How we Process and use your Personal Data

 

Your data may be used by us for the following purposes:

1. providing the service to client organisations of ‘recipient’ or ‘confidential recipient’ on their behalf of disclosures of alleged work-related wrongdoing, whether under the Protected Disclosures Act 2014 or otherwise;

2.  relaying information to Client Organisations in relation to disclosures made to us.  We will not, however, provide the personal data of a Discloser to a Client Organisation (i) without the Discloser’s consent; (ii) unless we are obliged to do so by law or (iii) unless we are obliged to do so by court order;

3.  contacting you in relation to disclosure(s) made by you, or (if you so request) in relation to our services or in order to provide you with guidance about making or dealing with a disclosure in relation to alleged wrongdoing or information about our services generally;

4.  providing the service to client organisations of investigation of allegations of work related or other wrongdoing;

5.  contacting you if we are requested by a client organisation to carry out an investigation of  alleged wrongdoing and we have been provided with confirmation that you have been advised by the party employing us to conduct the workplace investigation, or on their behalf, that you have been named as the person who made the complaint of alleged wrongdoing (‘Complainant’); as a person required to respond to a complaint of alleged wrongdoing (‘Respondent’); are a possible witness to alleged wrongdoing (‘Witness’) or a person who may be in a position to provide information or expert information in relation to a complaint of alleged wrongdoing (‘Expert Witness’);

6.  contacting you if we are requested to carry out an investigation of alleged wrongdoing and we have been provided with your name by a Complainant or Respondent as a possible Witness or Expert Witness to a complaint of alleged wrongdoing;

7.  systems testing, system maintenance and development, research or in order to deal with a dispute or claim. We may perform data profiling based on the data we collect from you for the purpose of statistical analysis.  We will only use this information in aggregate format and in a manner that does not identify you.  We may report suitably anonymised information to Client Organisations to meet their internal reporting (e.g. Board or Management reporting) or external reporting (e.g. under Section 22 Protected Disclosures Act 2014) requirements, or for comparative purposes;

8. reporting your personal data to regulatory or law enforcement agencies where required to do so by regulation or law.  We will also report your personal data to the courts where required to do so by court order;

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data.

THE LEGAL GROUNDS WE USE FOR PROCESSING PERSONAL DATA

We are required by law to set out in this privacy policy the legal grounds on which we may rely in order to process your personal data. We rely on one or more of the following lawful grounds:

  • you have explicitly agreed to us processing your information for a specific purpose;

  • the processing is necessary to perform the agreement we have with a client organisation or to take steps to enter into an agreement with a client organisation;

  • the processing is necessary for compliance with a legal and/or regulatory obligation we have;

  • to protect your vital interests or those of another person (e.g. in case of a concern about public safety);

  • the processing is necessary for the purposes of a legitimate interest pursued by us, which might include the following:​

            - provision of our services to our clients, to you or to third parties and to ensure that our contracts with 

              client organisations are fulfilled:

            - to prevent fraud or fraudulent misrepresentation;

            - to protect our business interests;

            - to ensure that complaints and complaints of alleged wrongdoing are fully and properly investigated;

            - to evaluate, develop or improve our services and products.

       - to keep you or our clients informed about relevant products and services and to provide you with                         

               information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined within this privacy policy, including our General and Website Terms and Conditions, we will do so because:

  • you have given us explicit consent to process that data;

  • a client organisation has given us explicit consent to process that data and is duly permitted or authorised to do so;

  • we are required by law to process that data in order to ensure we meet legal or regulatory obligations imposed on us;

  • the processing is necessary for the establishment, exercise or defence of legal claims;

  • you have made the data manifestly public.

In certain circumstances, it may still be lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

This project has been supported by Kildare Local Enterprise Office which is co-funded by the Irish Government and the European Union under Ireland's EU Structural Funds Programmes 2007 - 2013.