PRIVACY STATEMENT FOR Communities 4 Climate Action” 

Project Reference: 14LDRKLD110161

Who are we?

County Kildare LEADER Partnership is a Local Development Company that is responsible for the delivery of a range of rural, enterprise and social inclusion programmes in County Kildare. We are the Implementing Partner for the 2014 – 2020 LEADER programme in Kildare.

Why do we have a Privacy Statement?

Depending on the service being offered CKLP may need to process ‘personal data’ as defined by the General Data Protection Regulation (GDPR). We are committed to ensuring that personal data you supply to us is;

  • Obtained lawfully, fairly and transparently
  • Obtained for only specified, identified and legitimate purposes
  • Processed for purposes we have identified or purposes compatible with purposes identified.
  • Adequate, relevant and limited to what is necessary for those purposes
  • Personal data collected and processed must be accurate and (where necessary) kept up to-date.
  • Kept only for as long as is necessary for the purposes for which it was obtained.
  • Processed in a manner that ensures appropriate security of the personal data More detail is available in our Privacy Statement (See Appendix 1).

What types of personal data do we need to undertake this activity?

  • Name: Names are recorded by means of the recruitment questionnaire in order to identify people who are interested in taking part in the course.
  • Town: In order to know where participants are coming from geographically and to best plan the programme taking this into consideration, there is a section in the recruitment questionnaire in which we ask people to state the town the live in or their nearest town. We do not want to know your address and/or Eircode.
  • Membership of community group or club: This course is designed for people who are members of community and voluntary groups and clubs in County Kildare. Our recruitment questionnaire asks that you list the group(s) you belong to.
  • Mobile phone number: In order to easily contact course participants in the event of changes to the programme and for the smooth running of the field trips, the recruitment questionnaire asks that participants provide their mobile phone number. Records of your phone number will be deleted at the end of training programme and will not be used by CKLP for other purposes
  • Signature: You will be asked to sign an attendance sheet as evidence of attendance at training. This is required for CKLP to retain evidence of participation in our training programmes, in order to meet regulatory and audit requirements under the EU 2014- 2020 LEADER programme. This information is required.
  • Email address: Email address must be provided to the trainer to enable receipt of electronic course materials through Google Classroom. Participants must have a Gmail address to participate in the programme. Email addresses may also be used to send certificates. Records of your email address will be deleted at the end of training programme and will not be used by CKLP for other purposes.
  • Photos: At programmes organised by CKLP, we may take photos as evidence of our activities or for use in promoting the activities of CKLP on our website or in social media. We may also use them in printed material, such as brochures, or in newspaper features. Where photos are to be taken, you will be advised at the event and should inform the trainer/photographer if you wish to opt out of photos. If you consent to use of a photo by CKLP but subsequently wish to withdraw consent to continued use of your image you can may email us at leader@countykildarelp.ie.
  • Anonymised data: Our training evaluation sheet asks for your feedback along with gender, age range and nearest town/village. This sheet does not require a signature, or any personally identifiable information and this data will not be associated with any personally identifiable information. Provision of this information is not mandatory, but such data is beneficial to us in understanding participation and developing future training programmes.

Am I the only source of this personal data?

Yes, the data is provided at registration for training by participants.

Is personal data submitted as part of this activity shared with other organisations? County Kildare Leader Partnership do not share personal information provided in relation to this training with other data controllers, unless required to do so for audit or regulatory requirements under EU funding rules.

Where training services or ancillary services for CKLP are contracted and involve processing of personal data they shall be governed by suitable controls under a data processing agreement as required by the GDPR.

Data in this service is/is not transferred outside the EAA.

How long is my data kept for?

Data gathered under the RDP-LEADER Programme 2014-2020, including but not limited to participants email addresses, signature/attendance sheets and

Do you need to update your records?

If during the course your contact details change, in order to ensure you receive your certificate and training materials, please notify CKLP at:

Address: County Kildare LEADER Partnership, Jigginstown Commercial Centre, Old Limerick Road, Naas, Co.Kildare, W91 A2XE.

Emailing us at: leader@countykildarelp.ie

When making a request to update your records, please provide evidence to support this.

Your rights:

You have the right to obtain confirmation as to whether data concerning you exists, to request access to same, to be informed of the content and source of data and check its accuracy.

If the data held by us is found to be inaccurate you have the right to rectify/correct this – see above on how to update your records.

You also, subject to certain conditions being met, have the right to object to or seek restriction of the processing of personal data and to request the erasure of personal data held by CKLP.

Please note that to help protect your privacy, we take steps to verify your identity before granting access to personal data.

If you have concerns or wish to exercise your rights as above, contact the Data Protection Officer for CKLP:

County Kildare Leader Partnership - Data Protection Officer

Right to raise a concern with the Data Protection Commission

If you are not satisfied with the handing of your concerns by the County Kildare Leader

Partnership Data Protection Officer you are entitled to raise a concern with the Data Protection Commission who may investigate the matter for you. The Data Protection Commission website is www.dataprotection.ie or you can contact their Office at:

Changes to Privacy Statement:

We may make changes to this Statement. If we make changes they will be posted below.

Last updated on: 08.07.2019.


Appendix 1

Data Protection Acts 1988 to 2018

PRIVACY STATEMENT


Who are we?

County Kildare LEADER Partnership CLG., (CKLP) is the Implementing Partner for the delivery of the Rural Development (RDP)-LEADER Programme 2014-2020 within County Kildare. We will gather and process your personal information in accordance with this privacy notice and in compliance with the relevant Data Protection Regulation and law.

Why do we have a Privacy Statement?

This privacy statement has been created to demonstrate the County Kildare LEADER Partnership commitment that personal data you may be required to supply to us is:

    • Obtained lawfully, fairly and in a transparent manner
    • Obtained for only specified, identified and legitimate purposes
    • Processed for purposes which we have identified or purposes compatible with the purposes that we have identified.
    • Adequate, relevant and limited to what is necessary for purpose for which it was obtained
    • Personal data collected and processed must be accurate and (where necessary) kept up to-date.
    • Kept only for as long as is necessary for the purposes for which it was obtained.
    • Processed in a manner that ensures the appropriate security of the personal data including protection against unauthorised or unlawful processing.

More detail is available in our Data Protection Policy Statement, you can request a hard copy at leader@countykildarelp.ie or 045-895450

The County Kildare LEADER Partnership CLG., registered office is:

Jigginstown Commercial Centre, Newbridge Road, Naas, Co. Kildare.


What is the activity referred to in this Privacy Statement?

The delivery of the RDP-LEADER Programme 2014-2020 within County Kildare

What is the basis for making the processing of this personal data lawful?

Legitimate interest as Programme Implementer as information may need to be shared with other funding organisations, e.g. The Kildare Local Enterprise Office. You may also be asked to provide information on public funds you have received.

Processing is in accordance with Article 6(1) (c) and 6 )1) (b) of the General Data Protection Regulation,2016– processing being necessary for compliance with a legal obligation to which the data controller is subject and processing is necessary for the performance of a contract to which the data subject is party. Specifically, the lawful basis for this process is:

The RDP-LEADER Programme 2014-2020 Operating Rules. All initiatives/projects funded under the LEADER Programme 2014-2020 must be in compliance with these rules and regulations, including the two EU framework regulations:

  1. The Common Provisions Regulation (EU Regulation 1303-2013)
  2. EAFRD EU Regulation 1305/2013.

What types of personal data do we need to undertake this activity?

Contact information, for example:

    • Name
    • Home Address
    • Personal Email
    • Business Email
    • Home Telephone Number
    • Work Telephone Number
    • Mobile Telephone Number

For certain categories of applications for funding under the RDP-LEADER Programme supporting documents are required, examples include:

    • Bank Statements
    • Accounts
    • Business Plan
    • Tax Information (PPSN Number, Tax Clearance Access Number, VAT number)

What will happen if the personal data is not provided?

You are not obligated to provide your personal information to CKLP, however, as this information is required for us to deliver the RDP-LEADER Programme 2014-2020, we will not be able to deliver/provide the assistance of the programme to you without it.

Am I the only source of this personal data?

In some instances to assist with the delivery of the activity or to comply with regulatory or legislative requirements personal data is sourced from a third party.

Double funding checks are carried out with other potential sources of public funds in Ireland, examples include: The Kildare Local Enterprise Office, Kildare County Council, Failte Ireland, The Sports Capital Programme.

Is personal data submitted as part of this activity shared with other organisations?

County Kildare LEADER Partnership CLG may, to fulfil statutory or regulatory obligations or in the public interest, from time to time, have to share personal data with other organisations or entities. Where this is required County Kildare LEADER Partnership shall have regard to your rights, to the security and integrity of the data and will minimise the data shared

Data is shared with:

    • Kildare Local Community Development Committee
    • Kildare County Council
    • Kildare Local Enterprise Office
    • Kildare LEADER Independent Evaluation Committee
    • The Department of Agriculture, Food & the Marine (including publication of grant received on DAFM website).
    • The Department of Rural and Community Development
    • Pobal
    • E.U. Commission and E.U. Court of Auditors.
    • Comptroller and Auditor General and any other Government Department or Agency.

Data is also shared with other potential sources of public funds in Ireland.

Data is transferred to two other countries, Luxembourg and Belgium (E.U. Commission and E.U. Court of Auditors)

How long is my data kept for?

Data gathered by us under the RDP-LEADER Programme 2014-2020 is kept until 31st December 2028.

Your rights:

You have the right to obtain confirmation as to whether data concerning you exists, to request access to personal data held about you, to be informed of the content and source of data and check its accuracy.

If the data held by us is found to be inaccurate you have the right to rectify/correct this – see above on how to update your records.

You also, subject to certain conditions being met, have the right to object to or seek restriction of the processing of personal data and to request the erasure of personal data held by County Kildare LEADER Partnership.

Please note that to help protect your privacy, we take steps to verify your identity before granting access to personal data.

To exercise these rights please contact us at:

Telephone: 045-895450

Email: leader@countykildarelp.ie

Writing to us at: The RDP-LEADER Programme, County Kildare LEADER Partnership CLG, Jigginstown Commercial Centre, Newbridge Road, Naas, Co. Kildare.

Right of Complaint to the Data Protection Commissioner

If you are not satisfied with the outcome of the response received by County Kildare LEADER Partnership you are entitled to make a complaint to the Data Protection Commissioner who may investigate the matter for you. The Data Protection Commissioner’s website is www.dataprotection.ie or you can contact their Office at:

Date of Privacy Statement: 2nd August, 2018

Changes to this statement will be updated and appear on www.countykildarelp.ie