This statement governs the use by Reddy Charlton of any personal data in respect of which we are a controller.
This privacy statement will inform you as to how we use your personal data and tell you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
Reddy Charlton, a partnership and Reddy Charlton Services Limited both with registered address at 12 Fitzwilliam, Dublin 2 (together ‘Reddy Charlton’, ‘we’, ‘us’ or ‘our’ in this privacy notice) is the controller responsible for such of your personal data that you share with us.
We have appointed a data privacy manager who 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 as outlined hereunder, please contact the data privacy manager using the details set out below.
Name: Elaine Mc Grath
Address: 12 Fitzwilliam Place, Dublin 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 contact us in the first instance
2. Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
3. Changes to the privacy notice and your duty to inform us of changes
This privacy notice is current as at the date of this letter.
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.
THE DATA WE COLLECT ABOUT YOU
1. Personal Data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:-
1.1. Identity Data includes first name, last name, title, date of birth, photo ID, proof of address
1.2. Contact Data includes address, email address and telephone numbers.
1.3. Financial Data includes bank account, salary information, tax affairs, details of personal assets and liabilities.
1.4. Matter Data includes such other information as you may provide or we may require in relation to the scope of work set out in this letter of engagement or other instructions that you might give us.
2. 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:-
2.1. with your explicit written consent; or
2.2. 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.
2.3. to comply with any directions of relevant authorities for reasons of public interest in the area of public health.
3. 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.
HOW IS YOUR DATA COLLECTED?
We use different methods to collect data from and about you including through:
1. Direct interactions – You may give us your personal data via our website or in the course of a consultation with us or by corresponding with us by post, telephone, email or otherwise.
1. Third parties or publicly available sources – We may receive personal data about you from various third parties as set out below:-
- publically available social media platforms;
- public registers such as the Courts Service, the Companies Registration Office or the Property Registration Authority;
- the counterparty to a transaction or legal proceedings or their legal advisors;
- other professional advisors with whom we are instructed to liaise such as accountants or tax advisors.
HOW WE USE YOUR PERSONAL DATA
Most commonly, we will use your personal data in the following circumstances:-
1. Where we need to perform the contract we are about to enter into or have entered into with you.
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.
3. Where we need to comply with a legal or regulatory obligation
4. With your specific consent. If consent is used as a legal basis for processing your data, you have the right to withdraw consent at any time by contacting us at email@example.com
The below paragraph sets out the types of lawful basis that we will rely on to process your personal data.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of 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 contact us at firstname.lastname@example.org 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:-
1. “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and 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).
2. “Performance of Contract” means processing your data where it is necessary to provide our services to you pursuant to this or any other engagement at your request.
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.
4. Public Health: where it is needed for reasons of public health to assist with contact tracing.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|Performance of a contract with you|
|To market the services of Reddy Charlton and provide you with legal update and newsletter||Necessary for our legitimate interests (to keep you informed of our the services and expertise of Reddy Charlton)|
|To indicate on promotional material, tenders for work and in the course of marketing the firm, that we represent you and refer to the type of work we have carried out on your behalf||Consent|
|Monitoring email traffic in and out of our system||Virus and fraud detection|
|To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|Maintaining a log of visitors to the office||Reasons of public health or legal or regulatory obligations|
4. Opting Out
You can ask us to stop sending you marketing messages at any time by emailing email@example.com.
Where you opt out of receiving these marketing messages, we will continue to hold any personal data provided to us in the context of this or any other legal engagement.
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:-
1. Reddy Charlton may share your personal data with Reddy Charlton Services Limited and vice versa.
2. Where you engage Reddy Charlton jointly with any other party, we may share all information and personal data received from one client in the context of that engagement with the other client(s).
3. Service providers based inside of the EEA who provide IT and system administration services.
4. Our professional advisers and service providers acting as processors including lawyers, bankers, auditors and insurers based in Ireland who provide consultancy, payroll, dictation services, banking, legal, insurance and accounting services.
5. Your professional advisors and service providers including barristers, lawyers, bankers, auditors and insurers based within the EEA who provide consultancy, payroll, banking, legal, insurance and accounting services who you have advised to us and in relation to whom you have advised we may share your information.
6. The counterparty to a transaction and their legal advisors where relevant to the scope of work.
7. Revenue, governmental agencies, regulators, grant authorities, accreditation bodies and other authorities acting as processors or joint controllers based within the EEA 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.
8. Third parties (a) to whom we may choose to sell, transfer, or merge parts of our business or our assets or (b) from whom we acquire other businesses or merge with. 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.
9. Third parties where necessary for reasons of public interest in the area of public health including the Health Service Executive or other relevant authority to facilitate contact tracing.
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.
Where you instruct us to transfer data to any third party it shall be your responsibility to satisfy yourself that such third party has appropriate safeguards in place to protect your data.
Our engagement with you may from time to time require that we transfer your data to parties in other countries. Should this be the case we will first obtain your prior consent.
We will only retain your personal data for as long as necessary to fulfill 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 emailing firstname.lastname@example.org.
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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you have any queries or wish to exercise any of these rights please email email@example.com
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.
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.
3. Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no basis 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.
4. Object to processing of your personal data
You may object to processing 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.
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.
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.
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.
If you wish to exercise any of the rights set out above, please contact us as firstname.lastname@example.org