Effective from: January 1st 2020
Database reviewed and updated: quarterly
Explore Inishowen CLG is proudly committed to complying with the Data Protection Acts 1988 and 2003 and SI 336 of 2011 EUROPEAN COMMUNITIES (ELECTRONIC COMMUNICATIONS NETWORKS AND SERVICES) (PRIVACY AND ELECTRONIC COMMUNICATIONS) REGULATIONS 2011 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) which replaces the previous data protection directive (officially Directive 95/46/EC) on May 25th 2018 (“Data Protection Legislation”).
This document consists of two main parts:
1.1.2 Explore Inishowen CLG is a non-profit organization. Our function is to market the peninsula of Inishowen in County Donegal overseas and locally as a tourist destination. A core part of our business is to facilitate efforts to promote and publicise tourism products and services. In order to provide the most effective and efficient service, we will be required to collect, process and use certain types of information about people and organisations. This may include ‘personal data’ as defined by the Data Protection Acts and by the general data protection Regulation (GDPR) and may relate to current, past and future service users; past; current and prospective employees; suppliers; and members of the public who may engage in communications with our staff. In addition, staff may be required, from time to time, to collect, process and use certain types of personal data to comply with regulatory or legislative requirements.
1.1.4 The Policy explains how we use any personal data we collect about you (either “user” or “service provider”) when you use the Website. This Policy is designed to protect you, our users, by informing you what personal data is collected, how we will use the information about you, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of your personal information. Your use of the Website and any micro-sites is subject to your agreement with this Policy. In this Policy, the term “personal data” or “personal information” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below). Please read the following carefully. Entering into this Website and providing your consent to our use of your personal data in accordance with the terms of this Policy indicates that the user has reviewed this Policy and has agreed to be bound by it. If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us via the ‘How to contact us’ section referred to below.
1.2 Types of Personal Data stored
1.2.1 Explore Inishowen CLG would typically retain and process two types of information: personal and non-personal data. Personal data is the data that identifies you or can be used to identify or contact you. Non-personal data can be used to contact you and comprises of cookies, statistics and analytical information
1.2.2 The following are types of Personal Data: Name, address, IP address, email address, phone number.
1.2.3 The following are types of Non-personal data: website traffic including location, cookies, demographic information, IP addresses, browser types and other anonymous statistical data.
1.3 Purpose of data collection
1.3.1 The non-personal data gathered from visitors to our website is used to get a better understanding of website traffic as well as to better design and organise our website.
1.3.2 This website may use “cookie” technology. A cookie is a little piece of text stored by the browser on your computer, at the request of our server. Cookies may be used to deliver specific information to the interests of users and to save personal preferences. No personal information is recorded, and the cookie can always be deleted or declined using browser setting. See more about our Cookies Policy on our website.
1.3.3 Personal Data
We will use any Personal Data provided to us for the following purposes: a) to list information about providers of tourist services; b) to contact those providers if required in connection to any communications; c) to send the Explore Inishowen CLG Newsletter/Event Alerts and to communicate with website users.
1.4 Data storage and processing
1.4.1 Processing means performing any operation or set of operations on data, including:
- obtaining, recording or keeping data;
- collecting, organising, storing;
- altering or adapting the data;
- retrieving, consulting or using the data;
- disclosing the information or data by transmitting, disseminating or
- otherwise making it available;
- aligning, combining, blocking, erasing or destroying the data.
1.4.2 All information provided to us is stored on our secure servers, featured on our website in the case of service providers and in the form of electronic databases.
1.4.3 Explore Inishowen CLG complies with the highest standards when collecting and using personal information. No personal information will be retained for longer than is necessary to fulfil a legitimate business need or as required by applicable law.
1.5 Right of access
1.5.1 Service providers listed on the Website may ask to see what personal data we hold about them and be provided with:
- a summary of such personal data and the categories of personal data held;
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers;
- details of the period for which it is held (or the criteria we use to determine how long it is held);
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- any information available about the source of that data;
- whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
- where your personal data are transferred out of the EEA, what safeguards are in place.
1.5.2 Requests for personal data must be made to us directly (see ‘How to contact us’ below) specifying what personal data you need access to, and a copy will be retained on your personal file.
1.5.3 If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
1.5.4 There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for
1.5.5 Access to the Explore Inishowen CLG’s computer systems is restricted as follows:
- Access only by authorized staff.
- Databases are password protected.
- There are comprehensive back up procedures in operation.
- In accordance with security obligations under the Data Protection Acts, our systems are regularly backed-up. Back-up data is data held specifically for the purpose of recreating a file in the event of the current data being destroyed. Back-up data will not ordinarily be provided in response to a Data Access Request.
1.6 Right to restrict or prevent data processing
1.6.1 In accordance with Data Protection Legislation, request can be made to stop processing personal data temporarily if:
- data is inaccurate (but we will start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful;
- objection has been made.
1.6.2 If the right to restrict us from data processing has been exercised, we will continue to process the data if:
- users and service providers consent to such processing;
- the processing is necessary for the exercise or defense of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons;
- the processing is necessary for public interest reasons.
1.7 Right to update or correct stored data
1.7.1 Website users and service providers listed can require us to correct any mistakes in your personal data which we hold free of charge. See ‘How can you contact us’ below;
- let us have enough information to identify you (e.g. name, registration details);
- let us know the information that is incorrect and what it should be replaced with. If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort. It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible.
1.8 Information which will not be provided
1.8.1 Explore Inishowen CLG will not normally disclose the following types of information in response to a Data Access Request:
(a) Information about other People
A Data Access Request may cover information which relates to one or more people other than the Data Subject. The information about the other person may be Personal Data about that person, to which the usual data protection rules under the Data Protection Acts, including the restrictions on disclosure, apply. In such circumstances we will not grant access to the information in question unless either: (i) the other person has consented to the disclosure of their data to the Data Subject or (ii) in all the circumstances it is reasonable to make the disclosure without that person’s consent. If the person’s consent is not forthcoming and it is not reasonable to make the disclosure without consent, we will make available as much Personal Data as we can without revealing the identity of the other person (for example by excluding the person’s name and/or other identifying particulars).
(b) Opinions given in Confidence
Where we hold Personal Data about the Data Subject in the form of an opinion given in confidence we are not required to disclose such opinions in response a Data Access Request in all cases.
(c) Repeat Requests
The Data Protection Acts provide an exception for repeat requests where an identical or similar request has been complied with in relation to the same Data Subject within a reasonable prior period. Explore Inishowen CLG will consider that if a further request is made within a period of six months of the original request and where there has been no significant change in the personal data held in relation to the individual, it will be treated as a repeat request. Accordingly, where Personal Data has recently been provided to the Data Subject or his/her legal representative, Explore Inishowen CLG will not normally provide a further copy of the same data in response to a Data Access Request. Explore Inishowen CLG will not consider that it is obliged to provide copies of documents that are in the public domain.
(d) Privileged Documents
Where a claim of privilege could be maintained in proceedings in a court in relation to communications between an individual and his or her professional legal advisers (or between those advisers) any privileged information which we hold need not be disclosed pursuant to a Data Access Request. Where Explore Inishowen CLG refuses a Data Access Request, it will do so in writing and will set out the reasons for refusal. Any person who is dissatisfied with the response of Explore Inishowen CLG to their request has the right to make a complaint to the Data Protection Commissioner.
1.9 Right to erasure
1.8.1 In accordance with Data Protection Legislation, request of data erase can be made in case that:
- user/ service provider does not believe that we need their personal data in order to process it for the purposes set out in this Policy;
- if user or service provider had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
- user or service provider objects to our processing and we do not have any legal basis for continuing to process your personal data;
- data has been processed unlawfully or have not been erased when it should have been; or
- the personal data must be erased to comply with law.
2.1 Twitter Policy
2.1.1 The @govisitinishowen tweets will cover developments in Explore Inishowen CLG and related services. If you follow us, you can expect tweets covering some or all of the following:
- Press Releases on Explore Inishowen CLG;
- Event information;
- Alerts about new content on our website;
- Other practical information relevant to tourism in County Donegal.
2.1.2 Twitter may occasionally be unavailable, and we accept no responsibility for this lack of service. Retweets may be used to highlight relevant appropriate announcements, particularly those by other Government bodies and neighbouring councils.
2.1.3 Normally our Twitter account will be updated and monitored during office hours, Monday to Friday. We welcome and will read all @ messages. However, in general, due to resource constraints, we will not be in a position to reply to all messages.
2.1.4 @govisitinishowen will not be obliged to follow any of our followers. If we do follow a Twitter account, it does not imply endorsement of any kind.
2.1.5 Sending a message via Twitter will not be considered as contacting for official purposes and we will not be obliged to monitor or respond to requests for information through the Twitter channel.
2.1.6 Please do not include personal/private information in your tweets to us. Explore Inishowen CLG is not responsible, liable for and does not endorse the privacy practices of twitter or any linked websites. Your use of Twitter and any linked websites is at your own risk.
2.1.7 Explore Inishowen CLG assume no responsibility or liability for any injury, loss or damage incurred as a result of any use or reliance upon the information and material contained within or downloaded from these websites.
2.2 Facebook and Instagram Policy
2.2.1 This policy outlines participation criteria for postings and published commentary on the Explore Inishowen CLG Facebook and Instagram page.
2.2.2 The Explore Inishowen CLG Facebook and Instagram page intends to provide information and updates regarding providers of the services related to tourism, public and social festival and events.
2.2.3 In order to ensure that all discussions on the Explore Inishowen CLG pages are productive, respectful, energized and consistent with our mission and goals, we ask you to follow these guidelines:
- Be considerate and respectful of others. Vulgarity, threats or abuse of language will not be tolerated;
- Differing opinions and discussion of diverse ideas are encouraged, but personal attacks on anyone, including staff, will not be permitted;
- Share freely and be generous but be aware of copyright laws; be accurate and give credit where credit is due;
- Stay on topic;
- Refrain from using the Facebook page for solicitation, for commercial purposes or to market products;
- The sites are not monitored 24/7 and we will not always be able to reply individually to all messages or comments received. However, we will endeavor to ensure that any emerging themes or helpful suggestions are passed to the relevant people.
2.2.4 Sending a message/post via Facebook or Instagram will not be considered as contacting us for official purposes and we will not be obliged to monitor or respond to requests for information through the Facebook/Instagram channel.
2.2.5 We retain the right to remove comments or content that includes:
- Obscene or racist content;
- Personal attacks, insults, or threatening language;
- Potentially libelous statements;
- Plagiarised material; any material in violation of any laws, including copyright;
- Private, personal information published without consent;
- Information or links unrelated to the content of the forum;
- Commercial promotions or spam.
2.2.6 Explore Inishowen CLG is not responsible for the accuracy of content posted by any subscriber in any forum; opinions expressed in comments on Explore Inishowen CLG social media forums do not necessarily represent those of Explore Inishowen CLG.
2.2.7 All comments, once posted, become the property of Explore Inishowen CLG and we reserve the right to reproduce, distribute, publish, display or edit same. Derivative work also can be created from such postings or content, and used for any purpose, in any form and on any media.
How to contact us:
Tel: 00 353 74 93 63451
Explore Inishowen CLG, Railway Road, Buncrana, Co. Donegal, Ireland