Aislinn Events Privacy and Data Protection Policy
This Privacy and Data collection Policy governs the manner in which AISLINN EVENTS collects, uses, maintains and discloses information collected from users (each, a “User”) of the Aislinn Events.com website (“Site”) and the Elope to Ireland website. This Privacy and Data collection applies to the Site and all products and services offered by AISLINN EVENTS and ensure that the organisation complies with the requirements of the relevant Irish legislation.
Aislinn Events 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 Aislinn Events in relation to its staff, service providers, and clients in the course of its activities. Aislinn Events makes no distinction between the rights of Data Subjects who are employees and those who are not. All are treated equally under this Policy.
The policy covers both personal and sensitive personal data held in relation to data subjects by Aislinn Events. 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 Aislinn Events. Both categories will be equally referred-to as Personal Data in this policy unless specifically stated otherwise.
This policy should be read in conjunction with the associated Subject Access Request procedure, the Data Retention and Destruction Policy, the Data Retention Periods List and the Data Loss Notification procedure.
Aislinn Events as a Data Controller
In the course of its daily organizational activities, Aislinn Events acquires, processes and stores personal data in relation to:
- Employees of Aislinn Events
- Customers of Aislinn Events
- Third-party service providers engaged by Aislinn Events
In accordance with the Irish Data Protection legislation, this data must be acquired and managed fairly. Not all staff members will be expected to be experts in Data Protection legislation. However, Aislinn Events is committed to ensuring that their staffs has sufficient awareness of the legislation in order to be able to anticipate and identify a Data Protection issue, should one arise. In such circumstances, staff must ensure that the Data Protection Officer is informed, and in order that appropriate corrective action is taken.
Due to the nature of the services provided by Aislinn Events, there is a regular and active exchange of personal data between Aislinn Events and its Data Subjects. In addition, Aislinn Events exchanges personal data with Data Processors on the Data Subjects’ behalf.
This is consistent with Aislinn Event’s obligations under the terms of its contract with its Data Processors.
This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that an Aislinn Event staff member is unsure whether such data can be disclosed.
In general terms, the staff member should consult with the Data Protection Officer to seek clarification.
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, Aislinn Events will adhere to best practice regarding the applicable Data Protection legislation.
In the course of its role as Data Controller, Aislinn Events engages a number of Data Processors to process Personal Data on its behalf. In each case, a formal, written contract is in place with the Processor, outlining their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Irish Data Protection legislation.
The Data Protection Principles
The following key principles are enshrined in the Irish legislation and are fundamental to the Aislinn Event’s Data Protection policy.
In its capacity as Data Controller, Aislinn Events 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 Aislinn Events
- 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.
Aislinn Events 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, Aislinn Events will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
- Processing of the personal data will be carried out only as part of Aislinn Events’s lawful activities, and Aislinn Events will safeguard the rights and freedoms of the Data Subject;
- The Data Subject’s data will not be disclosed to a third party other than to a party contracted to Aislinn Events and operating on its behalf.
- …. be obtained only for one or more specified, legitimate purposes.
Aislinn Events 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 Aislinn Events holds their data, and Aislinn Events will be able to clearly state that purpose or purposes.
- ….. not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by Aislinn Events will be compatible with the purposes for which the data was acquired.
- …. be kept safe and secure.
Aislinn Events 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 unauthorized access to, or alteration, destruction or disclosure of any personal data held by Aislinn Events in its capacity as Data Controller.
Access to and management of staff and customer records is limited to those staff members who have appropriate authorization and password access.
- … be kept accurate, complete and up-to-date where necessary.
Aislinn Events will:
- ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
- conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. Aislinn Events conducts a review of sample data every six months to ensure accuracy; Staff contact details and details on next-of-kin are reviewed and updated every two years.
- 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.
Aislinn Events 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).
Aislinn Events has identified an extensive matrix of data categories, with reference to the appropriate data retention period for each category. The matrix applies to data in both a manual and automated format.
Once the respective retention period has elapsed, Aislinn Events 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.
Aislinn Events 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.
Data Subject Access Requests
As part of the day-to-day operation of the organisation, Aislinn Event’s staff engage in active and regular exchanges of information with Data Subjects. Where a formal request is submitted by a Data Subject in relation to the data held by Aislinn Events, such a request gives rise to access rights in favour of the Data Subject.
There are specific time-lines within which Aislinn Events must respond to the Data Subject, depending on the nature and extent of the request. These are outlined in the attached Subject Access Request process document.
Aislinn Event’s staff will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request.
As a Data Controller, Aislinn Events ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation.
Failure of a Data Processor to manage Aislinn Event’s data in a compliant manner will be viewed as a breach of contract, and will be pursued through the courts.
Failure of Aislinn Event’s staff to process Personal Data in compliance with this policy may result in disciplinary proceedings.
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
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How we use collected information
AISLINN EVENTS may collect and use Users personal information for the following purposes:
- To improve customer serviceThe information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize user experience-We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
- To improve our SiteWe may use feedback you provide to improve our products and services.
- To run a promotion, contest, survey or other Site featureTo send Users information they agreed to receive about topics we think will be of interest to them.
To send periodic emails.
We may use the email address to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Our Site is in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Compliance with children’s online privacy protection act
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
This document was last updated on 25/5/2018