Privacy Notice for Clients, Business Contacts and Website
Austin Kenny takes his responsibilities under applicable data protection law, including the General Data Protection Regulation (EU) 2016/679 and implementing legislation
(“Data Protection Law”) very seriously. The purpose of this notice is to inform you of the data relating to you that I may collect and use and the uses (including disclosures to third parties) I may make of your data, which includes the provision of mediation and business consultancy services.
Austin Kenny is the controller in respect of the data I collect and I take all reasonable steps to ensure the safety and privacy of all information and, where appropriate, enter into contracts with any third party processors to protect the privacy of any personal data processed by me.
This notice also sets out details of my processing of personal data in connection with your use of this website.
I am not responsible for the content or privacy practices of any linked sites.
- What information do I collect
I collect personal data that you voluntarily provide to me, for example when you communicate with me via email or normal mail. Such data may include:
1.1 your name, job title and name of employer and any personal data you send to us to provide you with my services;
1.2 your contact details, including your home address (where you have provided this to us), business address, email address and telephone number;
1.3 records of invitations and briefings sent to you and of your attendance at mediation meetings;
1.4 on occasions where public health concerns warrant it, and you are attending an event hosted or organised by me, information about your exposure to particular diseases and viruses; and
1.5 information relating to particular areas that may be of interest to you.
If I am in regular contact with you I may collect more information about my relationship with you.
- Purpose of processing and legal bases
Your personal data is used by me and by third party service providers acting on my behalf for the following purposes:
2.1 providing you with mediation and business consultancy services;
2.2 for administration and billing purposes and for other purposes which are reasonably incidental to the services being provided;
2.3 maintaining our list of contacts; and
2.4 safeguarding the health and safety of my personnel, visitors to my offices and of attendees at events hosted or organised by me.
The legal bases on which I collect, process and transfer your information in the manner described above are:
(a) For 2.1 and 2.2
(i) your consent (where I have sought it and you have provided it to me), and in which case, you can withdraw your consent at any time;
(ii) where any such processing is necessary for the performance of a contract with us; and
(iii) our legitimate interests in conducting our business in a responsible and commercially prudent manner.
(b) For 2.3 and 2.4
(i) My legitimate interest in maintaining a business relationship and communicating with you, as a business contact, about events and providing you with information about new developments.
(c) For 2.5
(i) your consent to my use of your health data for the purposes described above.
We may process special categories of data, such as accommodating any special dietary requirements you may have for any events that you attend. Any use of such information is based on your consent.
- Sources of data
As well as collecting information from you or other professional services advisors, in some cases your personal data has been supplemented by information obtained from publicly available sources, including LinkedIn and your employer’s website, for the purpose of confirming your current professional position.
- Sharing your data
We may disclose your personal data to third party recipients acting on your or my behalf, for the purposes of providing mediation and business consultancy services to you and for providing you with information which I believe you may be interested in.
We will retain your personal data for as long as it is reasonably necessary for us to provide you with mediation and business consultancy services. If you are a business contact, I will retain your personal data for as long as i consider you to be a business contact and I will give you the opportunity to unsubscribe if you no longer wish to receive communications and invitations from me.
- Security measures to keep your personal data safe
I employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. I carry out risk assessments on all third party service providers to make sure the personal data they hold is secure. I regularly review my security policies and procedures to ensure my systems are secure and protected.
- Necessity of provision of certain information and consequences
You may be required to provide me with certain information in order for me to verify your identify and carry out anti-money laundering or other checks which are required by law. This information consists of identification and verification documentation for individuals. If you do not provide me with such information, I may be unable to provide you with my services.
Apart from the details mentioned above, you are not under a statutory or contractual duty to provide me with any personal data. However, there may be some pieces of information that you need to provide to me so that we can provide you with my services. I will notify you of any such required information. If you do not provide me with this information, I may not be in a position to provide my services to you.
- Transfers abroad
Where relevant and necessary for the fulfilment of my services to you, I may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that I do so, I will ensure that appropriate measures are in place to comply with my obligations under applicable law governing such transfers, which may include (i) entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or (ii) seeking and obtaining your explicit consent to the transfer.
- Your rights and how to update your information
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:
9.1 the right to be provided with a copy of your personal data;
9.2 the right to request the rectification and/or erasure of your personal data;
9.3 the right to restrict the use of your personal data;
9.4 the right to object to the processing of your personal data, where I am processing it based on this being necessary for the purposes of my or of a third party’s, legitimate interests; and
9.5 the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller, where we are processing the data based on your consent or that this is necessary for the performance of a contract with you.
In order to exercise any of the rights set out above, or if you have any questions about how we process your personal data, you can email me at email@example.com . Please note that the limitation or deletion of your personal data may mean that I will be unable to provide you with the communications and/or invitations described above.
I am required to keep all personal data accurate and up to date. To assist me in doing so, I ask you to email me at firstname.lastname@example.org with any relevant changes, such as change of address or contact telephone numbers.
I take a high level of care in how your personal data is handled to ensure that it is safeguarded and our legal obligations are met. If you are not happy with the way I have used your information or addressed your rights, you may contact me at email@example.com. You also have the right to make a complaint to the Irish Data Protection Commission by emailing firstname.lastname@example.org.