This Privacy Policy governs all pages on Transparency International (TI) Ireland’s Integrity at Work (IAW) website, www.integrityatwork.ie. It does not apply to pages hosted by other organisations, including the websites of other TI National Chapters or related organisations or third-party sites. The IAW website may be linked to the websites of such other parties but those other sites may have their own privacy policy which applies to them.
Our website may be used without entering personal information. Different rules may apply to certain services on the Website, however, and are explained separately below. Where we do collect personal information from you (e.g. name, address, email address, telephone number, etc.) it will be in accordance with the provisions of the Data Protection Acts and the General Data Protection Regulation (“GDPR”).
Information is considered personal if it can be associated exclusively to a specific natural person. The provisions below serve to provide information as to the manner, extent and purpose for collecting, using and processing personal information by the provider. TI Ireland will not process personal data where this is unwarranted in any particular case by reason of prejudice to your fundamental rights and freedoms or legitimate interests.
In other circumstances, such as for the use of cookies and subscription to the IAW newsletter, TI Ireland also rely on your consent for the processing of your personal data. When we process your personal data on the basis of your consent, you are free to withdraw your consent at any time. TI Ireland always include an unsubscribe button in our communications, so you can opt out of receiving such communications at any time. You can also withdraw your consent by contacting us using the contact details at the bottom of the page. Please note that if you withdraw your consent, we may not be able to continue providing you with the service to which the consent related.
TI Ireland will not retain your data for longer than is necessary for the purposes of our legitimate interests. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
When we no longer need your personal data, or when consent is withdrawn, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Please be aware that data transfer via the internet is subject to security risks and, therefore, complete protection against third-party access to transferred data cannot be ensured.
Your Rights
- Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you wish to exercise any of these rights or have any questions about this policy, please contact:
The Data Protection Officer
Transparency International Ireland
Floor 2
69 Middle Abbey Street
Dublin 1
Ireland
or please email us: admin@transparency.ie
If you have any concerns over the use of your personal data by TI Ireland, you can submit a complaint to the Data Protection Commissioner:
Office of the Data Protection Commissioner
Canal House
Station Road
Portarlington
Co. Laois
Ireland
Phone: +353 (0761) 104 800 | LoCall 1890 25 22 31
Email: info@dataprotection.ie
Cookies
The IAW Website makes use of so-called cookies in order to recognize repeat use of the Website by the same user/internet connection subscriber. Cookies are small text files that your internet browser downloads and stores on your computer. They are used to improve the Website and services. In most cases these are so-called “session cookies” that are deleted once you leave the Website.
To an extent, however, these cookies also pass along information used to automatically recognize you. Recognition occurs through an IP address saved to the cookies. The information thereby obtained is used to improve our services and to expedite your access to the website.
You can prevent cookies from being installed by adjusting the settings on your browser software accordingly. You should be aware, however, that by doing so you may not be able to make full use of all the functions of the website.
Server Data
For technical reasons, data such as the following, which your internet browser transmits to us or to our web space provider (so called server log files), is collected: – type and version of the browser you use – operating system – websites that linked you to our site (referrer URL) – websites that you visit – date and time of your visit. This anonymous data is stored separately from any personal information you may have provided, thereby making it impossible to connect it to any particular person. The data is used for statistical purposes in order to improve the Website and services.
Contacting Us
On the IAW Website we offer you the opportunity to contact us, either by email and/or by using a contact form. In such event, information provided by the user is stored for the purpose of facilitating communications with the user. No data is transferred to third parties. Nor is any of this information matched to any information that may be collected by other components of the Website.
Use of Google Analytics with Anonymisation
The IAW Website uses Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter referred to as “Google“. Google Analytics employs so-called “cookies“, text files that are stored to your computer in order to facilitate an analysis of your use of the site.
The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.
We use Google Analytics with an IP anonymization feature on the Website. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from member states of the European Union or signatory states to the Agreement on the European Economic Area.
Google will use this information to evaluate your usage of our site, to compile reports on website activity for us, and to provide other services related to website- and internet usage. Google may also transfer this information to third parties if this is required by law or to the extent this data is processed by third parties on Google´s behalf.
Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly. You should be aware, however, that by doing so you may not be able to make full use of all the functions of the Website.
Google also offers a disabling option for the most common browsers, thus providing you with greater control over the data which is collected and processed by Google. If you enable this option, no information regarding your website visit is transmitted to Google Analytics. However, the activation does not prevent the transmission of information to us or to any other web analytics services we may use. For more information about the disabling option provided by Google, and how to enable this option, visit https://tools.google.com/dlpage/gaoptout?hl=en
Use of Twitter Recommendation Components
The IAW Website employs components provided by Twitter. Twitter is a service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA.
Each time the IAW Website receives an access request equipped with a Twitter component, the component prompts your browser to download an image of this component from Twitter. Through this process, Twitter is informed precisely which page of the TI Ireland Website is being visited. We have no control over the data that Twitter collects in the process, or over the extent of the data that Twitter collects. To the best of our knowledge, Twitter collects the URL of each website accessed as well as the IP address of the user, but does so solely for the purpose of displaying Twitter components. Additional information may be obtained from the Twitter data privacy policy, at: http://twitter.com/privacy.
You may change your data privacy settings in your account settings, at http://twitter.com/account/settings
Use of LinkedIn Recommendation Components
The IAW website employs components provided by the network LinkedIn. LinkedIn is a service of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time the IAW Website receives an access request equipped with a LinkedIn component, the component prompts your browser to download an image of this component from LinkedIn. Through this process, LinkedIn is informed exactly which page of the IAW Website is being accessed. By clicking the LinkedIn “recommend button“ while logged into your LinkedIn account, you can link content from the IAW Website to your LinkedIn profile. This allows LinkedIn to associate your visit to our site with your LinkedIn account.
We have no control over the data that LinkedIn collects thereby, nor over the extent of the data that LinkedIn collects. Nor do we have any knowledge of the content of data transferred to LinkedIn. Details on data collection by LinkedIn as well as your rights in this regard and your browser setting options may be obtained from the LinkedIn data privacy policy, which may be accessed at: http://www.linkedin.com/legal/privacy-policy
Use of YouTube Components
On the IAW Website we use components (videos) of YouTube, LLC 901 Cherry Ave., 94066 San Bruno, CA, USA, a company belonging to Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA.
When you display a page that has an embedded video, a connection will be made to the YouTube server and the content will appear on the TI Ireland Website via a communication to your browser.
Further information about data protection by YouTube is provided by Google under the following link:
https://policies.google.com/privacy
Use of Google AdWords
For purposes of promotion, the IAW Website also employs the Google ad tool “Google-Adwords”. As part of this, the Website employs the analysis service “Conversion-Tracking” from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter referred to as “Google“. If you access our site by way of a Google ad, a cookie is placed on your computer. Cookies are small text files that your internet browser downloads and stores to your computer. These so-called “conversion cookies” cease to be active after 30 days and are not used to identify you personally. If you visit certain pages of the Website while the cookie is still active, we and Google know that you, as user, have clicked on ads placed on Google and were redirected to our site. Google uses the information obtained through “conversion cookies” to compile statistics for the Website. These statistics tell us the total number of users who have clicked on our ad as well as which pages of our site were then accessed by each user. However, neither we nor other advertisers who use “Google-Adwords” receive any kind of information that can be used to personally identify users. You can prevent the installation of “conversion cookies” by making the appropriate change to your browser settings, for example by setting your browser so that the automatic placement of cookies is deactivated or by blocking cookies from the domain “googleadservices.com“.
You can obtain the relevant data privacy policy from Google at the following link:
https://policies.google.com/privacy
Integrity at Work Newsletter – Privacy Policy
Transparency International Ireland (TI Ireland) is committed to protecting your privacy. This privacy statement is intended to inform you on how and why we store your data in line with the entry into force of the General Data Protection Regulation (“GDPR”) on 25 May 2018.
Should you have any questions, please contact our Data Protection Officer, Donncha Ó Giobúin, on the following email: admin@transparency.ie
We use MailChimp for the Integrity at Work (IAW) newsletter and other communications. MailChimp is a proprietary US-based online platform which allows us to send you our newsletter.
Who is the Data Controller of my MailChimp data?
For the purposes of newsletters or other communications which we distribute via MailChimp, TI Ireland is the Data Controller of your data (we have primary responsibility for safeguarding your data) and MailChimp is a Data Processor (MailChimp are contracted to distribute our newsletters to you).
How does this work?
- This means that when you sign up to the IAW newsletter, we collect the data you provide — these comprise your name, email address and IP address which constitute personal data. We process this data on the basis of your consent as provided when you signed up and/or in pursuit of the legitimate interest of communicating information on our work and measures aimed at stopping corruption. TI Ireland will not process personal data in pursuance of its legitimate interests where the processing is unwarranted in any particular case by reason of prejudice to the fundamental rights and freedoms or legitimate interests of the data subject.
- We transfer this information to MailChimp who then ask you sign up to a MailChimp account using a double opt-in method which helps to verify that you are the actual service requester.
Who has access to my data?
TI Ireland’s Office Coordinator and a limited number of administrative staff have access to your data. Other parties who have access to your data are MailChimp and potentially processors to whom they may sub-contract data for the purposes of customer support provision or abuse investigation.
Insofar as MailChimp uses or discloses data relating to the operation, support or use of its services for its legitimate business purposes, such as billing, account management, technical support, product development, sales and marketing, MailChimp is the Data Controller of such data and processes the data in accordance with the MailChimp Privacy Policy – https://MailChimp.com/legal/privacy and Data Protection Laws. See especially, Section 16.
How are your data safeguarded?
Please be aware that MailChimp will store your name, contact details, IP address and any other data you supply using their facility. Please see MailChimp’s Privacy Policy here: https://MailChimp.com/legal/privacy/
MailChimp is certified under the EU-US privacy Shield Framework which is a mechanism employed by the EU and the US to safeguard the personal data of EU citizens stored in the latter jurisdiction. TI Ireland has a contract with MailChimp which includes the requirement for TI Ireland’s consent prior to sub-contracting or disclosure of any data of which we are the Controller.
Further information about the data protection offered by MailChimp can be found at:
- Mailchimp privacy policy
Newsletter tracking
Our newsletter includes so-called web bugs that allow us to recognize if and when an email has been opened and which links in the email have been clicked by its recipient.
This data is stored by us so that we can best align our newsletter to the wishes and interests of our subscribers. Accordingly, the data thus collected is used to send personalized newsletters to each recipient.
Your rights relating to personal data
You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:
- right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
- right to rectification- you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
- right to erasure – you have the right to request us to delete personal data that we hold about you.
- right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
- right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine-readable format.
In order to exercise any of the rights set out above, please contact our Data Protection Officer as above.
If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.
If you are unhappy with how we process personal data, we ask you to contact us so that we can rectify the situation.
You may lodge a complaint with a supervisory authority. The Irish supervisory authority is the Data Protection Commission.
We will store your data until you notify us that you no longer wish to receive our newsletter and/or other communications.