PRIVACY POLICY

Who we are:

A&L CASTORS Ltd. t/a PARNELLS

Unit A1/A2 Southcity Business Centre

Whitestown Way

Tallaght, D24 HT95, Ireland

• Tel: +353 1 452 0482
• Fax: +353 1 451 0778
• Email: info@parnells.eu

Richard Parnell.

Where do we process personal data:

A&L CASTORS Ltd. t/a PARNELLS stores and process personal data in Ireland.

Purpose of the processing:

A&L CASTORS Ltd. t/a PARNELLS process personal data for the following purpose(s):

• Client administration

• Direct Marketing

• Provision of goods or services

• Legal obligations

• Employee administration

• Monitoring (e.g. CCTV, web history, Apps, Cookies)

• Profiling of personal data

• Processing for a third party

The legal basis for this processing is:

• Consent

• Legitimate interests relevant and due to the running of day to day business

• Performance of a contract including possible consequences of failing to provide the personal data

• Legal obligation outlined in the section labelled Data Retention periods, including possible consequences of failing to provide the personal data

• To protect the vital interests of the data subject

Recipient(s) of the personal data:

Recipient of Customer/Supplier data:

• – Odoo Advantage Limited

Odoo Advantage Limited is providing specialist IT Services to clients around the world since the year 2000. We are the approved IT services to Parnells in the areas of Finance, Manufacturing, and Procedural functions including database storage and maintenance.

The Odoo privacy policy is available here: https://www.odoo.com/page/odoo-privacy-policy

And/or

• – ROCG

ROCG are Ireland’s leading management and financial services consultancy firm dedicated to working with family and privately owned SMEs. ROCG offer a unique blend of strategic, financial and operational advice to businesses and their owners in the SME sector. ROCG enjoy close working relationships with our clients, who consider us essential to their business success.

http://rocg.com/privacy/

And/or

• – New Wave Computer Services Ltd

NEW WAVE COMPUTER SERVICES WAS SET UP IN 1998 AS A TECHNICAL SERVICES PROVIDER, PROVIDING LOCAL AND NATIONWIDE COMPANIES WITH IT AND MAINTENANCE SERVICES. OUR MAIN FOCUS IS ON TECHNICAL CONSULTANCY AND SPECIALISED COMPUTER MAINTENANCE SERVICES.

And/or

• –eBay

eBay Inc. is a multinational e-commerce corporation that facilitates consumer-to-consumer and business-to-consumer sales through its website.

https://www.ebayinc.com/our-company/privacy-center/

https://www.ebayinc.com/privacy-policy/

And/or

• – Amazon

Amazon.com, Inc., doing business as Amazon, is an American electronic commerce and cloud computing .

https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=502584

HTTPS://AWS.AMAZON.COM/BLOGS/SECURITY/AWS-AND-THE-GENERAL-DATA-PROTECTION-REGULATION/

HTTPS://AWS.AMAZON.COM/COMPLIANCE/GDPR-CENTER/

And/or

• – Campaign Monitor

We use Campaign Monitor to disseminate our monthly newsletter. This is a third-party service and you will have signed up for the monthly newsletter via a form on our website, which will have passed your name and e-mail address to Campaign Monitor via a secure channel. By virtue of them storing your Personal Data, Campaign Monitor are therefore considered a Data Processor.

The Campaign Monitor privacy policy is available here: https://www.campaignmonitor.com/policies/

Recipient of Employees data:

• – Odoo Advantage Limited

Odoo Advantage Limited is providing specialist IT Services to clients around the world since the year 2000. We are the approved IT services to Parnells in the areas of Finance, Manufacturing, and Procedural functions including database storage and maintenance.

The Odoo privacy policy is available here: https://www.odoo.com/page/odoo-privacy-policy

And/or

• – ROCG

ROCG are Ireland’s leading management and financial services consultancy firm dedicated to working with family and privately owned SMEs. ROCG offer a unique blend of strategic, financial and operational advice to businesses and their owners in the SME sector. ROCG enjoy close working relationships with our clients, who consider us essential to their business success.

http://rocg.com/privacy/

And/or

• – New Wave Computer Services Ltd

NEW WAVE COMPUTER SERVICES WAS SET UP IN 1998 AS A TECHNICAL SERVICES PROVIDER, PROVIDING LOCAL AND NATIONWIDE COMPANIES WITH IT AND MAINTENANCE SERVICES. OUR MAIN FOCUS IS ON TECHNICAL CONSULTANCY AND SPECIALISED COMPUTER MAINTENANCE SERVICES.

And/or

• – Peninsula

Peninsula has been providing professional services to small businesses offering them expert support and guidance that helps them manage their legal requirements, without the extensive overheads of directly employing skilled professionals. Peninsula integrates seamlessly with company’s internal HR, Health & Safety and Legal departments, or as their dedicated, sole provider for the above.

• HR tool: Hronline/ BrightHR are a cloud-based Human Resource service Peninsula use that provides business with an easy way to arrange their day-to-day HR needs.

The Peninsula privacy policy is available here: https://www.peninsulagrouplimited.com/ie/privacy-policy/

https://www.brighthr.com/terms

And/or

• – Payback

Payback software is used by payroll bureaux and accountants across Ireland. Their payroll software is designed for the Irish market. All types and sizes of business across Ireland use Payback payroll software to process the payments for their employees.

http://www.payback.ie/privacy-policy/

Data Retention period:

A&L CASTORS Ltd. t/a PARNELLS retain data only for the length of time necessary to provide services to customers, engage in marketing activities, and other legitimate purposes of the business.

A&L CASTORS Ltd. t/a PARNELLS will be retaining customer marketing information for a further year after the last purchase for marketing activity and after that only the relevant information will be retained after that for tax and revenue purposes.

The customer information that is relevant for tax and revenue needs will be kept for 7 years due to legislation and regulatory rules set out by revenue.

Your rights:

You have the following rights in respect to the personal data that A&L CASTORS Ltd. t/a PARNELLS hold on you. Please contact us at the address above in order to exercise any of these rights:
1. The right to be informed
You have the right to receive “fair processing information”.
2. The right of access
You have the right to obtain:
• Confirmation of your personal data being processed
• Access to a copy of your personal data
• And any other supplementary information
3. The right to rectification
You have the right to have your personal data corrected if it is inaccurate or incomplete
4. The right to erasure (includes withdrawal of consent)
You have the right to have your personal data erased, in the following circumstances:
• You withdraw consent.
• The personal data has to be deleted to comply with a legal obligation.
• The personal data was unlawfully processed.
• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected.
• Where you object to the processing and there is no superseding legitimate requirement to continue the processing.
• The personal data is processed in relation to the offer of “information society services” to a child.
5. The right to restrict processing
You have the right to ‘block’ or suppress processing of personal data
6. The right to data portability
You have the right to obtain and reuse their personal data for their own purposes across different services.
7. The right to object
You have the right to object to:
• Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).
• Direct marketing (including profiling).
• Processing for purposes of scientific/historical research and statistics.
8. Rights in relation to automated decision making and profiling
You have the right not to be subject to a decision when:
• It is based on automated processing.
• It produces a legal effect or a similarly significant effect on the data subject.

The right to complain:

If you feel that A&L CASTORS Ltd. t/a PARNELLS has not fulfilled its obligations under the General Data Protection Regulation 2016/679, then you have the right to lodge a complaint with the Data Protection Commissioner (DPC).

The DPC offers guidance on how to make a complaint here: https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data- Protection-Commissioner/r/18.htm

Automated decision making, including profiling:

A&L CASTORS Ltd. t/a PARNELLS do not use any automated decision making or profiling.

To download a pdf copy of our pivacy policy click here

Data protection policy

Context and overview

Key details

Policy prepared by: Jonathan Slacke-Fitzpatrick

Approved by board / management on: Richard Parnell

Policy became operational on: 23/05/2018.

Next review date: 23/05/2019.

Introduction

A&L CASTORS Ltd. t/a PARNELLS needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures A&L CASTORS Ltd. t/a PARNELLS :
• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

Data protection law

The General Data Protection Regulation 2016/679 describes how organisations — including A&L CASTORS Ltd. t/a PARNELLS — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The General Data Protection Regulation is underpinned by eight important principles. These say that personal data must
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the EU, unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope
This policy applies to:
• The head office of A&L CASTORS Ltd. t/a PARNELLS
• All branches of A&L CASTORS Ltd. t/a PARNELLS
• All staff and volunteers of A&L CASTORS Ltd. t/a PARNELLS
• All contractors, suppliers and other people working on behalf of A&L CASTORS Ltd. t/a PARNELLS

It applies to all data that the company holds relating to living individuals even if that information technically falls outside of the General Data Protection Regulation 2016/679. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• …plus any other information relating directly or indirectly to individuals

Data protection risks
This policy helps to protect A&L CASTORS Ltd. t/a PARNELLS from some very real data security risks, including:
• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with A&L CASTORS Ltd. t/a PARNELLS has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:
• The board of directors is ultimately responsible for ensuring that A&L CASTORS Ltd. t/a PARNELLS meets its legal obligations.


• The Data Protection Officer, Carmel Lyon, is responsible for:
  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data A&L CASTORS Ltd. t/a PARNELLS holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.


• The IT Manage Service Provider, New Wave Computer Services Ltd/ERP Database Provider, Odoo Advantage Limited is responsible for:
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.


• The Marketing Manager, Jonathan Slacke Fitzpatrick is responsible for:
  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers.
  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines
• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• A&L CASTORS Ltd. t/a PARNELLS will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
• When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
• These guidelines also apply to data that is usually stored electronically but has been printed out for some reason.
• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.


When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data use
Personal data is of no value to A&L CASTORS Ltd. t/a PARNELLS unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy
The law requires A&L CASTORS Ltd. t/a PARNELLS to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort A&L CASTORS Ltd. t/a PARNELLS should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• A&L CASTORS Ltd. t/a PARNELLS will make it easy for data subjects to update the information A&L CASTORS Ltd. t/a PARNELLS holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests
All individuals who are the subject of personal data held by A&L CASTORS Ltd. t/a PARNELLS are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at carmel@parnells.eu. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons
In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, A&L CASTORS Ltd. t/a PARNELLS will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information
A&L CASTORS Ltd. t/a PARNELLS aims to ensure that individuals are aware that their data is being processed, and that they understand:
• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

To download a pdf copy of our Data protection policy click here