Privacy Statement
Introduction
At Harwyn Ltd., Management Consultants (‘Harwyn’) privacy has always been a core pillar of our business and approach; the introduction of the GPDR provides us with the welcome opportunity to demonstrate this in a transparent & codified manner to both existing and prospective clients.
Who we are?
Managing Director, Pat Harvey, and his team at Harwyn.
What information do we collect?
Across our various services we collect and use only personal data supplied to us by you, or by those who actively participate in its delivery. Data collection is typically from the contracting/requesting organisation/client or else is gathered directly from service users/participants (face-to-face/email/interview). With the exception of investigations/conflict resolution (which are more involving), this data is typically limited to contact details.
Harwyn does not collect sensitive personal data unless provided to us by either the contracting/requesting parties – and only for the purposes described in the requested/contracted service’s Terms of Engagement. Any sensitive data collected is treated in a strictly confidential manner (see retention and security below), and, retained only for such period as allows the service/case/contract to be completed.
Harwyn does not collect data through third parties neither does it buy data form external sources.
How do we use personal information?
Beyond administration, internal quality assurance, and on occasion marketing-related activity, your data will only ever be used in providing the service for which it was gathered i.e. requested service/case, project and will not be used for subsequent purposes without your prior consent (except where a legal obligation arises).
Our Terms of Engagement (cases commencing from May 25th, 2018) further states the types of data collected, along with the means and processes applied to it.
What legal basis do we have for processing your personal data?
All Personal Data is collected in accordance with the law: in most cases personal data is collected arising out of the delivery of a contract and provided by the requesting party. Where otherwise collected with the consent of the subject Harwyn recognises that this may be withdrawn at any stage (by requesting same in writing to Harwyn).
When do we share personal data?
Personal data will only ever be shared where required in the delivery of a contracted/requested service, and will only be shared with authorised representatives, legal/medical professionals (where required to satisfy contract), or with service providers who provide Harwyn with support services.
Where do we store and process personal data?
Harwyn takes its security responsibilities seriously, employing all appropriate physical and technical measures including encryption & staff training. These measures are reviewed at regular intervals.
How long do we keep your personal data for?
Personal data is only ever held for as long as required to meet the purpose for which it was gathered i.e. as set out in the Terms of Engagement, or beyond that until such time as any related, meaningful, likelihood of legal/regulatory follow-on exercise ceases to exist.
Your rights in relation to personal data
Along with discharging its own legal responsibilities under GDPR, Harwyn fully recognises the rights of data subjects (inc. to be informed, access, rectification, restriction of processing, portability, etc.). Any such request will be dealt with both promptly and in accordance with the law. Any such communications should be sent to Harwyn.
Any such requests will be subject to identity verification and where complex, may require processing time over and above one month – the rationale for such an occurrence will be communicated to you in writing, in advance.
Use of automated decision-making and profiling
Harwyn does not engage in automated profiling.
Contact us
All related queries should be addressed to Harwyn at:
Address: Harwyn Ltd, Carnmore, 78 Hawthorn Heights, Letterkenny, Co. Donegal.
Phone: 087 26090904
Statutory complaints can be addressed to the Data Protection Commission, Canal House, Station Rd, Port Arlington, Co. Laois.
Use of cookies and other technologies
Harwyn does not apply the use of cookies or capture specific data through its website.
Date of Statement
20.09.2020
Further Information
Further Information on your Rights under GDPR can be accessed through the Data Protection Commission’s website: www.dataprotection.ie