Effective from: 16 July 2019
When visiting an Independent News and Media (INM) site or using one of our services, you’re trusting us with your information. We know that this is a big responsibility and we work hard to protect your information and put you in control.
At INM we seek to maintain the privacy, accuracy, and confidentiality of all data (including your personal data) that we collect and use as part of our services.
We will use your personal data only for the purposes described below and in full compliance with the GDPR Data Protection Legislation.
The purpose of this privacy statement is to explain how INM, in our capacity as a data controller, collect and use your personal information.
This Privacy Statement applies to https://reachgroup.ie/
INM provides a range of services through this site. We describe these in detail in this statement but basically, we provide services under the following broad headings.
Registrations: Certain services are only available to registered users. For example, some of our newsletters, some of our competitions and access to certain selected articles.
By using this Site and by disclosing your Data to us, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement
When you visit our sites or use our services in any way we may collect and process different types of information about you. We have set out below the different types of data that we process, why and how we process it.
Certain services are only available to registered users
When you sign up or register with INM to avail of a service we collect only the information needed to provide that service.
What we process:
- Personal Identifier– we collect an identifier such as your email address.
- Password – we collect a password to ensure that your data is kept safely on our systems and that other users cannot access your personal data.
Why we process this data: The legal basis for processing this data is to enable us to deliver registration services that you have consented to.
The personal identifier allows us to recognise you when you come to our site or service. This enables us to provide you with the service that you signed up for.
Who has access: Customer registration identity information is only ever accessible to INM employees.
Access may be granted to our registration system provider in order to resolve problems but only under the strictest governance by INM. INM ensures that our registration provider, adheres to the highest standards of data protection and privacy.
We use analytics providers in order for us to understand our audience, the content that appeals to them and how well our site is working.
Analytics tools allow us to understand how our audience interacts with our site and our content and enables us to provide a better service to our site visitors. We do not collect or process any personal information in our analytics platform.
What we process:
- Your IP address – in order to track your activity on our site we process your IP address
- Anonymous data about your device – your operating system (e.g. iOS11), device type (e.g. tablet)
- Anonymous aggregated demographics – for example your current city and other anonymous data.
- Anonymous data about your browsing – stories you read, types of content consumed and browsing patterns.
Why we process this data: The legal basis for processing this data is the legitimate interests of INM to manage and optimise the running of our site and its content.
This data helps us optimise the way the site is structured and how content is arranged on the site. It also allows us to show interested parties how many people access the different parts of our site and on average how often they visit. This allows understanding of how many people look at our content at different times of the day etc. These statistics are always calculated on an aggregated basis – never individually. We use the data for future marketing and personalised advertisement(https://support.google.com/analytics/answer/2700409?hl=en-GB&utm_id=ad).
Who has access: Anonymised versions of the data are hosted on Google Analytics. At no point do we have access to personally identifiable information through Google Analytics. Anonymous aggregated reports about the general behaviour of our audience may be made available to the public or others.
Where links are provided on the site to other websites, INM bears no responsibility for such sites. These sites are not under our control and we are not responsible in any way for any of their contents.
Where links are provided to websites that process your data. INM will not be privy to any processing that occurs and accepts no responsibility in relation to the processing of your data by these third parties.
Your Rights Under Data Protection Law
You have several rights under data-protection law in relation to the personal information that INM holds about you. If you choose to exercise any of these rights, we will ask you to verify your identity. We will consider your request and provide a response within one month. These rights are described in detail on the Data Commissioner’s Website and summarised below:
- Right of Access: You are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”). Typically, there is no fee for this, however, we have the right to apply a reasonable fee in exceptional circumstances.
- Right of Portability: You can request a copy of the personal information we hold about you in a structured, commonly used and machine-readable format and if technically feasible, have your personal information transmitted to another data controller in a machine-readable format.
- Right to rectify: If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
- Right to withdraw consent: You have the right to withdraw your consent to any future processing for which you have previously given that consent.
- Right to Erasure: Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”).
- Right to Restriction: Restrict processing of your personal information in certain circumstances
- Right to object to processing: You are entitled to object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes.
- Rights relating to automated decision making including profiling: You are entitled to not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
- Right to complain: You are entitled to lodge a complaint with the Data Protection Commissioner if you have concerns about how we process your personal data.
You can complain directly to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois by telephone at +353 1890 25 2231 and/or by email to firstname.lastname@example.org.
You can also make a complaint directly to the relevant data protection authorities in the country where you are ordinarily resident. For example, in the UK you can also complain directly to the ICO at https://ico.org.uk/make-a-complaint/ or call their helpline on 0303 123 1113.
How To Exercise Your Rights
Requests for information or to exercise these rights should be made in writing to the INM Data Protection Office:
- by email to email@example.com
- by post to the INM Data Protection Office, INM, 27-32 Talbot St, Dublin 1, Ireland.
If possible, you should specify the type of information you would like to see to ensure that we meet your expectations. We must be able to verify your identity in order to ensure the safety of your data. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other individuals and/or businesses.
Limitations To These Rights
These rights are in some circumstances limited by data-protection legislation. You may have various rights under Data Protection Legislation. However, in certain circumstances, these rights may be restricted (Article 23 of the General Data Protection Regulation, which is transposed into UK law by the Data Protection Act 2018 sets out the circumstances in which your rights may be restricted). Also the personal information that is processed as part of INM’s journalistic work may be exempt under Art 85 of the GDPR.
These rights are in some circumstances limited by Data Protection legislation. You may have various rights under Data Protection legislation. However, in certain circumstances these rights may be restricted by Data Protection legislation. Also the personal information that is processed as part of INM’s journalistic work may be exempt under Art. 85 of the GDPR and Section 43 of the Data Protection Act 2018.
In particular, your rights may be restricted where this is necessary:
- for the prevention, detection, investigation and prosecution of criminal offences; and/or
- in the interest of freedom of expression and/or information; and/or
- in compliance with a legal obligation such as a court order and/or
- in contemplation of or for the establishment, exercise or defence of a legal claim or legal proceedings (whether before a court, tribunal, statutory body or an administrative or out-of-court procedure).
The following sections describe how we manage, secure and control access to your data and under what circumstances we disclose data to others.
Retention Of Your Data
To make sure we meet our legal Data Protection and Privacy obligations, where yo are an account holder, we will retain your information for at least as long as your account is active, as needed to provide you services or as necessary to comply with our legal obligations, resolve disputes, protect our legal interests and enforce our agreements.
If you ask for your account to be closed we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with legal obligations protect our legal interests, prevent fraud, collect any fees owed or to resolve disputes.
As a matter of course, we will delete personal data associated with accounts that have been inactive for at least 6 years.
Where you are not an account holder, we will retain your information for so long as is necessary to fulfil the purpose for which it is processed or for such longer period as is required to comply with our legal obligations, resolve disputes, protect our legal interests and enforce our agreements.
Sharing Data With 3rd Parties
We use third party service providers who work for us in the provision of our services. Your data may be processed by a third party if required to deliver a service you have requested or as otherwise set out in this Privacy Statement.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your Data.
We will have written contracts with them which provide assurances regarding the protections that they will give to your Data and their compliance with our data security standards and international transfer restrictions.
We also share data with other INM entities within the group where they are providing you with services that you have requested or where they provide services to us that you have requested or as otherwise set out in this Privacy Statement.
How Is Your Data Secured
INM operate and use appropriate technical and physical security measures to protect your personal data.
We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. In addition, our service providers are also selected carefully and required to use appropriate protective measures.
Where Do We Store Your Data?
In most cases, INM stores your data securely within the European Economic Area (EEA) using GDPR compliant service providers.
In some cases, INM may have to transfer or store your data to countries outside the EEA, for example, when one of our service providers use employees or equipment based outside the EEA.
For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.
Disclosure Of Your Data
Your Data is private and confidential. Your Personal data may only be shared within INM, for any of the purposes set out in this Privacy Statement.
From time to time, we may access and/or disclose your Data as set out in this Privacy Statement or if we are required to do so by law or in good faith and belief that such action is necessary to:
- conform with the law or comply with legal process served on us;
- protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or
- act under exigent circumstances to protect the personal safety of users of our services or members of the public.
Changes to this Information
This statement is effective from:1 April 2019
We may decide to make changes to this Privacy Notice. If it’s a fundamental change in how we deal with you, then the updated Privacy Notice will be provided to you well in advance of the change actually taking effect.
We will post the changes on our website or send them to you via e-mail along with an explanation of what the likely impact of those changes will be to you, if any.
In order to ensure fairness of the processing, we encourage you to review the content of this Privacy Notice regularly.
If you are unhappy with how we use your personal data
By using this Site and by disclosing your Data to us, you understand that we may collect, store, process, use and disclose your Data as described in this Privacy Statement. If you are not comfortable with any aspect of this Privacy Statement, you can discontinue using our Site or not provide us with any further personal data. We reserve the right to modify this Privacy Statement at any time.
Contact the Data Protection Office
INM has a data protection function including a data protection officer. If you wish to invoke your rights or have any questions please contact the INM Data Protection Office.
INM Data Protection Office
Independent News and Media PLC
27-32 Talbot Street