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PRIVACY POLICY

INTRODUCTION TO THE A-TEAM'S DATA PROTECTION POLICY

The A-Team Data Protection Policy

Rationale As a data controller, The A-Team and its volunteers (referred-to collectively as The A-Team) must comply with the data protection rules set out in the relevant Irish legislation.  This Policy applies to all personal data collected, processed and stored by The A-Team in the course of its activities.  In its role as a club for autistic children and young people, The A-Team may keep information relating to a club member’s physical, physiological or mental well-being, as well as their cultural or social identity.  Personal data also includes a combination of identification elements such as physical characteristics, pseudonyms, occupation, home address, etc. To the extent that The A-Team’s use of personal data qualifies as ‘business to customer’ processing, including the organisation’s communications to its members, their parents or guardians, and volunteers, The A-Team is mindful of its obligations under the relevant Irish legislation, namely: The Irish Data Protection Act (1988); The Irish Data Protection (Amendment) Act (2003); and The EU Electronic Communications Regulations (2011). Scope The policy covers both personal and sensitive personal data held in relation to its data subjects by The A-Team. The policy applies equally to personal data held in manual and automated form. All personal and sensitive personal data will be treated with equal care by The A-Team. Both categories will be equally referred to as personal data in this policy, unless specifically stated otherwise.

DEFINITIONS

For the avoidance of doubt, and for consistency in terminology, the following definitions apply within this Policy.

DATA

This includes both automated and manual data.  Automated data means data held on computer, or stored with the intention that it is processed on computer.  Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.  Personal Data Information that relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of The A-Team. Sensitive Personal Data Sensitive personal data is personal data which relates to specific aspects of one’s identity or personality, and includes information relating to ethnic or racial identity, political or ideological beliefs, religious beliefs, trade union membership, mental or physical well-being, sexual orientation, or criminal record. Data Controller The legal entity responsible for the acquisition, processing and use of the personal data. In the context of this policy; The A-Team is the data controller. Data Subject A living individual who is the subject of the personal data, i.e. to whom the data relates either directly or indirectly.  Data Processor A person or entity who processes personal data on behalf of The A-Team on the basis of a formal, written contract, but who is not an employee of The A-Team.  Data Protection Officer Emma Burns is the A-Team committee member with responsibility for monitoring compliance with the appropriate data protection legislation, to deal with Subject Access Requests, and to respond to data protection queries from members, parents, volunteers, and the general public.

The A-Team as a Data Controller

In the course of its daily organisational activities, The A-Team acquires, processes and stores personal data in relation to living individuals. To that extent, The A-Team is a data controller, and has obligations under the Data Protection legislation, which are reflected in this document.  The A-Team is committed to ensuring that all volunteers who have access to data also have sufficient awareness of the legislation in order to be able to anticipate and identify a data protection issue, should one arise. In such circumstances, volunteers must ensure that the Data Protection Officer (DPO) is informed, in order that appropriate corrective action is taken.  Due to the nature of the services provided by The A-Team, there is a regular and active exchange of personal data between The A-Team and its data subjects. In addition, The A-Team exchanges personal data with data processors on the data subjects’ behalf. This is consistent with The A-Team obligations under the terms of its contracts with its data processors.  This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a staff member is unsure whether such data can be disclosed. In general terms, the staff member should consult with the Data Protection Officer to seek clarification.

Third-Party Processors (where applicable)

In the course of its role as data controller, The A-Team engages third-party service providers, or data processors, to process personal data on its behalf. An example of this exchange is the sharing of parents and volunteer data with Youth Work Ireland Tipperary for training, vetting and child protection purposes, and the sharing of that information between Youth Work Ireland Tipperary and the Garda Vetting Office.

A formal, written contract is in place between The A-Team and the processor, Youth Work Ireland Tipperary.  Stephen Quinn is the Youth Work Ireland Tipperary employee appointed to liaise with The A-Team around data processing.

The Data Protection Rules

The following key rules are enshrined in Irish legislation and are fundamental to The A-Team’s data protection policy. In its capacity as data controller, The A-Team ensures that all data shall: 1.Be obtained and processed fairly and lawfully For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of: •The identity of the data controller (The A-Team); •The purpose(s) for which the data is being collected; •The person(s) to whom the data may be disclosed by the data controller; •Any other information that is necessary so that the processing may be fair. The A-Team will meet this obligation in the following way: •Where possible, the informed consent of the data subject will be sought before their data is processed; •Where it is not possible to seek consent, The A-Team will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.; •Where The A-Team intends to record activity on CCTV or video, a Fair Processing Notice will be posted in full view, prior to the recording; •Processing of the personal data will be carried out only as part of The A-Team’s lawful activities, and it will safeguard the rights and freedoms of the data subject; •The data subject’s data will not be disclosed to a third party other than to a party contracted to The A-Team and operating on its behalf, or where The A-Team is required to do so by law. 2.Be obtained only for one or more specified, legitimate purposes The A-Team will obtain data for purposes which are specific, lawful and clearly stated. A data subject will have the right to question the purpose(s) for which The A-Team holds their data, and it will be able to clearly state that purpose or purposes. 3.Not be further processed in a manner incompatible with the specified purpose(s) Any use of the data by The A-Team will be compatible with the purposes for which the data was acquired. 4.Be kept safe and secure The A-Team will employ high standards of security in order to protect the personal data under its care. The A-Team’s Password Policy and Data Retention & Destruction Policies guarantee protection against unauthorised access to, or alteration, destruction or disclosure of any personal data held by The A-Team in its capacity as data controller. Access to, and management of, staff and customer records is limited to those staff members who have appropriate authorisation and password access. In the event of a data security breach affecting the personal data being processed on behalf of the data controller, the relevant third party processor will notify the data controller without undue delay. 5.Be kept accurate, complete and up-to-date where necessary The A-Team will: •Ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy; •Conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. The A-Team conducts a review of sample data every 12 months at membership renewal time to ensure accuracy; •Ensure that volunteer contact details are reviewed and updated every two years, or on an ‘ad hoc’ basis where staff members inform the office of such changes; •Conduct regular assessments in order to validate the need to keep certain personal data. 6.Be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed The A-Team will ensure that the data it processes in relation to data subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained. 7.Not be kept for longer than is necessary to satisfy the specified purpose(s) The A-Team attempts to update its membership every 12 months. The personal data of inactive members is put into ‘holding’ for 12 months. This is to facilitate the return of lapsed members. After 12 months of inactivity, the member’s information and that of their parents or supporters, where relevant, will be permanently deleted from the electronic database. All manual data (primarily sign-in sheets) will be destroyed within or before the 5 year retention period. Once the respective retention period has elapsed, Youth Work Ireland undertakes to destroy, erase or otherwise put this data beyond use. 8.Be managed and stored in such a manner that, in the event a data subject submits a valid Subject Access Request seeking a copy of their personal data, this data can be readily retrieved and provided to them The A-Team has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.

DATA SUBJECT ACCESS REQUESTS

As part of the day-to-day operation of the organisation, The A-Team core volunteers engage in active and regular exchanges of information with data subjects. Where a valid, formal request is submitted by a data subject in relation to the personal data held by The A-Team which relates to them, such a request gives rise to access rights in favour of the Data Subject.

 

The A-Team’s volunteers will ensure that such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 calendar days from receipt of the request.

CONTACT DETAILS

For all queries relating to Data Protection, please contact our Data Protection Officer Emma Burns by email at theateamnorthtipp@gmail.com with the phrase “FAO Emma Burns - Data Query” in the subject line.

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