Privacy Statement

27.1 Who we are

Mosney Village’s Privacy Statement refers to our commitment to our compliance to data protection legislation including the Irish Data Protection Acts and the EU General Data Protection Regulation.

 

Throughout this document “we”, “us”, “contractor”, “our” and “ours” refers to

Mosney Village. Our registered address is Mosney Village, Julianstown, Co. Meath, A92 ED6V.

 

For the purposes of the Data Protection Laws the Contracting Authority is the Data Controller and the Contractor is the Data Processor in respect of Data which is Personal Data processed by the Contractor in the provision of the Services.

 

27.2 The information we collect about you

We collect and process your personal data in the course of business to provide a service to you. This personal data includes any offline physical data or online data that makes a person identifiable.

 

We process data for the following groups of individuals (current and former)

  • Residents

  • Staff Members

  • Service Users

  • Job Candidates

  • Sales Leads

  • Customers

  • Contractors

  • Outsourced Service Providers whose personal data is processed by us

  • Other Parties whose personal data is processed by us

 

We are the controller for the personal information we process, unless otherwise stated.

 

27.3 Legal Basis for processing your data

We collect your data based on the following legal basis:

 

Consent

Where you have explicitly agreed to us processing your information for a specific reason such as collecting your data for example explicit consent for us to  process any special category of data about you.

 

Where consent is relied upon as a basis for processing of any personal data, you will be presented with an option to agree or disagree with the collection, use or disclosure of personal data. Once consent is obtained, it can be withdrawn at any stage.

 

Contract

Where you have entered into a service with us and the processing is necessary to perform this service

 

Compliance

The processing is necessary for compliance with a legal obligation we have such as keeping records for revenue or tax purposes or providing information to a public body or law enforcement agency; we may

be required to process certain data to carry out our obligations under employment, social security or social protection law; the processing is necessary for the establishment, exercise or defence of legal claims.

 

Legitimate interest

Processing is necessary for the purposes of a legitimate interest pursued by us to safeguard the safety and security of our employees, property, and clients, buildings, information located or stored on the premises, and assets, and those of service providers, consultants, and advisors that assist us in carrying out its functions. To prevent fraud, to inform recruitment decisions taken about appointments and new hires. To operate our business generally and manage and administer our services to clients, suppliers and potential candidates and to enhance our service delivery.

 

As part of our marketing activities such as emails sent to residents via the Resident’s Mailing List, a withdrawal option will be  provided in all marking communication thereafter and you may opt out at any stage.

 

From time to time we may conduct customer satisfaction surveys. Where we do so we rely on the lawful processing of legitimate interest to enhance our service delivery. When completing your sales contract, under the data protection section, you will be presented with an option to opt out of such surveys. A withdrawal option will be provided in all survey communication thereafter.

 

 

27.4 When and how we collect information about you

You directly provide us with most of the data we collect. We collect data and process data when you:

  • Register online or place an order for any of our products or services, activities or events

  • Voluntarily complete a customer survey or provide feedback on any of our message boards or via email

  • Use or view our website via your browser’s cookies

  • Apply for employment

  • Apply or provide a quote for product or service

  • Engage in a contract

 

As part of our services, we need to obtain and process personal data as required where necessary to provide our services such as:

 

Types of Personal Data (i.e. any information relating to an identified or identifiable person)

Demographic Data

[e.g. name, date of birth, age,]

Contact Details

[e.g. home/work landline phone number, personal/work mobile, home/work postal address, personal/work email address]

Financial Data

[e.g. bank account number, credit card number]

Digital Identifiers

[e.g. IP Address, MAC Address, X/Y Geographic Coordinate, meta data, cookie identifier, radio frequency identification (RFID) tags, advertising IDs, pixel tags, account handles, device fingerprints, browsing history]

 

Social Media

[e.g. Twitter Account, URL Facebook, URL LinkedIn, URL Pinterest, URL Instagram]

Special Categories Data

[e.g. data relating to racial or ethnic origin, political, religious or, philosophical beliefs, trade union membership, health, sexual life or orientation, genetic or biometric data,]

Criminal Offences/Convictions

 

Government Identifiers

[e.g. passport number, personal public service number, driver's licence, income tax number]

Performance

Performance management

Opinions and Assessments

(Opinions and assessments collected in the course of operational tasks)

Other

(Car registration number, policy number, account number, claim reference number, unique reference number of a combination of specific criteria e.g. age, occupation, place of residence)

Any other types of data not listed above

 

 

We may also receive your data indirectly from the following sources:

  • third party  data controllers;

  • publicly available sources;

  • data brokers;

  • other data subjects.

 

Mosney Village as a processor

 

Where you, as a Data Controller, engage the services of us, we will act as Data Processors on your behalf. In doing so, we will: -

  • Only process personal data under the Contract in accordance with your reasonable written instructions and in accordance with applicable Data Protection Legislation

  • Adopt appropriate technical and organisational measures against accidental disclosure, loss or destruction of personal data

  • Inform you promptly in the event of unauthorised disclosure, loss or destruction of any personal data processed on your behalf

  • Refer to you any requests, notices or other communication from data subjects, the Office of the Data Protection Commissioner or any other law enforcement agency relating to personal data processed on your behalf

  • Ensure that all our personnel processing personal data are under an obligation of confidentiality

  • Make available reasonable information necessary to demonstrate compliance with our Data Protection Obligations

  • Make available such information and assistance as is reasonably necessary for you to comply with your obligations to respond to requests for exercising the data subject’s rights, to report personal data breaches and to conduct Data Protection Impact Assessments and Prior Consultation with Data Protection Authorities

  • Comply with our obligations to you in respect of sub-processing and Third Country Transfers.

 

  • Delete or return all personal data processed on your behalf where there is no legal basis for use to retain this data, upon the termination of any services provided by us to you

 

27.5 Protecting your data

We collect this data in a transparent way and only with the full knowledge of interested parties. Once this information is available to us, the following rules apply.

 

Our data will be:

  • Accurate and kept up-to-date

  • Collected fairly and for lawful purposes only

  • Processed by us on the basis of either a valid contract, consent, legal compliance or legitimate interest

  • Protected against any unauthorised access or illegal processing by internal or external parties.

 

Our data will not be:

  • Communicated to any unauthorised internal or external parties

  • Stored for longer than required for the purpose obtained

  • Transferred to organisations, states or countries outside the European Economic Area without adequate safeguards being put in place as required under Data Protection Law.

 

Our commitment to protect your data:

  • Restrict and monitor access to sensitive data

  • Develop transparent data collection procedures

  • Train employees in data protection and security measures

  • Build secure networks to protect online data from cyberattacks

  • Establish clear procedures for reporting privacy breaches or data misuse

  • Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorisation etc.).

 

27.6 Purpose for processing your data

You agree that any data you provide to us will be true, complete and accurate in all respects and you agree to notify us immediately of any changes to it. We will only collect personal information from or about you which is necessary for the following purposes:

 

General

  • To provide this website to you and respond to your queries

  • To comply with all relevant law

  • To manage your safety and security while you are on our premises

  • To facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders

  • To investigate, exercise or defend legal claims or other claims of a similar nature.

 

Residents

  • To provide a quality service to you during your stay at Mosney Village

  • To maintain our relationship with you whilst you are a resident and investigate any complaints or disputes or accidents

  • Contact you for direct marketing purposes, for example via the Resident’s Mailing List, subject to restrictions under the relevant laws, including the right to opt out of such marketing

 

  • Provide you with information relating to our services

  • To provide essential communication with you, including to respond to information requests

      submitted

  • To obtain your feedback on our products and services

  • To notify you about changes to contracted services relevant to you

 

Outsourced service providers

  • Set up, avail of your services, contact you and administer our account as a customer with us

 

Candidates for Jobs

  • To select suitable candidates for employment with us

 

 

27.7 How we use your information for Marketing

As part of our marketing activities, we would like to send you information about services and supports available within Mosney Village and in the local community that we think you might like, as well as those of the ‘Friends of Mosney Village’

 

  • An updated list of the ‘Friends of Mosney Village’ is available here on our website: www.mosneyvillage.ie

 

You have the right at any time to stop us, opt out, from contacting you for marketing purposes

 

27.8 Who we share your information with

Your personal information may also be processed by other organisations on our behalf for the purposes outlined above. We may disclose your information where necessary to the following Contracting Authority within a Government Department, Revenue, HSE, Social Welfare, Data Protection Commission, outsourced Employment Law advisors, pension brokers & trustees, legal advisors, business advisors, financial and leasing institutions, law enforcement, An Garda Síochána, Volunteer Agencies, debt collectors, IT providers, couriers, shredding company, security company, printing company, CCTV company, administration services, accountant/auditors, insurers, recruitment agents, marketing consultants or subcontractors and to possible successors to our business, others

 

27.9 How long will we hold your information

We will only retain personal data for as long as necessary for the purposes for which it was collected as required by law or regulatory guidance to which we are subject or to defend any legal actions.

 

27.10 Implications of not providing information

Where lawful basis is a statutory or contractual requirement, if individual is obliged to provide the personal data, failure to provide this information may result in us being unable to provide our services.

 

27.11 Processing your information outside the EEA

Some of third parties we share your data with may reside outside the European Economic Area (which currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein). If we do this, your information will be treated to the same standards adopted in Ireland. We may also disclose your information for the prevention and detection of crime and to protect the interests of us or others, or if required to do so by law or other binding request.

 

27.12 How to exercise your information rights (including the right to object)

 

Erasure

 

When have I the right to all my personal data being deleted by Mosney Village?

You have the right to have your personal data deleted without undue delay if:

  • The personal data is no longer necessary in relation to the purpose(s) for which it was collected/processed

  • You are withdrawing consent and where there is no other legal ground for the processing

  • You object to the processing and there are no overriding legitimate grounds for the processing

  • The personal data has been unlawfully processed

  • The personal data must be erased so that we are in compliance with legal obligation

  • The personal data has been collected in relation to the offer of information society services with a child.

 

What happens if Mosney Village has made my personal data public?

If we have made your personal data public, we, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform those who are processing your personal data that you have requested the erasure.

 

What happens if Mosney Village has disclosed my personal to third parties?

Where we have disclosed your personal data in question to third parties, we will inform them of your request for erasure where possible. We will also confirm to you details of relevant third parties to whom the data has been disclosed where appropriate.

 

 

Data portability

 

When can I receive my personal data in machine readable format from Mosney Village?

You will receive your personal data concerning you in a structured, commonly used and machine- readable format if:

  • processing is based on consent or contract

  • processing is carried out by automated means.

 

Would Mosney Village transfer the personal data to another service provider if I requested this?

We can transfer this data to another company selected by you on your written instruction where it is technically feasible taking account of the available technology and the feasible cost of transfer proportionate to the service we provide to you.

 

Under what circumstances can Mosney Village refuse?

You will not be able to obtain, or have transferred in machine-readable format, your personal data if we are processing this data in the public interest or in the exercise of official authority vested in us.

 

Will Mosney Village provide me with my personal data if the file contains the personal data of others?

We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Contact us at dataprotection@mosney.ie or Mosney Village, Julianstown, Co Meath A92 ED6V

 

Automated individual decision making

 

What are my rights in respect of automated decision making?

Mosney Village does not have any automated decision-making processes. Where any such processes are introduced, we will provide you with the relevant information required under the

“General Data Protection Regulation”.

 

Object

 

Have I already been informed about my right to object?

We have informed you of your right to object prior to us collecting any of your personal data as stated in our privacy statement.

 

When can I object to Mosney Village processing my personal data?

You can object on grounds relating to your situation.

 

Mosney Village will stop processing your personal data unless:

  • we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms

  • the processing is for the establishment, exercise or defence of legal claims.

 

What are my rights to object for direct marketing purposes?

Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

 

Where you object to processing for direct marketing purposes, we will no longer process this data for such purposes.

 

What are my rights to object in the use of information society services?

In the context of the use of information society services, you may exercise your right to object by automated means using technical specifications.

Contact us at dataprotection@mosney.ie or Mosney Village, Julianstown, Co Meath A92 ED6V

 

Restrict processing

When can I restrict processing?

You may have processing of your personal data restricted:

  • While we are verifying the accuracy of your personal data which you have contested

  • If you choose restricted processing over erasure where processing is unlawful

  • If we no longer need the personal data for its original purpose but are required to hold the personal data for defence of legal claims

  • Where you have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our legitimate grounds override.

 

What if Mosney Village has provided my personal data to third parties?

Where we have disclosed your personal data in question to third parties, we will inform them about the restriction on the processing, unless it is impossible or involves disproportionate effort to do so.

 

How will I know if the restriction is lifted by Mosney Village and/or relevant third parties?

We will inform on an individual basis when a restriction on processing has been lifted.          

Contact us at dataprotection@mosney.ie or Mosney Village, Julianstown, Co Meath A92 ED6V

 

Rectification

 

What can I do if Mosney Village is holding incorrect personal data about me?

Where you suspect that data we hold about you is inaccurate, we will on demand rectify any inaccuracies without undue delay and provide confirmation of same.

 

What happens if Mosney Village has transferred my data to third parties?

We will inform them and request confirmation that rectification has occurred. We will also provide you with details of the third parties to whom your personal data has been disclosed.

Contact us at dataprotection@mosney.ie or Mosney Village, Julianstown, Co Meath A92 ED6V

 

Withdraw consent

 

Under what circumstances could I withdraw consent?

You can withdraw consent if we are processing your personal data based on your consent.

 

When can I withdraw consent?

You can withdraw consent at any time.

 

If I withdraw consent what happens to my current data?

Any processing based on your consent will cease upon the withdrawal of that consent. Your withdrawal will not affect any processing of personal data prior to your withdrawal of consent, or any processing which is not based on your consent.

Contact us at dataprotection@mosney.ie or Mosney Village, Julianstown, Co Meath A92 ED6V

 

Lodge a complaint

 

Can I lodge a complaint with the Data Protection Commission?

You can lodge a complaint with the Data Protection Commission in respect of any processing by or on behalf of Mosney Village of personal data relating to you.

 

How do I lodge a complaint?

Making a complaint is simple and free. All you need to do is write to the Data Protection Commission giving details about the matter. You should clearly identify the organisation or individual you are complaining about. You should also outline the steps you have taken to have your concerns dealt with by the organisation, and what sort of response you received from them. Please also provide copies of any letters between you and the organisation, as well as supporting evidence/material.

 

 

What happens after I make the complaint?

The Data Protection Commission will then take the matter up with [name the organisation] on your behalf.

 

Access your data

 

When do I have the right to access my personal data from [name the organisation]?

Where Mosney Village process any personal data relating to you, you have the right to obtain confirmation of same from us, and to have access to your data.

 

What information will Mosney Village provide to me?

If we are processing your personal data, you are entitled to access a copy of all such personal data processed by us subject to a verification process to ensure we are communicating with the correct person. We will provide any of the following information:

  • why we are processing your personal data

  • the types of personal data concerned

  • the third parties or categories of third parties to whom the personal data have been or will be disclosed. We will information you if any of the third parties are outside the European Economic Area (EEA)or international organisations

  • how your personal data is safeguarded where we provide your personal data outside the European Economic Area or to an international organisation

  • the length of time we will hold your data or if not possible, the criteria used to determine that period

  • your rights to:

    • request any changes to inaccurate personal data held by us

    • have your personal data deleted on all our systems

    • restriction of processing of personal data concerning you

    • to object to such processing

    • data portability

  • your right to lodge a complaint with the Data Protection Commission info@dataprotection.ie

  • where we have collected your personal data from a third party, we will provide you with the information as to our source of your personal data

  • any automated decision-making, including profiling which includes your personal data. We will provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

 

What Information is not provided?

Business Information pertaining to your role as an employee

 

How long will it take to receive my personal data from Mosney Village?

We will provide you with a copy of the personal data we are currently processing within one month of request. In rare situations if we are unable to provide you with the data within one month we will notify you, within one month of your valid request, explaining the reason for the delay and will commit to delivery within a further two months.

 

How much will it cost me to receive my personal data?

We will not charge for providing your personal data unless we believe the request is excessive and the cost of providing your data is disproportionate to your services provided.

 

Can I request additional copies of my personal data?

If you require additional copies we will charge €20 to cover our administrative costs.

 

Can I receive my personal data electronically?

You can request your personal data by electronic means and we will provide your personal data in a commonly used electronic form if technically feasible.

 

What will Mosney Village do if another person’s personal data is shared with my personal data? We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Contact us at dataprotection@mosney.ie or Mosney Village, Julianstown, Co Meath A92 ED6V

 

How to contact us and/or Our Data Protection Officer/Lead

There are many ways you can contact us, including by phone, email, and post.

+ 353 41 9829200; dataprotection@mosney.ie

Our postal address: Mosney Village, Julianstown, Co Meath A92 ED6V

Changes to this notice

Where changes to this Privacy Statement occur the updated version will be available in the main Reception and published on our website at www.mosneyvillage.ie and where appropriate/possible communicated directly to individuals through a communication channel.

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