KDYS

Privacy Notice

Who we are

This privacy notice applies to all personal data processing activities carried out by Kerry Diocesan Youth Service (KDYS).

KDYS is a company limited by guarantee and is also a registered charity. KDYS is a data controller in respect of personal data that we process in connection with our business and the services we provide. In this notice, references to “we”, “us”, “our” or “the organisation” are references to KDYS.  Our principle address is KDYS, Fair Hill. Killarney, Co. Kerry V93 WOFH, Tel: 064 6631748

We respect individual’s rights to privacy and the protection of personal data. The purpose of this Privacy Notice is to clarify how we collect and use personal data in relation with our service.

Personal Data” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).

We may update our Privacy Notice from time to time by publishing the updated Privacy Notice on our website (www.kdys.ie).

The Information We Process

We collect and process various categories of personal data at the start of and for the duration of your relationship with us. We will limit the collection and processing of data to data necessary to achieve one or more legitimate purposes as identified in this notice. Personal data may include:

  • Basic personal information including name and address, date of birth and contact details;
  • Your Personal Public Service Number (PPSN)
  • Financial information including bank account details
  • Information about your family (such as dependents, marital status, next of kin and contact details)
  • Education and employment details
  • Visual images (such as copies of passports or CCTV images); and
  • We may also process certain special categories of information for specific and limited purposes such as detecting and preventing child safeguarding issues. We will only process special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the specific purpose and activities set out in KDYS Data Schedule and Retention List for which the information is provided). This may include:
  • Information about racial or ethnic origin
  • Religious or philosophical beliefs
  • Trade union membership
  • Physical or psychological health details or medical conditions

Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes such as to perform checks to prevent and detect child safeguarding issues and to comply with laws relating to child safeguarding. It may involve sharing information between Tusla and law enforcement agencies

How we obtain personal data?

Your personal data is made up of all the data we collect and hold about you. It includes:

  • Information you give to us
  • Information we receive from third parties (for example, referral for a young person or family to access a KDYS service)
  • Information we learn about you through our relationship with you
  • Information that we gather from publicly available sources (such as the press, online search engines)

Your Rights

We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table below.

If you wish to exercise any of these rights, or if you have queries about we use your personal information which are not answered here please contact our Data Compliance Officer at dataprotection@kdys.ie.

Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue our relationship with you.

 Rights Description
Access – You have a right to get access to the personal information we hold about you If you would like a copy of the personal information we hold about you please complete a Data Subject Access Request Form or email dataprotection@kdys.ie
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information

If you believe that any of the information we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.

Please note that if you request us to restrict processing your information, we may have to suspend involvement in the organisation and/or the services we provide to you.

Erasure – You have a right to request that we delete your personal information

You may request that we delete your personal information if you believe that:

o   We no longer need to process your information for the purposes for which is was provided

o   We are not using your information in a lawful manner

Please note that the right to erasure is subject to certain exemptions. Also, if you request us to delete your information we may have to suspend involvement in the organisation and/or the services we provide to you.

Restriction – You have the right to request us to restrict the processing of your personal information

You may request us to restrict the processing of your personal information if you believe that:

o   Any of the information that we hold about you is inaccurate

o   We no longer need to process your information for the purpose for which it was provided, but you require the information to establish, exercise or defend legal claims or

o   We are not using your information in a lawful manner.

Please note the right to restriction is subject to certain exemptions.

Also, if you request us to restrict processing your information we may have to suspend involvement in the organisation and/or the services we provide to you.

Portability – You have a right to data portability

Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal information you provided to us in a portable format (subject to certain exemptions).

You may also ask us to provide it to a third party, if technically feasible. We’re not responsible for any such third party’s use of your information, which will be governed by their agreement with you and any privacy statement they provide to you.

Objection – You have the right to object to the processing of your personal information

You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in KDYS Data Schedule and Retention List, unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests of where we need to process your information to investigate and protect us or others from legal claims.

Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information.

Please note the right to restriction is subject to certain exemptions.

Also, if you object to us processing your personal information we may have to suspend involvement in the organisation and/or the services we provide to you.

Marketing – You have a right to object to direct marketing You have a right to object at any time to processing of your personal information for direct marketing purposes
Withdraw Consent – You have a right to withdraw your consent Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
Lodge Complaints – You have a right to lodge a complaint with us or with the Data Protection Commissioner

If you wish to raise a complaint in relation to how we handled your personal information, please contact us in any of the following ways:

In person – speak to any KDYS employee

In writing – address your letter to Complaints Manager, KDYS, Fair Hill, Killarney, Co Kerry or email complaintsmanager@kdys.ie

You have the right to complain to the Data Protection Commissioner.

You can contact the Data Protection Commissioner at, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois. Phone: +353 (0) 761 104 800; LoCall 1890 25 22 31; email: info@dataprotection.ie. For more information, visit www.dataprotection.ie

Changes to the way we use your information

From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow you a period of at least 30 days for you to raise any objections before that change is made. However, please note that in some cases, if you do not agree to such changes if may not be possible for you to continue to be involved in the organisation or for us to continue to provide certain services to you.

How we use and share your information within KDYS

We will only use and share your information where it is necessary for us to carry out our business activities.  We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in KDYS Data Schedule and Retention List.

How we use and share your information with Joint Controllers

In some cases KDYS is obliged under its funding obligations to share data with a Joint Controller, in these instances you will be informed of this.

Sharing with third parties

We will not share your information with anyone outside KDYS except:

  • Where we have your permission
  • Where required for your service
  • Where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies
  • With third parties providing services to us such as agents and sub-contractors acting on our behalf such as the company providing the online affiliation system
  • In anonymised form as part of statistics or other aggregated data shared with third parties; or
  • Where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

KDYS will not share your information with third parties for their own marketing purposes.

Transferring Information Overseas

We may transfer your information to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way and in accordance with applicable laws.

In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway) we will only do so where:

  • The European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately
  • The transfer has been authorised by the relevant data protection authority; and/or we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected.
  • The transfer of said data is authorised by the data subject.

Marketing Information

Subject to the marketing preferences you have indicated to us, we may send you relevant marketing information (including details of other services provided by KDYS which we believe may be of interest to you) by mail, phone, email, text and other forms of electronic communication.

If you change your mind about how you would like us to contact you or you no longer wish to receive this information you can tell us at any time by contacting dataprotection@kdys.ie

Communications about your involvement with KDYS

We will contact you with information relevant to your involvement in KDYS by a variety of means including email, text message, post and/or telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.  We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes of processing outlined in the KDYS Data Schedule and Retention List

How long we keep your information

Through your involvement in KDYS we create records that contain your information. Personal data records are stored on various media (automated and manual data).

We manage our records to help serve those involved with KDYS well and to comply with legal and regulatory requirements. Records help demonstrate that we are meeting our responsibilities and to keep as evidence of our activities.

The determination of the retention periods of these records is based on the type of record, the nature of the activity or service and the applicable legal and regulatory requirements.

We may on exception retain your information for longer periods particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators.

Some Personal Information (name, address, date of birth, name of club/group and period of involvement) of young people, volunteers and employees may be retained indefinitely to comply with Child Safeguarding requirements. This is intended to make sure that we will be able to produce records as evidence as needed.

This notice was last reviewed on 1st March 2022.