Data Protection Policy for Fortress Consortium Ltd T/A Fortress Planning
Fortress Consortium Ltd T/A Fortress Planning is a registered company with the SCSI (Society of Chartered Surveyors of Ireland) and IEI (Engineers Ireland) and Privacy and Data Protection Rights are very important to us.
In the service of our work with you, you give us information about yourself – we respect your trust in us to use, store and share your information in accordance with new laws – including GDPR related legislation.
Please be assured that the personal information you provide to us will only be used to ensure that you receive the best Service possible, that your data will be held legally, securely and in a compliant manner and that your information can only be assessed by those who require it for the delivery of our services.
Enquiries about this Data Protection Policy should be made to: Fortress Consortium Ltd T/A Fortress Planning, Canopy Street, Cashel, Co. Tipperary, E25 AW80 - Email to firstname.lastname@example.org ; Phone to 062 65566.
Who we are
When this notice mentions “we” or “us”, we mean the Limited Company operated by Brigid Browne (Managing Director) and Mike Ryan (Director) and includes staff employed by them.
Mike Ryan as Director has overall responsibility for Data Protection within the Company and may be contacted by email or phone on the details given above; by calling to the office, or by writing to him at our office address.
Information & You
So that we can deliver effective service to you, we must gather and use personal information about you. If you do not provide the personal information, we may be unable to provide the quality of service you seek.
Why we collect your Data
We collect and use personal data information to provide the following services:
- The provision of Customer Service, Enquiry Responses, Quotations and other follow up Information on your request
- Customisation and Tailoring of Services for clients
- To manage vendor accounts and for accounting (payment) purposes
- To comply with Regulations and Statutory Obligations
- To comply with requirements imposed by Professional Associations such as SCSI, IEI where certification is required
- To provide personnel, payroll and pension administration services in connection with our employees
- To get and retain Clear and Opt-In Consent for further marketing follow up
- For provision of the enforcement of legal rights for the protection of both our interests
- For provision of Billing, Payment, Remittance or receipt/payment of money on your behalf
How we collect information about you
When you visit our Website
- Cookies are present to store statistical details (See Cookie Section)
- Google Analytics identity general data on what pages users access and how long they stay
- You might submit Enquiries or Make a payment through 3rd Party Secure site
- Contact Us Form
When you use the Consultancy services that we provide
- Details noted when you make enquiry by face to face calls, phone, email or via website
- Forms (Agents Forms, Consultants Engagement Form, etc.) used in the provision of our services.
- Details required relating to contractual obligations
- Photography may be taken at related to the provision of our services but any use is consent based
When you provide us with Consent to send you regular updates
- Email Consent
- Hardcopy Written Consent
When you visit or engage with our Social Media platforms
- Engagement (Likes/Comments/Competitions on Facebook/Twitter/LinkedIn
The Specific Details we Collect
- First Name, Last Name
- Contact information including email address and telephone number
- Company Role if Applicable
- Company or Home Address and Billing address
- PPS number may be required for very specific services relating to Planning services
- Sign up time and date
- Transaction data (services commissioned, services commissioned type, contract value, contract time and date)
- Banking Details (but we do not store sensitive payment data)
- Google Analytics (no personal identifiable information is passed on - all information is anonymised)
Our website use ‘cookie’ technology. A cookie is a little piece of text that our server places on your device when you visit any of our websites or apps. They help us make the sites work better for you.
The only function of cookies associated with our website is to track hits so as to monitor the parts of the site which are of most interest to visitors and to enable adjustments to be made to suit those requirements. No information is retained for any other purpose.
[Note: You can change the settings on your browser to refuse all cookies. However, you should note that disabling cookies may result in some parts of the site not working efficiently or in slower downloads].
For further information about cookies and how to control their use, please visit the following third party educational resources: http://www.allaboutcookies.org and http://www.youronlinechoices.eu
Sharing of Personal Data
The policy of Fortress Consortium Ltd T/A Fortress Planning is not to Share your Personal Data with 3rd Parties
However – from time to time – we may be required to pass your data to 3rd parties as outlined below.
Please note – this will be clarified to you at the time that the data is collected and will either be done so as to provide you with a better service – or because it is legally required to do so.
- Specific Office based Staff will have access to your related information to process the required service and undertake the necessary administration such as Designs, Inspections, Certificates etc.
- Our Staff or approved third party consultants may receive your data (contact details & role details) to contact you for provision of our services to execute your specified requirements.
- Our Staff or approved third party consultants may receive your data (contact details, service details, design brief, etc.) in advance of service for provision of our services to execute your specified requirements.
- The Professional Associations with whom we work may receive your data for the purpose of reviewing assessments and auditing certification
- Specific Government Departments, Local Authorities or 3rd Party Organisations (Lending, Banking, Financial Institutions, Legal Professionals, etc.) may receive your data with your consent in provision of our services to execute your specified requirements on your behalf.
- Revenue Commissioners may receive details for tax compliance reasons
- Our Accountants may receive details for Accounting, Audit and Regulatory purposes
Contractor & Third Party Data Protection Compliance
We expect and actively require any Third Parties with whom we work to be compliant with their legal obligations under Data Protection.
It is our policy to require all contractors or those who may come into contact with any Personal Data we hold to show GDPR compliance via self-assessment and audit though our Supplier Data Protection Checklist.
We will store this checklist for the duration of our working relationship with that 3rd party (+ 12 months)
How we keep your Information Safe
We take appropriate measures under the laws that apply, to ensure your data is safe.
Emails & other Electronic Data is stored in secure closed network system
Specific Projects are stored on a Cloud Based Database secure application
AntiVirus Software is used on all IT Systems
Encryption is enabled on all systems holding Personal Data
A Firewall assists against Network Intrusion
Wi-Fi is secure
Documents are stored in a locked Office in Individual covered Files
Data is managed Safely and not left in areas where non relevant employees can access
Any data which might be viewed as in any way sensitive is stored in locked cabinets in the office of the Director
Printing is completed with printers containing no memory card to ensure only those who should have access to the printed do so and only data which Employee A prints, is accessible to Employee A and cannot be retrieved from the printers by unauthorised third parties.
We do not use, record or retain CCTV footage in our office.
Although Fortress Consortium Ltd T/A Fortress Planning does not hold sensitive data, it is our policy to engage with a GDPR Compliant Professional Shredding Company and safety/securely dispose of the Personal Data we hold to ensure compliance – see section on Data disposal
Calls relating to Personal Data
If you contact us about your information, we may need to ask you to identify yourself and furnish proof of identity – this is to help protect your information.
How long do we keep your personal data
We have policy based and regulatory obligations that mean we must keep your data while you are a client and for certain periods of time after you stop being a client. Those periods depend on the nature of the work we have done for you.
General Data Retention Policy (Clients)
We retain general data for a period of 7 years
General Data Retention Policy (Contractors/Staff or approved third party consultants/Vendors)
We retain personal data of the above for the duration of working relationship (+12 months)
Health and Safety Requirements
Client Project Safety File (Hardcopy) – 7 Years
Client Project Safety File (softcopy) – 10 Years
Revenue – 6 Years
What is the legal basis on which we gather and hold your information ?
To use your information lawfully, we rely on one or more of the following legal bases:
- Performance of a contract
- Legal obligation
- Protecting the vital interests of you or others
- Public interest
- Our legitimate interests
- Your consent
To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. We may also gather information about you from third parties to help us meet our obligations.
If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our services.
Disposal of Personal Data
Once the period of stated storage is complete, or based on a Request to delete personal data (presuming we have no legal or statutory obligation to retain it) – it is our policy to have your personal date securely disposed of – through 6 monthly scheduled contracts with our professional shredding company.
This service will dispose of personal data such as has been collected on Designs, Forms, Feedback, Inspections and more.
- Date will be securely deleted from the following media:
- Paper Based Files
- CRM & Database Systems
- Electronic Storage – including Hard Disks, External Hard Drives, Memory Sticks & Email
- BackUp Date will be deleted also in relation to these files
Sometimes we need your consent to use your personal information.
With direct marketing for example, we need your consent to make you aware of services which may be of interest to you.
We may do this by phone, post, email, text or through other digital media.
It is our policy to keep, in as far as is possible, a documented record of this consent.
Often, at the end of a service or piece of work for you, we contact you to give and get feedback.
We will generally provide options at this point in relation to how you might provide consent or otherwise for us to contact you with updates, marketing material and other promotions.
The DPO will conduct regular inspections and maintain a systematic audit schedule to monitor compliance and Optima Training will actively record and report any Breaches in relation to Data Protection.
Any employee, client or 3rd party can alert the DPO to the breach, who will update the Breach Log before identifying the breach type and evaluate any risk associated with the breach.
Where there is a possibility of risk, and where the personal data breached is neither Encrypted or Anonymised, the DPO will report the breach to the DPC, and depending on the severity/urgency of the risk – may also notify the data subject. This will be done as soon as possible – and within the required 72 hour limit.
Staff Awareness & Training
Training sessions have been completed with all staff regarding to GDPR which came into effect on the 25th August 2018. All future induction sessions with include a specific session on data protection.
Your Data Rights
You can exercise your rights by contacting us on 062 65566, emailing us on email@example.com or calling into our Office - Fortress Consortium Ltd T/A Fortress Planning, Canopy Street, Cashel, Co. Tipperary, E25 AW80.
Whenever you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.
Your right to obtain information cannot adversely affect the rights and freedoms of others. Therefore, we cannot provide information on other people without consent. (See Sharing of Data for further details)
We generally do not charge you when you contact us to ask about your information. However, if requests are deemed excessive or manifestly unfounded, we may charge a reasonable fee to cover the additional administrative costs or choose to refuse the requests.
The following section details your information rights and how we can help ensure that you are aware of these rights, how you can exercise these rights and how we intend to deliver on your requests.
- You can ask us for a copy of the personal information we hold and further details about how we collect, share and use your personal information
- If you want to update or correct any of your personal details, please contact us at on 062 65566, emailing us on Info@fortressplanning.ie or calling into our Office - Fortress Consortium Ltd T/A Fortress Planning, Canopy Street, Cashel, Co. Tipperary, E25 AW80
- You can change your mind wherever you have given us your consent, such as for marketing or processing your information.
- You may have the right to restrict or object to us processing your personal information. We will require your consent to further process this information once restricted. You can request restriction of processing where;
- The personal data is inaccurate and you request restriction while we verify the accuracy
- The processing of your personal data is unlawful
- You oppose the erasure of the data, requesting restriction of processing instead
- You require the data for the establishment, exercise or defence of legal claims but we no longer require the data for processing
- You disagree with the legitimate interest legal basis and processing is restricted until the legitimate basis is verified
You may ask us to delete your personal information or we may delete your personal information under the following conditions:
- The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- You withdraw your consent where there is no other legal ground for the processing
- You withdraw your consent for marketing purposes
- You withdraw your consent for processing a child’s data
- You object to automated decision making
- The personal data has been unlawfully processed
- The personal data has to be erased for compliance with a legal obligation.
- You declare to us that you are no longer a client of ours
Data Protection Feedback, Further Information & Complaints
If you have a complaint about the use of your personal information, please let a member of staff in our Office know, giving them the opportunity to put things right as quickly as possible.
If you wish to make a complaint you may do so in person, by phone, in writing and by email. We will fully investigate all the complaints we receive. We ask that you supply as much information as possible to help us resolve your complaint quickly.
You can also contact the Office of the Data Protection Commissioner in Ireland on the below details:
Visit their website www.dataprotection.ie.
Phone on +353 (0)57 8684800 or +353 (0)761 104 800
Write to Data Protection Office, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square, Dublin 2, D02 RD28, Ireland.
This Data Protection Policy will be reviewed regularly in light of any legislative or other relevant developments.