Data Protection Statement
This Data Protection Statement provides information about the ways in which Dunhill GAA and Dunhill Sports Centre (‘Dunhillgaasc’) collects, stores and uses personal data relating to individuals (data subjects). This Data Protection Statement relates to personal data received by Dunhillgaasc where data subjects contact, or request information from, Dunhillgaasc directly, and also personal data received by Dunhillgaasc indirectly.
Who we are
Dunhill GAA Club was founded in 1890 and Dunhill Sports Centre was built 1989.
About our Privacy Policy
We respect your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily. This privacy policy (the “Policy”) together with our Terms of Service sets out important information about your rights in relation to the processing of your personal data, and the basis on which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of this website (“our Site” or “the Site”). We do not knowingly attempt to solicit or receive information from children.
Controller
Under this Policy, and unless the circumstances otherwise require, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data you provide to us.
The information we collect
We will collect and process the following data about you for the following purposes:
Information you give us
Your Data. This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our Site, register for, subscribe to or use the Services, search for a product, place an order on our Site, participate in discussion boards or other social media functions on our Site and/or when you participate in and respond to our sign-up or other surveys or report a problem with our Site and/or the Services.
The personal data that we process includes (i) basic personal information, such as a data subject’s name / surname; date of birth (ii) contact information, such as a data subject’s postal address, email address and phone number(s); and (iii) any other personal data that is provided to Dunhillgaasc during the course of the performance of its functions.
Special category data
Dunhillgaasc also processes special category data. This includes, as set out above, special category data received by Dunhillgaasc where data subjects contact, or request information from, Dunhillgaasc directly, and special category data received by Dunhillgaasc indirectly. Such special category data may include personal data concerning health when using the facilities.
The information we collect about you
Automatically Collected Information. With regard to each of your visits to our Site we will automatically collect the following information:
- Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application and other performance data.
- Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us;
Cookies
What are cookies and why we use them
The Site may use cookies from time to time. “Cookies” are small text files which are stored by your browser on your computer and are normally used to gather statistical information and to analyse trends of use or access to a website. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies may be used to save your personal preferences so you do not have to re-enter them each time you access the Site. For more about our use of cookies and how you can disable them, please see our cookie policy.
What we do with your information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
E-Privacy Regulations
Dunhillgaasc is also responsible for monitoring and enforcing compliance with the E-Privacy Regulations (S.I. No. 336 of 2011 – the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011). The E-Privacy Regulations relate to the processing of personal data in the context of certain electronic communications. From 25 May 2018, processing of personal data in this context (including, amongst other things, unsolicited electronic communications made by phone, e-mail, and SMS) is subject to both the general laws set out in the GDPR and the specific laws set out in the E-Privacy Regulations.
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 contact us at admin@dunhillgaasc.ie
How long we keep your information
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. This means that the period of time for which we store your personal data may depend on the type of data we hold. 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.
How Does Dunhillgaasc Collect Personal Data?
Phone Calls To Dunhillgaasc
Dunhillgaasc does not audio record or retain audio recordings of phone conversations.
Where an individual contacts Dunhillgaasc by phone, caller numbers are automatically stored on the recipient phone for a limited period of time in a list of inbound and outbound calls, but no further processing of this data (caller numbers) is carried out by Dunhillgaasc.
During the course of dealing with a query, complaint or other matter, Dunhillgaasc may record personal data received by it during the course of phone calls in the form of notes made on any bookings.
Emails:
All emails sent to Dunhillgaasc are recorded and are stored for the purposes of the matter to which the email relates. The sender’s email address will remain visible to all staff tasked with dealing with the query.
Please be aware that it is the sender’s responsibility to ensure that the content of their emails does not infringe the law. Unsolicited unlawful material, together with the details of the sender, may be reported to An Garda Síochána and/or other relevant authorities and further emails from such recipients may be blocked.
Post:
Original hard copy versions of post items are retained for a period of six weeks and are then confidentially destroyed thereafter.
In addition to the scanned version of post items retained by the relevant section of Dunhillgaasc, a master scanned copy of all post received is retained for a period of 12 months.
Social Media:
Dunhillgaasc also receives personal data through its social media interactions on Facebook and Instagram. Dunhillgaasc operates social media accounts on these platforms in support of its functions. Messages or posts received by Dunhillgaasc on these social media platforms are viewed by Dunhillgaasc but the personal data contained in the messages/posts is not logged or stored other than on the relevant social medial platform, and no further processing of such personal data is carried out by Dunhillgaasc.
CCTV:
We operate closed-circuit television at our sports centre. We have CCTV cameras located in the gymnasium and internally at points of entry/exit.
The purpose for our processing of personal data collected by the CCTV in operation is for security and safety. The legal basis of the processing is Article 6(1)(f),GDPR, which allows us to process personal data on the basis that it is necessary for Dunhillgaasc legitimate interests. CCTV footage is retained by the Commission for a period of 14 days.
Website:
Dunhillgaasc website (www.dunhillgaasc.ie) uses certain cookies. Our Website & Cookie Policy can be accessed here.
What Is The Legal Basis For The Processing Of Personal Data?
The legal basis for the processing of personal data by Dunhillgaasc will depend on the legislative framework that applies and the purpose for which the processing is being carried out.
Your Personal Data and Your Rights
Accessing your Personal Data
You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to admin@dunhillgaasc.ie
We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Right of Restriction
You may restrict us from processing your personal data in any of the following circumstances:
- You have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
- The processing of your personal data is unlawful and you request the restriction of the use of personal data instead of its erasure;
- We no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise or defence of legal claims; or
- Where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds.
Corrections or Erasure (Right to Rectification and Right to Be Forgotten)
If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at admin@dunhillgaasc.ie
Your Right to Object
You have the right to object to the processing of your personal data at any time:
- For direct marketing purposes
- For profiling to the extent it relates to direct marketing
- Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights, and freedoms or in connection with the enforcement or defence of a legal claim
To exercise your right to object at any time, please email admin@dunhillgaasc.ie. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
Personal Rights
The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned. If we receive any such request or communication directly from your customers and/or in relation to Your End Customer Data, we will refer the matter to you and cooperate in providing such reasonable assistance as may be required to enable you, as a controller, to respond to the matter. This will be described in more detailed in the Terms of Service or the other relevant contract between us
Disclosure to third parties
Personal data collected by Dunhillgaasc is held confidentially and is not shared by Dunhillgaasc with any third parties, with the following exceptions:
- Where the sharing of the personal data is necessary for the performance by Dunhillgaasc of its functions. This may arise, for example, in the context of complaints handling, where Dunhillgaasc will usually disclose the complainant’s identity and the subject matter of the complaint to the data controller or processor against whom the complaint is made. This is required both for practicality (because without disclosing the identity of the complainant in this manner, it will likely be impossible to investigate the complaint) as well as to ensure procedural fairness.
- For the purpose of legal proceedings. In the event that the matter or complaint in question is brought before the Courts (whether the Irish Courts, the Court in the Member State of any other data protection supervisory authority or the Court of Justice of the EU), the materials, including any information, documents or submissions provided by an individual, may be made public in open court.
- In the case of service providers or suppliers to Dunhillgaasc. Dunhillgaasc uses data processors to provide certain services to Dunhillgaasc. Dunhillgaasc requires such processors to abide by certain terms to protect any personal data which is processed by the service provider/supplier during the course of providing the service, in accordance with the requirements set out at Article 28(3) of the GDPR.
How Long Does Dunhillgaasc Retain Personal Data?
The retention periods for personal data held by Dunhillgaasc are based on the requirements of the data protection legislation set out above at Section 2 of this Data Protection Statement and on the purpose for which the personal data is collected and processed. For example, in the case of complaints, Dunhillgaasc will retain personal data (as contained on its case file) for as long as is necessary for the handling of the complaint and for any subsequent action that is required.
The retention periods applied by Dunhillgaasc to personal data which it processes are also, in certain circumstances, based on legal and regulatory requirements to retain information for a specified period and on the relevant limitation periods for taking legal action.
Your Data Protection Rights
Under data protection law, data subjects have certain rights.
Subject to certain restrictions, which are set out below, you can exercise these rights in relation to your personal data that is processed by Dunhillgaasc.
The data subject rights are:
- The right to be informed about the processing of your personal data;
- The right to access your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability;
- The right to object to processing of your personal data;
- The right to restrict processing of your personal data;
- Rights in relation to automated decision making, including profiling.
Restriction of data subject rights in certain circumstances
Article 23 of the GDPR allows for data subject rights to be restricted in certain circumstances. In addition, the 2018 Act contains certain provisions dealing with the restriction of rights of data subjects, in particular Sections 59, 60 and 61, which give further effect to the provisions of Article 23. General guidance in relation to the application of Article 23 and the related provisions of the Data Protection Act 2018 is available here.
Your Right To Complain
If you have any concerns in relation to the manner in which we process your personal data, you can contact us on admin@dunhillgaasc.ie
If you are dissatisfied with how we process your personal data, you have the right to complain to the Data Protection Commission.
Changes To Our Data Protection Statement
This Data Protection Statement is kept under regular review and is therefore subject to change.