Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and users of the Digital Stepping Stones tool ("DSS Tool").
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users of the DSS Tool; in other words, where we determine the purposes and means of the processing of that personal data. "Personal Data" means any information about an individual from which that person can be identified.
1.3 Our website provides you with access to the DSS Tool which, through an online self-guided assessment, allows you to assess your level of digital skills and identify any areas where you may need to upskill to address any gaps in your personal digital divide.
1.4 We use cookies on our website to collect certain information when you visit our website, as explained in our Cookie Policy. Insofar as those cookies are not strictly necessary for the provision of our website and the DSS Tool, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to An Cosán (The Shanty Educational Project Ltd). For more information about us, see Section 9.
How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and the DSS Tool (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing your use of the website and the DSS Tool. The legal basis for this processing is consent. Please see our Cookie Policy for more details.
2.3 We will process your name and email address ("identification data") if you choose to use the DSS Tool. The identification data will be collected via your completion of the DSS Tool submission form. The source of the identification data is you. The legal basis for this processing is contractual necessity, namely to deliver the results of your DSS assessment to you.
2.4 We will process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.5 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.
Providing your personal data to others
3.1 We may disclose your personal data to any member of our technical team and to our service providers insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We will also disclose aggregated and anonymised data ("aggregated data") to funders of An Cosán. This aggregated data could be derived from your personal data but is not considered personal data under data protection laws as this data will not directly or indirectly reveal your identity. For example, we will use analytics cookies to gather aggregate information about your usage of the DSS Tool to calculate the number of users who access and/or complete the DSS Tool.
3.3 In addition to the specific disclosures of personal data set out in this Section 3, we will disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject.
International transfers of your personal data
4.1 We will not transfer your personal data to countries outside the European Economic Area (EEA).
Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process shall not be kept for longer than is necessary for the purposes for which it was collected.
5.3 We will retain your personal data as follows:
(a) Your name and e-mail address will be retained only for as long as is required to deliver the results of your DSS Tool assessment to you via email.
5.4 Notwithstanding the other provisions of this Section 5, we will retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, and for the establishment of defence of legal claims that may be brought by or against us.
Security
6.1 We are committed to protecting the security of your personal data. We have put in place appropriate security measures to protect your personal data from unauthorised access, use and disclosure. We limit access to your personal data to those An Cosán employees and third parties who have a legitimate and justifiable reason to view your data, and have been authorised to do so. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk.
Amendments
7.1 We reserve the right to update this policy from time to time at our sole discretion by publishing a new version on our website and updating the "last updated" date at the top of this privacy policy.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 However, if we make material changes to this policy, we will notify you by means of a prominent notice on the website prior to the change becoming effective.
Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities should you require a full explanation of these rights. In each case, these rights are subject to restrictions as laid down by law.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information (including details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data).
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions to the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to data portability, which enables you to request us to transmit personal data that you have provided to us to a third party. This will be done without hindrance, and a copy of the personal data can also be provided to you when it is technically feasible to do so.
8.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Irish Data Protection Commission.
8.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by notice to us, in addition to the other methods specified in this Section 8. We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a basis to do so in law, or if it is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.
Our details
9.1 This website is owned and operated by An Cosán (The Shanty Educational Project Ltd).
9.2 We are registered in Ireland under Registered Charity No. 8659, Registered Company No. 131383, Charity Regulator Number 20021528, and our registered office is at Kiltalown Village Centre, Jobstown, Tallaght, Dublin 24.
9.3 Our principal place of business is at Kiltalown Village Centre, Jobstown, Tallaght, Dublin 24.
9.4 You can contact us:
(a) using our website contact form;
(c) by telephone, on (01) 462 8488; or
(d) by email, using info@ancosan.ie.
9.5 Our contact details are: ancosanvcc@digitalsteppingstones.ie