Introduction

This policy governs the use by The Girls’ Brigade Ireland (‘us’ ‘we’) of any data you share with us whether by using our website www.girlsbrigadeirl.ie (the ‘The Girls’ Brigade Ireland Website’) , including any data you may provide through this website when you register yourself or another as a member, sign up to a newsletter, purchase a product or service. It also includes data provided when you submit a document to us or otherwise engage with our services such as the data collected in person at brigade meetings and events.

The Girls’ Brigade Ireland, as organisation where the majority of its members are under the age of 18, is very conscious of its responsibilities in respect of both Child Protection and the protection of the privacy of its members. This document deals with Privacy only and is intended, in compliance with the GDPR, to inform you about how your personal data is used, with whom it is shared and to tell you about your privacy rights and how the law protects you. For the purpose of this document, any reference to the ‘website’ shall be deemed to be a reference to The Girls’ Brigade Ireland Website accessed by you including any 3rd party membership registration site which is accessed via that website.

1. [PURPOSE OF THIS PRIVACY NOTICE]

2. [THE DATA WE COLLECT ABOUT YOU]

3. [HOW IS YOUR PERSONAL DATA COLLECTED]

4. [HOW WE USE YOUR PERSONAL DATA]

5. [DISCLOSURES OF YOUR PERSONAL DATA]

6. [INTERNATIONAL TRANSFERS]

7. [DATA SECURITY]

8. [DATA RETENTION]

9. [YOUR LEGAL RIGHTS]]

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1. Controller The Controller of your personal data is The Girls’ Brigade Ireland, a charity registered with the Charities Regulator, charity number 5294.

We have appointed the Chairperson of the National Board as data privacy manager and this person is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Name: The Data Privacy Manager Address: The Girls’ Brigade Ireland, 2, Tritonville Avenue Sandymount Dublin 4 Email: privacy@girlsbrigadeirl.ie

1.2. You have the right to make a complaint at any time to the Data Protection Commissioner’s Office (www.dataprotection.ie) being the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner’s Office so please email us at privacy@girlsbrigadeirl.ie

1.3. Changes to the privacy notice and your duty to inform us of changes This version was last updated on August 12th 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4. Third-Party Links The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

2.1. Personal Data if you are a member under the age of 18 Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

2.1.1. Identity Data includes first name, last name, date of birth

2.1.2. Contact Data of your Parent or Guardian includes address, email address and telephone numbers.

2.1.3. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

2.1.4. The Girls’ Brigade Ireland service and accomplishment related data. Includes your length of membership of The Girls’ Brigade Ireland and badges your have earned and your achievements in any competitions you may have entered.

2.1.5. Usage Data includes information about how you use our website and services.

2.2. Personal Data if you are a member over the age of 18 Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

2.2.1. Identity Data includes first name, last name, date of birth

2.2.2. Contact Data includes address, email address and telephone numbers.

2.2.3. Service and accomplishment related data. Your length of service, any badges you earned while you were under 18 (retained for 7 years once you turn 18), results of Lieutenant interviews.

2.2.4. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

2.2.5. Usage Data includes information about how you use our website and services.

2.2.6. Marketing and Communications Data includes your preferences in receiving information about upcoming events aimed at promoting The Girls’ Brigade Ireland from us and your communication preferences.

2.3. Personal Data if you are a parent or guardian of a member under the age of 18

2.3.1. Identity Data: includes first name, last name.

2.3.2. Contact Data includes address, email address and telephone numbers.

2.3.3. Family Details includes name of daughter(s) who are members of The Girls’ Brigade Ireland.

2.3.4. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

2.3.5. Usage Data includes information about how you use our website and services.

2.3.6. Marketing and Communications Data includes your preferences in receiving information about upcoming events aimed at promoting The Girls’ Brigade Ireland from us and your communication preferences.

2.4. Special Categories ”Special categories” of particularly sensitive personal information require higher levels of protection (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

2.4.1. In limited circumstances, with your explicit written consent or the explicit consent of your parent or guardian. We do not ordinarily request or require medical or health information. You are not obliged to provide this information but if we are not made aware of any relevant medical or health issues we will be unable to take appropriate measures to ensure your safety and comfort or, if you are a parent/guardian of a member, that of your child.

2.4.2. Where we need to carry out our legal obligations

2.4.3. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

2.5. Criminal convictions As stipulated in Child Protection legislation, all adult members of The Girls’ Brigade

Ireland who interact with Children or Vulnerable persons must be vetted by the relevant authorities. The vetting process requires the provision of verified Proof of Identify and Proof of Address by all vetting candidates and, subsequently, checks by the relevant authorities of their records. The results of this vetting will be available to the recognised liaison person and an individual vetting subject may obtain a copy of their Garda Vetting disclosure from the liaison person by sending a request by email to privacy@girlsbrigadeireland.ie.

2.6. Further information We may provide you with further specific information about the type of data and purpose of it at the point of data capture.

3. HOW IS YOUR DATA COLLECTED

3.1. We use different methods to collect data from and about you including through:

3.1.1. Direct interactions. You may give us your personal data such as Name, Address, phone and email on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

3.1.1.1. complete the online registration form on our website in your capacity of a member over the age of 18 or as a Parent or Guardian completing the registration of a member under that age.

3.1.1.2. Submit a query on our website

3.1.1.3. Sign up to our newsletter

3.1.1.4. Ask to exercise your rights under the GDPR

3.1.1.5. Provide personal data in person at brigade meetings and events.

3.1.2. From your parents or guardians.

3.1.2.1. If you are under the age of 18 in September then your parents must complete and submit the online membership registration on your behalf and provide us with your personal data such as your name, address, and date of birth as well as some medical information if they feel is it in your best interests for us to know about it.

3.1.2.2. We may also receive personal data from third parties such as vetting disclosures from the National Vetting Bureau.

3.1.2.3. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.1. To administer your membership or that of your child of The Girls’ Brigade Ireland.

4.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.3. Where we need to comply with a legal or regulatory obligation.

Paragraph 5 below sets out the types of lawful basis that we will rely on to process your personal data. If consent is used as a legal basis for processing your data, you have the right to withdraw consent at any time by sending an email from the account we use to contact you to privacy@girlsbrigadeirl.ie.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please email us at privacy@girlsbrigadeirl.ie. if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. The lawful basis of processing that we use are as follows

5.1. Legitimate Interest means the interest of The Girls’ Brigade Ireland in conducting and managing our affairs to enable us to give our members and employees the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing us at privacy@girlsbrigadeireland.ie

5.2. Performance of Contract in the context of The Girls’ Brigade Ireland means processing your data where it is necessary for the administration of your membership or processing your registration of your membership, or that of your daughter, of the organisation as well as the processing that is required for the day to day running of events and regular meetings.

5.3. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

5.4. Consent we will only process your data when you have consented to it for one or more specific purpose. You consent will be as easy to withdraw as it was to grant and processing your data will cease if your consent is withdrawn.

5.5. Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at privacy@domain.ie

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.6. Opting Out. You can ask us to stop sending you marketing messages at any time by emailing us at privacy@domain.ie at any time or by clicking the Opt-out link in any of our marketing emails. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a course participation, membership registration or other transactions.

6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

6.1. External Third Parties 6.1.1. Service providers based inside the EEA who provide IT and system administration services.

6.1.2. Professional advisers acting as processors or joint controllers including Information Technology, lawyers and insurers based in Ireland who provide consultancy, legal, insurance, IT and accounting services.

6.1.3. Revenue, governmental agencies, regulators, and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances or to whom we are obliged to share information about our organisation and participation in it.

6.1.4. [DETAILS OF ANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKETING COMPANY].

6.1.5. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. INTERNATIONAL TRANSFERS

Neither The Girls’ Brigade Ireland nor any of its service providers transfers data outside the EEA.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, Captains, officers, helpers, contractors and other third parties who need to know in order to perform their duties. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION – HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by emailimg us at privacy@girlsbrigadeireland.ie

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may;

10.1. Request access to your personal data. This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.2. Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

10.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

10.4. Object to processing of your personal data. You may object 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

10.5. Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.6. Request transfer of your personal data to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

10.7. Right to withdraw consent. Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11. If you wish to exercise any of the rights set out above, please email us at privacy@girlsbrigadeireland.ie