Privacy Statement

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The Independent Reviewer (the “Independent Reviewer”) of CA Compliance Limited at 26 Upper Pembroke Street, Dublin 2, Ireland is an individual who provides an uninvolved and unbiased evidenced-based adjudication of a matter on which a decision has been communicated by an organisation or body.

The independent Reviewer is an individual who has had no role or responsibility for any part of a matter under review, assuring an impartial and objective adjudication.

The Independent Reviewer will not be an employee of the organisation nor a member of the body of which a decision is before her to review.

The Independent Reviewer takes her responsibilities under applicable data protection law, including the General Data Protection Regulation and implementing legislation such as the Data Protection Act 2018 very seriously.  The purpose of this notice is to inform you of the data relating to you that the Independent Reviewer may collect and use in connection with your complaint and the uses (including disclosures to third parties) the Independent Reviewer may make of such data.

The Independent Reviewer is the controller of this personal data. If you have any questions about the use of your personal data, please contact the Independent Reviewer at reviewer@independentreviewer.ie.

Personal Data that the Independent Reviewer collects from you

The Independent Reviewer may collect and process personal data relating to you in connection with your complaint to include:

  • your name and contact details, including your address, phone number, email address and post code;
  • any previous correspondence with the organisation or body in relation to your complaint including the reference used them in such correspondence;
  • the date on which the organisation or body made its decision in relation to your complaint;
  • where relevant, details of the services which are the subject of your complaint investigated by the organisation or body; and
  • any other personal data which you provide to the Independent Reviewer directly.

Personal Data that the Independent Reviewer collects from other sources

The Independent Reviewer will collect and process personal data relating to you in connection with your complaint from the organisation or body.

Purposes of Processing and Legal Basis

The Independent Reviewer will use personal data relating to you for the purposes of:

  • receiving and examining your complaint against the organisation or body;
  • contacting you in order to provide you with updates in relation to your complaint and to notify you of the outcome of your complaint;
  • requiring the production of documents in the possession of the organisation or body in connection with the investigation and examination of your complaint;
  • where applicable, notifying any named party who is a subject of the complaint that the complaint is being independently reviewed and that the files have been requisitioned from the organisation or body;
  • where applicable, notifying any named party who is a subject of the complaint of the outcome of your complaint;
  • where applicable, producing an annual report on the activities of the Independent Reviewer for an organisation or body (wherever applicable, personal data will be anonymised before being used for this purpose); and
  • complying with any legal and regulatory obligations.

The legal bases on which the Independent Reviewer collects, processes and transfers your information in the manner described above are:

  • that this is necessary for compliance with any legal or regulatory obligation that applies to the Independent Reviewer; and
  • that this is necessary for the performance of tasks that the Independent Reviewer carries out in the public interest or in the exercise of official authority vested in the Independent Reviewer by law or otherwise.

Recipients of Data

The Independent Reviewer may disclose your personal data to other organisations in connection with the above purposes, including:

  • to the organisation or body;
  • to any named party who is a subject of your complaint;
  • to third parties who the Independent Reviewer engages to provide services or benefits to her or to you, such as professional advisers; and
  • to competent regulatory authorities and other bodies where requested or required by law.

Requirement to Provide Data

You are not under a statutory or contractual duty to provide the Independent Reviewer with any personal data. However, there are some pieces of information that you must provide to the Independent Reviewer so that she can examine your complaint. If you do not provide the Independent Reviewer with this information, she may not be able to examine your complaint in a fulsome manner.

Retention

The Independent Reviewer will not hold your data for longer than is necessary. The Independent Reviewer may retain your personal data for as long as she needs it for the purposes described in this Notice, or to comply with her obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and the Independent Reviewer.

Transfers Abroad

In connection with the above the Independent Reviewer might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that the Independent Reviewer does so, she will ensure that appropriate measures are in place to comply with her obligations under applicable law governing such transfers.  These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that the Independent Reviewer has taken in this regard, please contact the Independent Reviewer at reviewer@independentreviewer.ie.

Your rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

  • Right to access the data – You have the right to request a copy of the personal data that the Independent Reviewer holds about you, together with other information about the processing of that personal data.
  • Right to rectification– You have the right to request that any inaccurate data that is held about you is corrected, or if the Independent Reviewer has incomplete information you may request that she update the information such that it is complete.
  • Right to erasure– You have the right to request the Independent Reviewer to delete personal data that she holds about you. This is sometimes referred to as the right to be forgotten.
  • Right to restriction of processing or to object to processing– You have the right to request that the Independent Reviewer no longer processes your personal data for particular purposes, or to object to the processing of your personal data for particular purposes.

If you wish to exercise any of the rights set out above, please contact the Independent Reviewer at reviewer@independentreviewer.ie.

Complaints

If you have any queries or complaints in connection with the processing of your personal data, you can contact the Independent Reviewer at info@cacompliance.ie.

You also have the right to lodge a complaint with the Irish Data Protection Commission if you are not happy with the way the Independent Reviewer has used your information or addressed your rights.  Details of how to lodge a complaint can be found at (https://www.dataprotection.ie/docs/Contact-us/11.htm) or you can call the Data Protection Commission at 353 (0)761 104 800.

Independent Reviewer
CA Compliance Limited

Updated 10 October 2018