Introduction
This is the Privacy Policy of The Paddy McGrath Housing Project of Talbot House, Granby Lane, Dublin 1 (hereby referred to as “us”, “we” and “the charity”). The purpose of this Privacy Policy is to ensure that individuals understand how we use or process their information.
The Paddy McGrath Housing Project endeavours to comply with the General Data Protection Regulation, Data Protection Acts, ePrivacy Regulation and data protection best practices. This Policy informs individuals how The Paddy McGrath Housing Project processes personal data in accordance with the principles of data protection identified in data protection legislation.
We will process any personal information provided to us by individuals, whether it be provided through our website (www.mcgrathhousing.ie), in person, by any form, correspondence, telephone, email or by any other means, or otherwise held by us in relation to you in the manner set out in this policy.
By submitting your information to us and or by using our website you confirm your consent to the use of your personal information as set out by this Privacy Policy. If you do not agree with the terms of this Privacy Policy please do not use our website or provide us with any personal information.
The Paddy McGrath Housing Project is a registered charity that provides a wide range of services to its members, residents and the general public at large. We employee a number of staff and also at times rely on volunteers; both employees and volunteers have an internal Data Protection Policy that governs how they process data.
Information collected by us
The information about you that we may collect, use and store (process) includes:
Information necessary in order to facilitate, process, deliver or that relates to the billing of an agreed business transaction, fundraising, payment or collection of monies or any transaction associated with membership or residency of The Paddy McGrath Housing Project (name, address, contact details, billing details, etc.).
Information you provide to us by filling out any forms on the website or by way of emailing us.
Records of correspondences whether by email, telephone, through any form on our website or by any other means.
Information you provide to us in person.
Details of any business, commercial or membership transactions you carry out with us, whether through email, the website, telephone, or by any other means.
Details of your visits to our website including traffic data, location data, weblogs and other communication data in accordance with our Cookie Policy [
https://mcgrathhousing.ie/about/more/cookie-policy.html ] that may identify personal information (e.g. cookies) and non-personal information (e.g. information of an anonymised or technical nature)
How we use your personal information
We may use your personal information for the purposes of:
Processing any enquiry requested by you;
Providing any support services requested by you;
Entering into and or completing any sales or membership related request requested by you;
Setting up, operating and managing any account or line of credit, if applicable;
Setting up, operating and managing any marketing and or fundraising services subject to your explicit consent (please see Marketing & Fundraising below);
Complying with our legal duties and responsibilities;
Debt collection and the collection of outstanding monies;
Providing, monitoring, reviewing and supporting our online presence via our website and social media (please see our Cookie Policy [
https://mcgrathhousing.ie/about/more/cookie-policy.html ])
Monitoring any billing or credit transactions for the purpose of preventing fraud;
Provision of security to, and ensuring the health and safety of, employees, volunteers and visitors to company premises.
Special categories of personal data
The Paddy McGrath Housing Project is a registered charity that provides support to those affected by homelessness, long term illnesses and criminality. Sometimes people are referred to us by the Health Service Executive, Dublin City Council and other registered charities and or support services.
In order to provide support, we receive some high-level special categories of personal data from these organizations, e.g. a summary or overview of a person’s health, disability or illness status, criminal record, financial support or social welfare payments, etc.) in accordance with each organisations Privacy Policy and their legal grounds of processing such special categories of personal data. For example, these organisations may have received consent form the individual to share their data to us so we may provide support. Such data is generally limited to a person’s health status, disability or illness status, criminal record, financial support or social welfare payments In such cases, the data will only be used for the purposes of establishing whether we are able to provide an individual with support, and in such cases, how we may make contact with the person to provide that support. We do not use such data for any other purposes and it is then deleted or destroyed in accordance with our data retention policy.
In cases where we make contact with a person and they decline our offer of assistance then we delete or destroy the data in accordance with our data retention policy.
In cases where we make contact with a person and they accept our offer of assistance then we arrange to meet with them to establish what types of support we can offer and what would be suitable in their circumstances. In such cases we ask for consent in writing, and only when it is provided, we process more in-depth special categories of personal data to establish the person’s suitability and any associated risk factors for the provision of support. Such data is generally limited to a person’s health, disability or illness status, criminal record, financial support or social welfare payments, medical history and current medication and are used only for the purposes of providing ongoing support.
As stated, we will process special categories of personal data with the explicit consent of any individual that we request in writing (via a consent form) and the data will be held as confidential, secure, will be used only for the purposes for which it was collected and will be destroyed or deleted once is it no longer necessary (in accordance with our data retention policy).
General
The Paddy McGrath Housing Project does not engage in any automated decision making processes nor do we use any personal data as a basis for any such automated decisions.
The Paddy McGrath Housing Project does not transfer personal data outside the EU or outside the jurisdiction of GDPR or ePrivacy Regulation.
Marketing & Fundraising
The Paddy McGrath Housing Project is a registered charity that relies on State funding to provide our support services. We do not engage in direct marketing with the general public nor do we keep a database for fundraising or advertising purposes.
In terms of data processing, subject to your explicit consent, we may also use your personal information for the purposes of:
Marketing (newsletter, e-zine, updates, etc.)
Providing you with information about ourselves as a charitable organisation.
Providing you with information about our support services.
Carrying out any research or survey that may affect our charitable aims and objectives.
Advocacy and or public awareness of any issue in accordance with our charitable aims and objectives.
At some interactions with The Paddy McGrath Housing Project you may be asked to consent to your data being used for marketing purposes. In such cases, consent will require a positive action on your part. For example, on a new membership form you would have to tick a box stating that you consent to your data being processed for marketing and or fundraising purposes.
The Paddy McGrath Housing Project is committed to privacy by design and privacy by default. As such, you will never have to ‘opt-out’ of our marketing or fundraising processes; you will only ever have the option of ‘opting in’ if you’d like to be included. We do not engage in ‘pre-ticked’ boxes on consent forms nor do we ever assume you would consent to your data being processed. You are free to withdraw consent for any marketing and or fundraising related matters at any time you want.
Social media
The Paddy McGrath Housing Project does not currently engage with social media but we may consider doing so in the future. In such an event, any use of social media cookies or widgets would be governed by our Cookie Policy [ https://mcgrathhousing.ie/about/more/cookie-policy.html ].
Information Storage
We will take reasonable steps to ensure that your information is kept secure and protected, including but not limited to electronic data being protected using appropriate software, relevant networks safety and security checks, and, any computers or devices that can access data are encrypted. We do store some personal data in physical forms and they are kept in an appropriately secure environment.
We have a general data retention policy that relates to the retention of relevant data for seven years. Personal data that is no longer required will be destroyed and or deleted in secure manner.
We do not record or process personal data, including special categories of personal data that is not required or not necessary for any of our stated purposes or for the aims and objectives of the charity.
Disclosure of data
We may outsource certain managerial or operational functions to external third parties, e.g. accounting auditors, bookkeeping, etc. and in such cases where your personal data is required for the purposes of completing those functions then an appropriate data processing agreement, with relevant safeguards, will be in place to ensure our ongoing obligations under the Data Protection Acts are upheld.
We may also have to disclose certain personal data in accordance with any legal obligation imposed on us. Any such disclosure would be in accordance with the law, e.g. disclosed on foot of a court order, etc.
Requesting your data
Any person has the right to find out whether an organisation has any personal data about them, what they use the personal data for and ask for copies of personal information held by that organisation.
If you wish to make a data access request in order to get a copy of any personal data we may process, please write a letter stating that you wish to make a data access request and address it to:
Don O’Higgins
Chief Executive Officer
The Paddy McGrath Housing Project
Talbot House
Granby Lane
Dublin 1
Or email Don O’Higgins at don@mcgrathhousing.ie.
In order to process your request we may request that you send us a copy of your identification (passport, drivers licence, etc.). The reason we may ask for personal identification is to ensure that you are the correct person making the request for your personal data.
Unfortunately, verbal data access requests cannot be entertained.
In response to any data access request, you have the right to refer the matter to the Data Protection Commissioner if you are unhappy with the outcome, however, we ask that you would notify us first of any issue so that we may help resolve it as quickly as possible.
Rectifying mistakes
You have the right to rectify any incorrect or inaccurate personal data at no cost to you.
If you believe that we are incorrectly processing any of your personal data, please inform us by writing to Don O’Higgins, CEO at the above address or email don@mcgrathhousing.ie.
Queries or complaints
If you have any queries or complaints regarding our Privacy Policy or any data protection matter, please let us know by writing to the above person or email us at don@mcgrathhousing.ie.
Individuals have the right to refer any matter to the Data Protection Commissioner by contacting them at www.dataprotection.ie or by writing to:
Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House
Station Road
Portdarlington
Co. Laois
If you are, for whatever reason, considering contacting the Data Protection Commissioner about us we would ask that you inform us of your difficulty first so that we can try to resolve it to your satisfaction.
Changes to our Privacy Policy
Any changes we may make to our Privacy Policy in the future will be posted on our website.
Any changes will become effective upon posting the revised Privacy Policy on our website. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email, notice on our website or any other agreed communications channels.
Privacy Policy last reviewed: April 2018
