www.stevenfarrell.ie Data Protection Policy Document
The purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of www.stevenfarrell.ie. This includes obligations in dealing with personal data, in order to ensure that www.stevenfarrell.ie complies with the requirements of the relevant Irish legislation, namely the Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003) and the GDPR Act (2018).
www.stevenfarrell.ie must comply with the Data Protection principles set out in the relevant legislation. This Policy applies to all Personal Data collected, processed and stored by www.stevenfarrell.ie in relation to its clients when they visit and or purchase from www.stevenfarrell.ie in the course of its activities.
The policy covers both personal and sensitive personal data held in relation to data subjects by www.stevenfarrell.ie. The policy applies equally to personal data held in manual and automated form.
All Personal and Sensitive Personal Data will be treated with equal care by www.stevenfarrell.ie. Both categories will be equally referred-to as Personal Data in this policy, unless specifically stated otherwise.
www.stevenfarrell.ie as a Data Controller
www.stevenfarrell.ie stores and processes personal data in accordance with the Irish Data Protection legislation, this data must be acquired and managed fairly.
Upon visiting and while viewing www.stevenfarrell.ie your time zone, IP address and web browser and other information will be automatically collected in the form of Cookies and Log Files.
Upon attempting to or processing an order www.stevenfarrell.ie will collect a certain amount of information which could include your name, billing and or shipping address, credit card information (or other payment method), email address and contact telephone number.
This information will be kept secure by www.stevenfarrell.ie and only shared with our payment processors when relevant and chosen method of postage when relevant.
www.stevenfarrell.ie might also use your contact information to communicate directly with you regarding but not limited to your order.
Subject Access Requests
Any formal, written request by a Data Subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.
It is intended that by complying with these guidelines, www.stevenfarrell.ie will adhere to best practice regarding the applicable Data Protection legislation.
In the course of its role as Data Controller, www.stevenfarrell.ie engages Mailchimp as a third-party Data Processor, this company is fully compliant with the new GDPR Data Regulations and we have contact from them.
The Data Protection Principles
The following key principles are enshrined in the Irish legislation and are fundamental to the Data Protection policy of www.stevenfarrell.ie.
In its capacity as Data Controller, www.stevenfarrell.ie ensures that all data shall:
… be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
The identity of the Data Controller (www.stevenfarrell.ie)
The purpose(s) for which the data is being collected
The person(s) to whom the data may be disclosed by the Data Controller
Any other information that is necessary so that the processing may be fair.
www.stevenfarrell.ie will meet this obligation in the following way.
Where possible, the informed consent of the Data Subject will be sought before their data is processed;
Where it is not possible to seek consent, www.stevenfarrell.ie will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
The Data Subject’s data will not be disclosed to a third party other than to a party contracted to www.stevenfarrell.ie and operating on its behalf.
…. be obtained only for one or more specified, legitimate purposes.
www.stevenfarrell.ie will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which www.stevenfarrell.ie holds their data, and www.stevenfarrell.ie will be able to clearly state that purpose or purposes.
www.stevenfarrell.ie processes personal data for the following purpose(s)*: *(this is a non-exhaustive list)
Direct Marketing and or order updates
Provision of goods or services
Your data is processed only in cases where one or more of the following legal bases applies:
Performance of a contract including possible consequences of failing to provide the personal data
Legal obligation, including possible consequences of failing to provide the personal data
To protect the vital interests of the data subject
Performance of a task carried out in the public interest
….. not be further processed in a manner incompatible with the specified purpose(s).
…. be kept safe and secure at all times.
The www.stevenfarrell.ie will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by www.stevenfarrell.ie in its capacity as Data Controller.
Access to and management of staff and customer records is limited to those staff members who have appropriate authorisation and password access.
… be kept accurate, complete and up-to-date where necessary.
ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
conduct regular assessments in order to establish the need to keep certain Personal Data.
… be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
www.stevenfarrell.ie will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
… not be kept for longer than is necessary to satisfy the specified purpose(s).
www.stevenfarrell.ie has identified an appropriate data retention period for personal data, based on the period required for retention of financial records, due to the use of registration information in our annual voluntary audit process. This retention period applies to data in both a manual and automated format.
Once the respective retention period has elapsed, www.stevenfarrell.ie undertakes to destroy, erase or otherwise put this data beyond use.
… be managed and stored in such a manner that, in the event a Data Subject submits a valid Subject Access Request seeking a copy of their Personal Data, this data can be readily retrieved and provided to them.
www.stevenfarrell.ie has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.
This includes both automated and manual data.
Automated data means data held on computer, or stored with the intention that it is processed on computer.
Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.
Information which relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, www.stevenfarrell.ie refers to the definition issued by the Article 29 Working Party, and updated from time to time.)
Sensitive Personal Data
A particular category of Personal data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s Sexual Orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.
A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.
A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.
A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.
Data Protection Officer
A person appointed by www.stevenfarrell.ie to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to Data Protection queries from staff members and service recipients
Relevant Filing System
Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals, or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.