Amendment History          Details

Original Approval Authority and Date:    Board of Management 21/3/2108