The Together-Razem Centre Privacy Policy GDPR

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain. The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects.

These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

The Together-Razem Centre is strongly committed to protecting the privacy of its user and student community. The intent of this privacy statement is to detail the information The Together-Razem Centre may gather about individuals who visit its website and how that information is used.

What does this privacy policy cover?

The Privacy Policy applies to your use of The Together-Razem’s websites, products and services (collectively, “Services”).

By using The Together-Razem’s services, you are consenting to the use of your information in the manner set out in this Privacy Policy.

Updates to our Privacy Policy

The Together-Razem Centre may update this Privacy Policy from time to time so you are encouraged to periodically revisit this page for the latest Centre’s Privacy Policy. The current privacy policy replaces all previous versions and by your continued use of the Services you accept its terms.

Information we may hold about you and why

The information below describes how the Together-Razem Centre manages your personal information in accordance with the law and your rights.

Personal information is any information about an identifiable individual and is collected directly from you. Personal information you provide us may include information such as your name, email address, billing address, telephone number, personal profile. It does not cover every situation so please read notices on forms, web pages or other points where you give us information about yourself. These will describe the specific uses we make of the information, the reasons and legal basis for holding it as well as your rights.

The Together-Razem Centre may collect personal information directly from you when you:

  • create an account on one of our websites
  • in general, information you give us when you fill in forms, subscribe to our services, (for example such as: application forms to enrol to Razem Academy, English Classes, sponsorship, or to attend all type events) and email newsletters.
  • to support you when you use any of our services (for example, at our Advice and Information Clinics, Legal Clinics, to use our Community Translation Services, Counselling Services, other social groups, cultural events) when you use one of the forms available to access our services
  • When you contact the The Together-Razem Centre team
  • When you are applying for online support using our website advice service poradniaonline.org
  • when you apply for a job or to volunteer with us, including to process applications and to monitor recruitment statistics. If you come to work for us we will retain it to administer your employment
  • to manage feedback and complaints.
  • When you download our content
  • information we hold about you to support our fundraising operations.
  • When you simply communicate with us by email

The Together-Razem Centre may combine personal information with other information that does not, on its own, directly identify you (“non-personal information”).

For example non-personal information such as which parts of our websites you have visited may be associated with your The Together-Razem Centre account. This The Together-Razem Centre to provide you with a more personalised experience (with your consent). If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

How we use your information

Your information may be used by The Together-Razem for purposes such as:

  • Enabling us to provide you with our websites, services, support or information you have requested.
  • Sending you information about our services, administrative messages, appointment reminders, assessment notices, updates, security alerts and information requested by you.
  • Improving our services and developing new services.
  • Diagnosing problems in our services and websites.
  • Registering and activating your online accounts.
  • Providing support.
  • Sending you marketing, advertising, educational content, promotional messages and other information that may be of interest to you. These messages may be tailored based on your interactions with our websites and products.
  • Protecting and/or enforcing our legal rights and interests, including defending any claim.
  • For any other purposes authorised by you.

Many of the purposes we use your information for are necessary to provide our Services, others are for our legitimate interests such as research, data analysis, improving our Services and developing new services. Where our basis for processing information is legitimate interests, the information will only be used in an anonymised and/or aggregated form so that it does not identify you. Where our basis for collecting and processing information is your consent, for example, sending you marketing communications and the placement of certain types of cookies and similar technologies, you can withdraw your consent at any time as set out in this privacy policy.

Please note: You can always choose not to provide personal information to The Together-Razem Centre, but if you choose not to do so, in many cases we will not be able to provide you with our services, or respond to any queries you may have.

Our Websites:

www.together-razem.org, www. uclinic.info and www.poradniaonline.org

For visitors to our websites we collect the following types of personal data:

  • data regarding the location of the incoming the IP and the IP address itself;
  • location information on you when you browse our website;
  • email addresses, phone-numbers and other contact details supplied by users of our services for the purpose of booking appointments, online advice, events participation, courses and workshops or our Razem Academy school purposes
  • personal details including age, date of birth, nationality, education, employment
  • general details concerning your mental health, time of when you book an appointment with a healthcare professional through our website and
  • financial details such as credit or debit card numbers when we process a payment authorised by you through our site.

 

Newsletter and Emails:

Emails or Newsletters we send you may include technology that tells The Together-Razem whether you have received or opened an email, or clicked a link in the email. Marketing emails we send you may be tailored based on your interactions with our websites and services. If you do not want us to collect information from our Centre emails, or you don’t want to receive our newsletters anymore, you can unsubscribe by using the unsubscribe link within each email or by changing your notifications settings when logged into your account if you have one.  Please note we are using MailChimp system for our Newsletter.

 

Fundraising & PR activities
We may use your information in our legitimate interests to support our charitable work, or where we contact you by electronic means, with your consent, to:

  • process any donations you make.
  • send you information about The Together-Razem Centre and its work and how you can support us. We may do this by post. We may also contact you by email, text or social media, where you have given permission.
  • help manage our communications with you by sharing it with our contractors working on our behalf to process donations and send communications.
  • build a picture of our supporters and help identify other similar potential donors to target our advertising to. In doing this we may share it with The Together-Razem Centre’s contractors but you will not be identified (for example, any data we send to social media is in an unidentifiable form).
  • ascertain whether you might like to support us if you are a personal charitable trust or foundation or interested in philanthropic giving. We may use publically available information about you to do this (for example websites or social media). We will always contact you first to see if you are happy to receive fundraising messages.

We use Google Analytics and similar technology to understand what aspects of our work people are interested in supporting. Information is collected anonymously and you will not be identified by it.

Information we collect on the website including the IP address of your computer, to:

  • help keep our site safe and secure.
  • help us diagnose faults with the website.
  • ensure that content from our site is presented in the most effective manner for you and for your computer COOKIES.
  • to understand how users make use of our website, using Google Analytics and similar technology allowing us to improve it. Information collected using Google Analytics is collected anonymously and you will not be identified by it.

 

Cookies and similar technologies

  • Session cookies are only stored on a per session basis to assist in the customers navigation of our web-sites, so that we offer personal content for you.
  • Persistent cookies are only stored to assist in the customer’s navigation of our web-sites using the stored data to display related preferences.
  • Customer can control cookies by changing the options on their own PC. For more See http://www.allaboutcookies.org/

Who do we share your personal information with?
We may share your personal information:

  • with our contractors who carry out work on our behalf (teachers, psychotherapists etc)
  • As per our Confidentiality Statement, and Consent Form you sign using our counselling services we do not disclose your personal information to any other third parties except in very limited circumstances (as set out in the Confidentiality Statement and Consent form). Personal Data will be kept for no longer than is necessary to provide our services to clients.
  • where we are under a legal obligation to disclose or share your information.
  • in some circumstances we may disclose information or undertake monitoring of potentially criminal behaviour under the Regulation of Investigatory Powers Act.

Data storage

Data is held in Ireland using different (multiple) servers. The Together-Razem Centre does not store personal data outside the EEA.

Securing your Data

The Together-Razem Centre takes technical measures as well as organisational security measures which are set out in law and by industry standards to ensure that we protect your personal data from unauthorised access, use or disclosure.

We will ensure that we use your personal information as set out in our privacy notice and to the choices that you have made regarding permission. The Together-Razem Centre only partner with reputable service providers who contract to provide the same level of security on information so that your data is at all times protected and used in accordance with our Privacy Notice.

Retention Policy & Retention

The Together-Razem will process personal data during the duration of any contract and will continue to store only the personal data needed as required by Law or Regulations

Purpose Retention Schedule
Social Advice, Information Provision, Legal Clinics, English Classes or Razem Academy School  Service Provision

 

 3 Years following final closure of case, or duration since final contact, whichever most recent. See Data Protection Policy appendix 4.

 
Counselling & Psychotherapy Service Provision 8 Years following final closure of case, or duration since final contact, whichever most recent.
Information mailings

 

 Data is retained for as long as mailing list is maintained, then subsequently deleted.

 
Fund-raising and development Data is retained for as long as mailing list is maintained, then subsequently deleted.

 
Research

 

 Subject to same retention schedule as Client Records -See Data Protection Policy appendix 4.

 
Human Resources

 

 See See Data Protection Policyappendix 3 HR record retention schedule.

 

Invoice Details:

Legally invoice details are required to be maintained for a period of 6 years and the current year.

Client Payments:

No Financial Information is stored either hard or soft copy in any of the cases above.

CCTV Images:

If we use CCTV images are kept for 28 days, unless a request is made from the Garda Siochana then it can be kept for 2 years which is stored locally.

Your rights as a data subject

At any point whilst The Together-Razem is in possession of or processing your personal data, all data subjects have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. This will not be possible while students are completing their courses.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
  • Right of portability – you have the right to have the personal data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that The Together-Razem refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

The Together-Razem at your request, can confirm what information it holds about you and how this information is processed.

You can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Together-Razem or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

The Together-Razem will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If The Together-Razem is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to info@together-razem.org  or writing to us at the address further below.

Governing Law

This Privacy Statement is governed by the laws of Ireland and you submit to the exclusive jurisdiction of the Irish Courts.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by The Together-Razem  or its partners, you have the right to complain to The Together-Razem. If you do not get a response within 30 days, you can complain to the Data Protection Regulator.

The details for each of these contacts are:

 

The Together-Razem Centre
Attention of the CEO
Unit 2a, Kilnap business Park, Mallow Rd, Cork

Telephone +21 4395588 or email info@together-razem.org

Data Protection Regulator
Canal House, Station Road
Portarlington
Co. Laois, R32 AP23

Telephone +353 761 104800 or email: info@dataprotection.ie