The Irish Council for Overseas Students CLG, trading as The Irish Council for International Students (ICOS), has a registered address at 41 Morehampton Road, Dublin 4, D04 AE28 and we are a company registered in Ireland under company number 66784. We are also a charity registered with the Charities Regulator, registered charity number 20101275. Our designated Data Protection Champion is Brian Hearne. He can be contacted in relation to Your Privacy at firstname.lastname@example.org.
Your Rights - Your Information
You have the right to access any personal information that we process about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
Your rights under data protection law also include the right to:
- request erasure of your personal data;
- restrict our processing of your personal data;
- object to our processing of your personal data;
- object to any direct marketing from us; and
- be informed about any automated decision-making that we use.
These rights are in some circumstances limited by data protection law.
If we receive a request from you to exercise any of your rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your Rights – Restrict the use of your Information
You are not obligated to provide your personal information to us, however, as this information is required for us to provide you with many of our services, we will not be able to offer you these services without it.
Your Rights - Lodging A Complaint
ICOS only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with us and the supervisory authority. Brian Hearne, Data Protection Champion, email@example.com. Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Telephone +353 (0761) 104 800 Email: firstname.lastname@example.org.
Your Data – How we collect
We collect your personal data for the purpose of providing you with a service that you have requested from us. We also collect data when you register to our site’s Member Area, or subscribe to our newsletter and communications (members only). Furthermore, we collect data when you submit a query using our contact form or directly by email that allows us to respond to your query. We also collect data such as your nationality for statistical purposes. We will never collect any unnecessary personal data from you and do not process your information in any way, other than already specified in this notice. You may also visit and browse our site without going through the registration process.
Your Data – What we collect
We process your personal information that you voluntarily submit to us (such as through registering on our site or submitting a contact form). This information may include name, email address, employment details, telephone number, work or home address (preferably work address), as well as any other information you choose to include in submissions to us.
We may also receive personal data about you from third parties.For example, if you are applying for a fellowship through Ireland’s Fellowship Programme, we may receive personal information about you from the mission to which you submitted your application.
Non-personal information such as demographic data regarding your IP addresses may be collected from all of our website visitors on a cumulative basis. This type of anonymous statistical data cannot be used to identify or contact you.
We sometimes conduct anonymous surveys in which we collect statistical data such as nationality or gender. Some of the responses you give may also be used in our policy and advocacy work.
Your Data – The Purpose
We take your privacy very seriously and will only use your data when we have a lawful basis for doing so. Most commonly, we will use your personal data in the following circumstances:
- To enter into and perform a contract
When we enter into or are about to enter into a contract, it is necessary to collect personal data from you in order to put the necessary arrangements in place.
- To comply with our legal obligations
We may process your personal data to comply with certain legal obligations to which we are subject, such as to verify information provided to us.
- For our legitimate interests
We may use your personal data for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). When we use your personal data in this way, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. Our legitimate interests including managing and operating the administrative and technical aspects of our business efficiently and effectively.
- With your consent
In certain circumstances, we may rely on your explicit consent to process your personal data. Where we do, you have the right to withdraw your consent free of charge at any time.
Your Data - Why we collect it
We collect and process your data, so we can provide the best service to you. When we process your information we may use it for one or all of the following reasons:
- To provide you with the product/service you have requested
- To contact you in relation to the product/service you have requested
- To share updates about ICOS’ recent activities
- To conduct research about issues facing international students
- To share recent activity and updates in our website member area
- To customise the website in accordance with your preferences
- To respond to any communications we may receive from you
- For internal record keeping
Your Data - Special Category
On occasion we may need to request sensitive personal information from you, such as dietary requirements at an event. Where we collect sensitive personal data, we will only request the information required for the specified purpose and always ask for your explicit consent. You can modify or remove consent at any time, which we will act on immediately, unless there is a legitimate interest or legal reason for not doing so.
Your Data - Photographs
We may from time to time host events with photographers present. We encourage photographs for posterity and promotion. If you wish to have a copy of the photograph, please contact us. If at any time you do not wish your photograph to be kept or promoted, please let us know by emailing email@example.com.
Your Data - Retention
We only retain personal information for as long as is necessary and we have strict review and retention policies in place to meet our obligations. Where you have consented to us using your details, we will keep such data until you notify us otherwise and/or withdraw your consent. This may impact upon our ability to provide services to you.
Your Data and Third Parties
We do not share or disclosure any of your personal information other than for the purposes specified in this notice.
Third party service providers
We use third-parties to provide services and business functions to us at our direction and on our behalf. For example, we may share your personal information with accountants, legal advisers, IT service providers, payment service providers, security service providers and administrative service providers engaged by us.
All processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
We do have external links to third party websites. While we do attempt to ensure such third party sites are all reputable, we are not responsible for the content or privacy policies of these other websites.
Ireland's Fellowship Programmes
We process your personal data when you participate in an Ireland Fellowship Programme, which we administer on behalf of the Department of Foreign Affairs and Trade (the “Department”). When we process your personal data for this purpose, we do so on the basis of the Department’s instructions and in accordance with the terms and conditions governing the Ireland Fellowship Programmes.
An Garda Síochána, government or quasi-government bodies, courts and tribunals
We may share your personal data with these organisations and bodies where required to do so by law.
Potential sale or merger
Your data – Transfers outside the EEA
We may transfer, store or process your personal data in countries outside the European Economic Area (“EEA”). Where the laws of such countries do not afford an equivalent level of protection of personal data as the laws of Ireland, we will use one of the following safeguards:
- Transfer the personal data to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient of the personal data that means they must protect it to the same standards as the EEA.
- Transfer it to organisations that are part of the Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
Your Data - Cookies
When you agree for it to be placed on the hard drive, the cookie may save your personal preferences, so you do not have to constantly re-enter them or it may provide you with preferential content.
Your Data - Security
We take your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction. Your personal information is stored on secure servers. We are committed to ensuring that your data is secure, however we cannot guarantee the security of any information you send to us via the internet as no internet data transmission can be guaranteed to be 100% secure. In order to prevent unauthorised access, we have taken all reasonable physical, electronic and managerial steps to protect your personal information, through encryption, anonymisation and authentication.
Your Privacy – Amendments