PRIVACY STATEMENT

 

Who collects my data?

 

Your privacy is important to Healthy Workforce Limited “HWF”.  This privacy statement provides information about the personal information that Healthy Workforce Limited collects, obtains, and the ways in which Healthy Workforce Limited uses that personal information. HWF will process your personal and health information in accordance with the General Data Protection Regulation 2016 (“GDPR”) which is in effect as of 25 May 2018. As data controllers HWF employs appropriate technical and organisational measures to meet the requirements of GDPR.

 

 

Our Data Code of Conduct

 

Obtain and process information fairly;

Keep it only for one or more specified, explicit and lawful purposes;

Use and disclose it only in ways compatible with these purposes;

Keep it safe and secure;

Keep it accurate, complete and up-to-date;

Ensure that it is adequate, relevant and not excessive;

Retain it for no longer than is necessary for the purpose or purposes;

Give a copy of his/her personal data to an individual, on request.

 

What type of data is collected?

 

Personal data and information collected

 

HWF may collect and use the following kinds of personal information: 

 

·       information about your use of this website; 

·       information that you provide for the purpose of registering with the website;

·       information about transactions carried out over this website; 

·       information that you provide for the purpose of subscribing to the website services; and

·       any other information that you send to Healthy Workforce Limited.

 

Personal data collected with your consent can be used to identify or contact you and may include: your name, address, date of birth, telephone number, and email address.  This information will only be collected if you voluntarily submit it to us.

 

Sensitive data and information collected

 

Sensitive personal data relating to your health, voluntarily submitted to us by you is collected with your consent, and for the purpose of clinical assessment, treatment, programme provision or advice, and is necessary to be obtained in order to provide the most accurate service for you.

 

 

How we collect personal information

 

You have the option to register on the Healthy Workforce Limited website where you will need to provide us with some personal details to complete registration such as an email address and telephone number.  You can also provide us with additional information, which will allow us to provide you with a more personalised experience whenever you visit our website. While Healthy Workforce Limited makes all commercial efforts to protect our customers’ privacy, customers should be aware that information disclosed while connected to the Internet is transferred to the Healthy Workforce Limited servers over a publicly available telecommunications network. Healthy Workforce Limited cannot be held responsible, and accept no liability, for unauthorised access to the public network beyond its reasonable control and all information provided by customers is done entirely at the customers’ own risk.

 

 

What is my data being used for?

 

Using and processing personal information

 

 

Healthy Workforce Limited may use your personal information to: 

 

·       administer this website;

·       respond to your inquiries or provide customer support;

·       verify your identity;

·       assess your medical status and book your appointment(s);

·       send updates regarding your appointment and programmes;

·       personalise the website for you;

·       enable your access to and use of the website services;

·       publish information about you on the internal secure website;

·       supply and offer services;

·       send you statements and invoices;

·       to contact you in the event of a data breach;

·       collect payments from you; and

·       send you marketing communications.

 

 

The data shall not be further processed in any manner incompatible with that purpose or those purposes. Where Healthy Workforce Limited discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement. 

 

As far as possible, we will not disclose personal data without consent. Healthy Workforce Limited may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.

 

Direct Marketing

 

HWF will never use your data for direct marketing purposes without your consent. At any time, you may opt-out (i.e refuse the use of your personal data for direct marketing), including at the time the data is collected, or on every subsequent marketing message. Unsubscribing will always be free of charge and fully respected. Other forms of communication including appointments or reminders do not fall under “direct marketing “however your consent will be required and you will have an option to opt out or unsubscribe. If you subscribe to our email newsletter, we use email tracking to record and save your email address to your subscriber record to monitor and store your preferences.

 

When you attend an HWF service clinic you will be asked to provide data including sensitive data to allow us service to complete the following;

            Perform a clinical assessment

            Provide you with appropriate treatment, programmes and or advice.

 

 

How secure is my data?

 

Securing your data

 

We take our security responsibilities seriously, taking all reasonable steps including appropriate technical and organizational measures to protect your data. We review our security measures regularly.

 

Your personal and health data is stored securely, offsite and in electronic format. All electronic communications are hosted within platforms which are SSL-secure, password protected and encrypted. Any personally identifiable information you make available on our site or social media sites, for example by posting a comment, will be available to others.

 

Access is restricted to essential personnel of HWF who are bound by their professional ethics and/or confidentiality agreements. We provide non-personal data to third parties, where such information is combined with similar information of other users, e.g we may inform third parties regarding the number of unique users who visit our website, activities visitors to our webpage engage in while on our website.

 

The third parties to whom we may provide this information may include, commercial partners, sponsors, licensees, researchers and other similar parties. We will not disclose your personal data to third parties unless you have consented to this disclosure or are required to do so by law.

 

HWF will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Healthy Workforce Limited will store personal information you provide securely. 

 

 

Retention of Data

 

 

We keep your personal data for as long as relevant and necessary for the purposes for which it was collected and to provide you with services, to conduct our legitimate business interests or where otherwise required by law. We will retain your data for the lifetime of your account with us and for a period thereafter in accordance with our information retention policy. We are required to hold certain communications data in line with our obligations under the Communications (Retention of Data) Act, 2011. We will not hold information longer than necessary.

 

Relevant and up to date Information.

 

 

Information HWF stores are accurate, complete and where necessary up to date.

 

What about social platform marketing?

 

Facebook Conversion Tracking Pixel

 

HWF may, from time to time, use Facebook Advertising, Facebook Pixel Re-Marketing, and communications. This tool allows us to understand and deliver ads, making them more relevant to you. The collected data remains anonymous, and we cannot see the personal data of any individual user. However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes (in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/). Facebook has ultimate control of the information gathered through Facebook Advertising, Facebook Pixel Re-Marketing, and communications. You can opt-out of Facebook’s use of cookies and Facebook Pixel Re-Marketing through settings on your Facebook Account.

 

 

Google Remarketing

 

HWF may from time to time, utilise Google’s remarketing technology. This allows us to display relevant ads based on the pages on the HWF website you have viewed. The advertisements will be displayed using cookies. This cookie will not record any personal information or identify you personally. If you would prefer to not receive any targeted advertisements, you can deactivate the use of cookies for these purposes through Google by visiting the website: https://www.google.com/settings/ads/. Google has its own data protection policy which can be accessed here: https://www.google.com/intl/en/policies/privacy/.

 

 

What are my rights?

 

Your rights include but are not limited to the following:

 

• Access and request personal or sensitive personal data about yourself;

• Rectification, to correct any information if it is incomplete or misleading;

• Withdraw your consent regarding the processing of your data at any time;

• Erase information, you have a right to request to delete your information;

• Restrict processing, you have a right to restrict processing of your personal information;

• Object to data processing of your personal information;

• Object to direct marketing;

• You have a right to data portability.

• Review our Data Protection Policy;

• Ask any questions about your data.

• You have a right to lodge a complaint with the regulator;

 

A right of access to your data

 

You have the right to access, erase or correct information held about you in certain circumstances. You have the right to request a copy of any personal information we hold about you. To make such a request, please write by sending an email to info@healthyworkforce.ie.

 

You have a right to lodge a complaint with the regulator.
 

If you wish to raise a complaint in relation to how we handled your personal information, you can raise a complaint online. We hope to address your concerns through our normal complaints process, however, we may escalate your complaint to our Data Protection Officer for further investigation. You also have the right to contact

 

The Data Protection Commissioner;

Canal House, Station Road,

Portarlington,

R32 AP23,

County Laois,

Ireland.
 

Phone: +353 (0761) 104 800 
LoCall: 1890 25 22 31
E-mail: info@dataprotection.ie

For more information, visit www.dataprotection.ie.

 

 

You have a right to data portability.

Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format (subject to certain exemptions). You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

 

Sharing of Data with Third Parties

 

We reserve the right to transfer information (including your personal data) to a third party in the event of a proposed sale, sale, reorganisation, transfer, financial arrangement, sub-participation, asset disposal or other transaction relating to our business and/or assets held by our business. Provided that the third party agrees to adhere to the terms of the Website Privacy Policy, and provided that the third party will only use your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-in.

 

in anonymized form as part of statistics or other aggregated data shared with third parties; or
 

where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

 

Updating this statement

 

Healthy Workforce Limited may update this privacy policy by posting a new version on this website.  

You should check this page occasionally to ensure you are familiar with any changes.  

 

Other websites

 

This website contains links to other websites. Healthy Workforce Limited is not responsible for the privacy policies or practices of any third party.

 

 

Contact Healthy Workforce Limited

 

If you have any questions about this privacy policy or Healthy Workforce Limited’s treatment of your personal information, please write:

 

·       by email to info@healthyworkforce.ie; or 

·       by post to Apt 61 Park Lodge, North Circular Road, Dublin 7

 

May 2018