Who are we?

We are Frontier Privacy Limited (Frontier Privacy) registered company number 591407 at 4 Upper Pembroke Street, Dublin 2.

We provide a range of data protection consulting services, including gap assessments; document drafting; training and advisory work.  We collect and process personal data in order to provide these services.  Frontier Privacy is the data controller in respect of this data.

This statement sets out the basis on which any personal data we collect from you, or from others, will be processed by us.  Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Our data protection contact may be contacted at admin@frontierprivacy.com, 4 Upper Pembroke Street, or on + 353 1 6392935.

 

What personal information do we collect from you?

You may give us personal data by:

  • Becoming a client of or a supplier to Frontier Privacy. Clients and suppliers supply us with information. The type of information we collect and process for this purpose is:
    • Name
    • Employee/job title/position
    • Contact details including address, phone number and email address
    • Documentation confirming your identity e.g. passport/drivers licence
    • Directors’ details
    • Financial information e.g. bank details, billing details, tax number
    • Any information provided to us on your behalf.
  • Corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary to provide you with our services or to submit a question/suggestion/comment in relation to our website or our services.
  • Filling in forms on www.frontierprivacy.com (our website) such as the contact us form.
  • Applying to work with us. The type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal data (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.

 

What information about you do we obtain from others?

We do not usually collect personal data from third party sources.   However, we may connect with clients and contacts via social media networks, e.g. Linked In.  In those circumstances we may have access to your publicly available details from that source.  We do not download that data or integrate it with our systems.

 

Why do we collect this information?

We collect the information, set out above, in order to provide you with our services, to market our services, to improve our website and to recruit staff.

We use this information as follows:

Clients:

  • To set you and/or your company up as a Client on our systems;
  • To liaise with you about services we are providing you with;
  • To liaise with you about projects that we are undertaking with you;
  • To liaise with you about training including CIPP/E training;
  • To ensure payment of our invoices;
  • To advise you of updates to our products and services and new developments in data protection generally, where you have asked us to do so.

 Candidates:

  • To create a candidate profile for you if you are a prospective employee.
  • To prepare interview notes.

Website Users:

  • To administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • As part of our efforts to keep our website safe and secure;
  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • To make suggestions and recommendations to you and other users of our website about services that may interest you or them.

The legal bases for the processing of your personal data are:

  • Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract.
  • Processing necessary for compliance with a legal obligation to which we are subject;
  • Processing necessary for the purposes of the legitimate interests which we pursue where such interests are not overridden by your interests or fundamental rights or freedoms;
  • That you have provided consent for the processing for one of more specified purposes.

We would not usually collect or process any special category data.

 

Who do we share this information with?

We may share your personal data with our consultants who work on your account, selected business associates; suppliers and contractors to provide you with our services. For example, these business partners may include our web hosting provider and our IT Cloud service providers.

In addition, we may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If we or substantially all of our assets are acquired by a third party, in which case information held by us about our Clients will be one of the transferred assets;
  • If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our Clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We attach at Schedule 1 a list of the categories of third parties with whom your personal data is shared.

 

How long do we keep hold of your information?

The time periods for which we retain your information depend on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.

For further information on the periods for which your personal data is kept, please contact admin@frontierprivacy.com.

 

Do we transfer your information Outside The European Union or European Economic Area?

In some circumstances, it may be necessary for us to transfer your Personal Data to a country outside the European Economic Area (“EEA”).  We will only transfer your Personal Data where the transferee is based in a country that has been approved by the EU Commission, or where there are appropriate safeguards in place to protect your Personal Data.  If you would like further information about the appropriate safeguards in place to govern the transfer of your Personal Data, please contact admin@frontierprivacy.com.

 

What are your rights with respect to your personal data?

You have the following rights:

  • The right to access the personal data we hold about you.
  • The right to require us to rectify any inaccurate personal data about you without undue delay.
  • The right to have us erase any personal data we hold about you in circumstances such as where it is no longer necessary for us to hold the personal data or, in some circumstances, if you have withdrawn your consent to the processing.
  • The right to object to us processing personal data about you such as processing for profiling or direct marketing.
  • The right to ask us to provide your personal data to you in a portable format or, where technically feasible, for us to port that personal data to another provider provided it does not result in a disclosure of personal data relating to other people.
  • The right to request a restriction of the processing of your personal data.

Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

You may exercise any of the above rights by contacting our Data Protection contact.

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie.

 

What will happen if we change our Privacy Statement?

This statement may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this statement each time you use our website or our services. This statement was last updated on 25th May 2018.

 

How can you contact us?

Our Data Protection Contact can be contacted by:

  • Phone: + 353 1 6392935
  • Address: 3-4 Upper Pembroke Street, Dublin 2.
  • On our website contact form: www.frontierprivacy.com
  • Or by email: admin@frontierprivacy.com

 

 

Schedule 1

We have set out below a list of the categories of third parties with whom we share your data.

Categories of Recipients:

  • Frontier Privacy Consultants
  • Email & Cloud services
  • Law Firms (where appropriate)
  • IT services
  • Accounting: software service providers, our Accountant and our Auditor
  • Insurance Services (our Broker and Insurance Company)
  • Revenue Commissioners and other Regulatory Bodies (where required to do so)
  • Payroll service provider
  • Bookkeeper
  • Telephone answering service (when you phone us)
  • Office Management Company (when you meet with us in our offices)
  • Bank
  • Recruiters
  • International Association of Privacy Professionals  (your contact details and feedback forms – where you undertake on our CIPP/E training courses)

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ALL RIGHTS RESERVED.