What is collectedThe NCFA website does not store or capture any personal information when someone visits it and is not registered. The system will log your IP address along with other information provided by your browser. This may include the name and version of the browser you are using, your operating system and any website address that referred you to the NCFA website. This information will only be used for producing anonymous website statistics and will be used to help us with the delivery of the services on the website.
However the system will record personal information if you:
- Provide information by filling in a form on our site
- Subscribe, register or apply for services that require personal information to be given
- Report a fault and give your contact details for us to respond
- Complete surveys that we use for research purposes
Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way. There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you. Certain cookies contain personal information – for example, if you click to “remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites, or a user’s general location.
What sort of cookies does we use? Generally, our cookies perform up to three different functions:1. Essential cookies: Some cookies are essential for the operation of our website. For example, some cookies allow us to identify subscribers and ensure they can access the subscription only pages. If a subscriber opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to.
2. Performance Cookies: We use other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.
3. Functionality Cookies: We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site, and recall your customisation preferences. We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online or comment on a blog.
Can a website user block cookies?Yes, if you do wish to disable our cookies then please follow the instructions here for your browser. Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.
Your rightsFrom May 2018 you have enhanced rights over how your personal data is held, processed and stored, and NCFA is committed to upholding and meeting these. They include the requirements that data be:
- Processed lawfully, fairly and in a transparent manner
- Collected for specified, explicit and legitimate purposes
- Adequate, relevant and limited to what is necessary
- Accurate and, where necessary, kept up-to-date
- Retained only for as long as necessary
- Processed in an appropriate manner to maintain security.
Access to informationAny formal, written request by a Data Subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.
It is intended that by complying with these guidelines, NCFA will adhere to best practice regarding the applicable Data Protection legislation.
National Campaign for the Arts Data Protection Policy
IntroductionThe purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of National Campaign for the Arts (NCFA). This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the General Data Protection Regulation (GDPR) 2018, the Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003).
RationaleNCFA must comply with the Data Protection principles set out in the relevant legislation. This Policy applies to all Personal Data collected, processed and stored by NCFA in relation to its steering group, service providers and clients in the course of its activities. NCFA makes no distinction between the rights of Data Subjects who are employees, and those who are not. All are treated equally under this Policy.
ScopeThe policy covers both personal and sensitive personal data held in relation to data subjects by NCFA. The policy applies equally to personal data held in manual and automated form.
All Personal and Sensitive Personal Data will be treated with equal care by NCFA. Both categories will be equally referred-to as Personal Data in this policy, unless specifically stated otherwise.
This policy should be read in conjunction with the associated Subject Access Request procedure, the Data Retention and Destruction Policy, the Data Retention Periods List and the Data Loss Notification procedure.
National Campaign for the Arts as a Data ControllerIn the course of its daily organisational activities, NCFA acquires, processes and stores personal data in relation to:
- Members of NCFA
- Personel of NCFA
- Third party service providers engaged by NCFA
In accordance with the Irish Data Protection legislation, this data must be acquired and managed fairly. Not all staff members will be expected to be experts in Data Protection legislation. However, NCFA is committed to ensuring that its staff have sufficient awareness of the legislation in order to be able to anticipate and identify a Data Protection issue, should one arise. In such circumstances, staff must ensure that the Data Protection Officer is informed, and in order that appropriate corrective action is taken.
Due to the nature of the services provided by NCFA, there is regular and active exchange of personal data between NCFA and its Data Subjects. In addition, NCFA exchanges personal data with Data Processors on the Data Subjects’ behalf.
This is consistent with NCFA’s obligations under the terms of its contract with its Data Processors.
This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a NCFA staff member is unsure whether such data can be disclosed.
In general terms, the staff member should consult with the Data Protection Officer to seek clarification.
Subject Access RequestsAny formal, written request by a Data Subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.
It is intended that by complying with these guidelines, NCFA will adhere to best practice regarding the applicable Data Protection legislation.
Third-Party processorsIn the course of its role as Data Controller, NCFA engages a number of Data Processors to process Personal Data on its behalf. In each case, a formal, written contract is in place with the Processor, outlining their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Irish Data Protection legislation.
These Data Processors include:
- Survey Monkey: https://www.surveymonkey.com/curiosity/surveymonkey-committed-to-gdpr-compliance/
- Campaign Monitor: https://www.campaignmonitor.com/trust/
- Google GSuit: https://cloud.google.com/security/gdpr/
- Paypal: https://www.paypal.com/ie/webapps/mpp/ua/privacy-full
The Data Protection PrinciplesThe following key principles are enshrined in the Irish legislation and are fundamental to the NCFA’s Data Protection policy.
In its capacity as Data Controller, NCFA ensures that all data shall:
1. Be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
- The identity of the Data Controller (NCFA)
- The purpose(s) for which the data is being collected
- The person(s) to whom the data may be disclosed by the Data Controller
- Any other information that is necessary so that the processing may be fair.
NCFA will meet this obligation in the following way:
- Where it is not possible to seek consent, NCFA will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
- Where NCFA intends to record activity on CCTV or video, a Fair Processing Notice will be posted in full view;
- Processing of the personal data will be carried out only as part of NCFA’s lawful activities, and NCFA will safeguard the rights and freedoms of the Data Subject;
- The Data Subject’s data will not be disclosed to a third party other than to a party contracted to NCFA and operating on its behalf.
2. Be obtained only for one or more specified, legitimate purposes.
NCFA will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which NCFA holds their data, and NCFA will be able to clearly state that purpose or purposes.
3. Not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by NCFA will be compatible with the purposes for which the data was acquired.
4. Be kept safe and secure.
NCFA will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by NCFA in its capacity as Data Controller.
Access to and management of staff and customer records is limited to those staff members who have appropriate authorisation and password access. 5. Be kept accurate, complete and up-to-date where necessary.
- conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to- date. NCFA conducts a review of sample data every six months to ensure
- conduct regular assessments in order to establish the need to keep certain Personal Data.
6. Be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
NCFA will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
7. Not be kept for longer than is necessary to satisfy the specified purpose(s).
NCFA has identified an extensive matrix of data categories, with reference to the appropriate data retention period for each category. The matrix applies to data in both a manual and automated format.
Once the respective retention period has elapsed, NCFA undertakes to destroy, erase or otherwise put this data beyond use.
8. Be managed and stored in such a manner that, in the event a data subject submits a valid subject access request seeking a copy of their personal data, this data can be readily retrieved and provided to them.
NCFA has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
Data Subject Access RequestsAs part of the day-to-day operation of the organisation, NCFA’s staff engage in active and regular exchanges of information with Data Subjects. Where a formal request is submitted by a Data Subject in relation to the data held by NCFA, such a request gives rise to access rights in favour of the Data Subject.
There are specific time-lines within which NCFA must respond to the Data Subject, depending on the nature and extent of the request. These are outlined in the attached Subject Access Request process document.
NCFA’s staff will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request.
ImplementationAs a Data Controller, NCFA ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation.
Failure of a Data Processor to manage NCFA’s data in a compliant manner will be viewed as a breach of contract, and will be pursued through the courts.
Failure of NCFA’s staff to process Personal Data in compliance with this policy may result in disciplinary proceedings.
DefinitionsFor the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.
- Data: This includes both automated and manual data. Automated data means data held on computer, or stored with the intention that it is processed on computer. Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.
- Personal Data: Information which relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, NCFA refers to the definition issued by the Article 29 Working Party, and updated from time to time.)
- Sensitive Personal Data: A particular category of Personal data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s Sexual Orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.
- Data Controller: A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.
- Data Subject: A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.
- Data Processor: A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.
- Data Protection Officer: A person appointed by NCFA to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to Data Protection queries from staff members and service recipients
- Relevant Filing System: Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals, or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.