Privacy Statement - Cunneen Locksmiths

1. General Data Protection Regulation (“GDPR”)

Upon the implementation of the GDPR on 25 May 2018, CUNNEEN PREMIER LOCKSMITHS has updated the way they use and collect personal data from residents in the EU. This involves, identifying CUNNEEN PREMIER LOCKSMITHS data protection officer (“Privacy Officer”), how clients can contact the Privacy Officer and identifying the process of transferring client’s personal information. Further, the implementation of cookies notices on CUNNEEN PREMIER LOCKSMITHS website has been activated to ensure CUNNEEN PREMIER LOCKSMITHS clients have adequate protection in providing consent to CUNNEEN PREMIER LOCKSMITHS in withholding their personal data.

2. Types Of Personal Information That Is Collected, Used, Processed & Held

CUNNEEN PREMIER LOCKSMITHS collects personal information for a variety of reasons. This personal information will be collected in the normal course of business and will relate to Goods and/or Services that are provided by CUNNEEN PREMIER LOCKSMITHS to clients. This information collected will be done so in the course of business where the client is a customer of CUNNEEN PREMIER LOCKSMITHS or when the client acts as a guarantor for another person or company that is a client of CUNNEEN PREMIER LOCKSMITHS. CUNNEEN PREMIER LOCKSMITHS will not collect information that is not relevant or sensitive in nature unless it is required in the normal course of business.

The personal information that is collected may include, but will not be limited to the following;

Full name
Address
Date of birth
Credit references if applicable
Publicly available information which relate to the clients activities
Driver’s license details
Medical insurance details (if applicable)
Electronic contact details including email, Facebook and Twitter details
Next of kin and other contact information where applicable

The client acknowledges that provided the correct Privacy Act disclosures have been made that CUNNEEN PREMIER LOCKSMITHS may conduct a credit report on the client for the purposes of evaluating the credit worthiness of the client.

CUNNEEN PREMIER LOCKSMITHS ensures that all personal information is held in a secure manner. Where applicable and to the best of CUNNEEN PREMIER LOCKSMITHS knowledge all computers or servers have the required security protections in place to safeguard and protect any personal information that is held by CUNNEEN PREMIER LOCKSMITHS.

We use cookies on our website. Cookies are small files which are stored on your computer. They are designed to hold a modest amount of data (including personal information) specific to a particular client and website, and can be accessed either by the web server or the client’s computer. In so far as those cookies are not strictly necessary for the provision of CUNNEEN PREMIER LOCKSMITHS Services, we will ask you to consent to our use of cookies when you first visit our website.

In the event that you utilise our website for the purpose of purchases/orders, CUNNEEN PREMIER LOCKSMITHS agrees to display reference to cookies and /or similar tracking technologies, such as pixels and web beacons (if applicable), and requests consent for CUNNEEN PREMIER LOCKSMITHS collecting your personal information which may include:

IP address, browser, email client type and other similar details;
Tracking website usage and traffic; and
Reports are available to CUNNEEN PREMIER LOCKSMITHS when CUNNEEN PREMIER LOCKSMITHS sends an email to the client, so CUNNEEN PREMIER LOCKSMITHS may collect and review that information

If you consent to CUNNEEN PREMIER LOCKSMITHS use of cookies on our website and later wish to withdraw your consent, you may manage and control CUNNEEN PREMIER LOCKSMITHS privacy controls through your browser, including removing cookies by deleting them from your browser history when you leave the site.

CUNNEEN PREMIER LOCKSMITHS also regularly conducts internal risk management reviews to ensure that its infrastructure (to the best of its knowledge) is secure and any identifiable risks have been mitigated as much as they can be in the normal course of business.

3. Procedures And Responding To Potential Breaches Of Privacy

In accordance with the Act CUNNEEN PREMIER LOCKSMITHS is aware of its responsibilities to notify its clients in the event of a potential data breach that may cause serious harm to clients. Further, in the event the client is located in the EU, CUNNEEN PREMIER LOCKSMITHS acknowledges that any potential data breaches will be safeguarded by the provisions of the GDPR.

CUNNEEN PREMIER LOCKSMITHS will collect and process personal information in the normal course of business. This personal information may be collected and processed (but is not limited to) by any of the following methods;

Credit applications forms
Work authorisation forms, quote forms or any other business documentation
Publicly available databases that hold information
Websites that detail information such as Sensis, Facebook, Google etc
By verbally asking you for information as part of normal business practices

Where relevant to data processing as per the GDPR, and in particular where CUNNEEN PREMIER LOCKSMITHS uses new technologies, and takes into account the nature, scope, context and purposes of processing and considers that the data processing is likely to result in a high risk to the rights and freedoms of natural persons, the Privacy Officer shall, prior to the processing of personal information, carry out an assessment of impact of the envisaged processing operations by way of a protection impact assessment. The data protection assessment will be required in instances whereby:

a systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person;
processing on a large scale of special categories of data referred to in Article 9(1) of the GDPR, or of personal data relating to criminal convictions and offences referred to in Article 10 of the GDPR; or
a systematic monitoring of a publicly accessible area on a large scale.

The assessment shall be carried out in accordance with Article 35 (7) of the GDPR and carry out reviews of such data protection impact assessments when there is any change of the risk associated with the processing of personal information.

As a client of CUNNEEN PREMIER LOCKSMITHS and agreeing to CUNNEEN PREMIER LOCKSMITHS Terms and Conditions of Trade, which includes of CUNNEEN PREMIER LOCKSMITHS privacy policy you hereby agree and consent to the provisions of this Privacy Policy Manual, including but not limited to the collection, processing, use and disclosure of your personal information. In the event that you withdraw your agreement and consent to any of the above use, processing collection and disclosure, then CUNNEEN PREMIER LOCKSMITHS warrants that any request by you to withdraw your consent or agreement shall be deemed as confirmation by you to cease any and/or all collection use, processing and disclosure of your personal information. You may make a Request to withdraw your consent at any time by telephone and/or by e-mail to the following contact details;The Privacy Officer

CUNNEEN PREMIER LOCKSMITHS will ensure that any Information that is to be obtained from you is done so verbally or by using CUNNEEN PREMIER LOCKSMITHS prescribed forms which;

Authorise CUNNEEN PREMIER LOCKSMITHS:

To collect personal information; and
Inform the individual what personal information is being collected; and
Inform the individual why (the purpose) the personal information is being collected; and
Inform the individual why & when personal information will be disclosed to 3 rd parties.

It is the responsibility of CUNNEEN PREMIER LOCKSMITHS to ensure that any personal information obtained is as accurate and up to date as possible and information is only collected by lawful means in accordance with the Act and relevantly, in accordance with the GDPR.

4. Purposes For Which Information Is Collected, Held, Used And Disclosed

Disclosure To Third Parties

CUNNEEN PREMIER LOCKSMITHS will not pass on your personal information to third parties without first obtaining your consent, unless such information is required for the provision of the supply of Goods and Services via any of the associated Franchisees of CUNNEEN PREMIER LOCKSMITHS outside of the Client’s present location.

In accordance with the Act, including the GDPR (where relevant), personal information can only be used by CUNNEEN PREMIER LOCKSMITHS for the following purposes:

Access a credit reporter’s database for the following purposes:
1. To assess your application for a credit account; or
2. To assess your ongoing credit facility; or
3. To notify a credit reporter of a default by you; or
4. To update your details listed on a credit reporter’s database; or
Check trade references noted on the prescribed form for the following purposes:
1. To assess your application for a credit account; or
2. To assess your ongoing credit facility; or
3. To notify a default.
Marketing products and Services provided by CUNNEEN PREMIER LOCKSMITHS; and
Any other day to day business purposes such as complying with IRD requirements, managing accounting returns or legal matters.

Relationship With Credit Reporter – In the event that notification of a default has been reported to a Credit Reporter and your credit file has been updated (including any changes to the balance outstanding or contact details), then the Credit Reporter shall be notified as soon as practical of any such changes.

CUNNEEN PREMIER LOCKSMITHS will only gather information for its particular purpose (primary purpose). In accordance with the Act, including the GDPR (where relevant) CUNNEEN PREMIER LOCKSMITHS will not disclose this information for any other purpose unless this has been agreed to by both parties.

5. How An Individual May Access Personal Information Held, And How They May Seek Correction Of Such Information

You shall have the right to request from CUNNEEN PREMIER LOCKSMITHS a copy of all the information about you that is retained by CUNNEEN PREMIER LOCKSMITHS. You also have the right to request (by telephone and/or by e-mail) that CUNNEEN PREMIER LOCKSMITHS, including (where relevant) any third party associated Franchises trading under the trademark of “CUNNEEN PREMIER LOCKSMITHS” that such information is corrected that is incorrect, outdated or inaccurate.

Any requests to receive your personal information or to correct personal information should be directed to the following contact details;The Privacy Officer
CUNNEEN PREMIER LOCKSMITHS
Please refer to the relevant Franchise for the contact details on the link provided below: https://cunneenlocksmiths.ie/

CUNNEEN PREMIER LOCKSMITHS will destroy personal information upon your request (by telephone and/or by e-mail) or when the personal information is no longer required. The exception to this is if the personal information is required in order for CUNNEEN PREMIER LOCKSMITHS to fulfil their performance of Services or is required to be maintained and/or stored in accordance with the law.

6. How An Individual May Complain About A Breach Of The GDPR, And How The Complaint Will Be Dealt With

You can make a complaint to CUNNEEN PREMIER LOCKSMITHS internal dispute resolution team (‘IDR’) regarding an interference with and/or misuse of your personal information by contacting CUNNEEN PREMIER LOCKSMITHS via telephone or e-mail.

Any complaints should be directed to the following contact details in the first instance;The Privacy Officer
CUNNEEN PREMIER LOCKSMITHS
Please refer to the relevant Franchise for the contact details on the link provided below: https://cunneenlocksmiths.ie/

In your communication you should detail to CUNNEEN PREMIER LOCKSMITHS the nature of your complaint and how you would like CUNNEEN PREMIER LOCKSMITHS to rectify your complaint.

We will respond to that complaint within 7 days of receipt and will take all reasonable steps to make a decision as to the complaint within 30 days of receipt of the complaint.

We will disclose information in relation to the complaint to any relevant credit provider and or Credit Reporting Body that holds the personal information the subject of the complaint.

In the event that you are not satisfied with the resolution provided, then you can make a complaint to the Privacy Commissioner.

7. Will Personal Information Be Disclosed To Overseas Recipients

CUNNEEN PREMIER LOCKSMITHS (including any third party associated Franchises trading under the trademark of “CUNNEEN PREMIER LOCKSMITHS”) shall not disclose information about the client to third party overseas recipients unless the client has provided its consent. CUNNEEN PREMIER LOCKSMITHS will notify you if circumstances change regarding overseas disclosure and will comply with the Act and the GDPR in all respects.

Unless otherwise agreed, CUNNEEN PREMIER LOCKSMITHS agrees not to disclose any personal information about the client for the purpose of direct marketing. You have the right to request (by telephone and/or by e-mail) that CUNNEEN PREMIER LOCKSMITHS does not disclose any personal information about you for the purpose of direct marketing.

11. Privacy Officer (Responsibilities)

CUNNEEN PREMIER LOCKSMITHS has appointed an internal Privacy Officer to manage its privacy matters. The name of this officer is available by making contact with CUNNEEN PREMIER LOCKSMITHS. The privacy officers duties include (but are not limited to) the following:

The Privacy Officer needs to be familiar with the GDPR. Educational material is available from the office of the Privacy Commissioner which explains what CUNNEEN PREMIER LOCKSMITHS needs to know in order to comply with the Privacy Act.

If a person complains to the Privacy Commissioner thatCUNNEEN PREMIER LOCKSMITHS has breached their privacy, the Privacy Commissioner may contact the Privacy Officer to discuss the complaint, and to see whether there is any means of settling the matter. The Privacy Officer shall provide whatever assistance is necessary. The Privacy Officer may be asked to provide background information or identify the staff members who can do so.

Complaints

In the event that a complaint about privacy issues is received the Privacy Officer will:

Take ownership of the complaint and ensure that it is dealt with in a timely manner.
Acknowledge receipt of the complaint within 24 hours and advise the complainant of their rights.
Fully investigate the complaint.
Respond, with findings, to the complainant within 20 days of receipt.
Keep a record of all complaints received for ongoing review of policies and procedures.

In the event that a complaint about privacy issues is received via a credit reporter the Privacy Officer will:

Take ownership of the complaint and ensure that it is dealt with in a timely manner.
Acknowledge receipt of the complaint to the credit reporter within 24 hours .
Fully investigate the complaint.
Respond, with findings, to the credit reporter within 7 days of receipt.
Keep a record of all complaints received for ongoing review of policies and procedures.

Other

The Privacy Officer shall ensure that CUNNEEN PREMIER LOCKSMITHS documentation complies with the Privacy Act and Credit Reporting Privacy Code at all times.