In this Privacy Notice the following definitions shall apply:
“Client Personal Data” means any personal data provided to us by you, or on your behalf, for the purpose of providing our services to you, pursuant to our engagement letter with you;
“Data Protection Legislation” means all applicable privacy and data protection legislation and regulations including the General Data Protection Regulation EU 2016/679 as supplemented by the Data Protection Bill 2018 together with other laws which relate to privacy and electronic communications;
“Data Subject” means an individual to whom personal data relate;
“Joint Controller” means, where 2 or more controllers jointly determine the purposes and means of the processing of personal data (referred to as “joint controllers” per the Data Protection Bill 2018), they shall determine their respective responsibilities for compliance in a transparent manner by means of an agreement in writing between them, save in so far as the said responsibilities are determined by the law of the European Union or the law of the State.
“Personal Data” means information relating to—
“Processing” of or in relation to personal data, means an operation or a set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, including—
“Processor” means an individual who, or a legal person, public authority, agency or other body that, processes personal data on behalf of a controller, but does not include an employee of a controller who processes such data in the course of his or her employment;
“Special Categories of Personal Data” means—
2. WHO WE ARE
This privacy notice provides you with details of who we are and how we collect and process your personal data.
This is the privacy statement of MICHAEL F. DOLAN & CO. LTD. (trading as MICHAEL F. DOLAN & CO. Statutory Auditors and Accountants) whose place of business and registered address are Park House, Main Street, Loughrea, Co. Galway.
MICHAEL F. DOLAN & CO. Statutory Auditors and Accountants “the Firm” (referred to as “we”, “us” or “our” in this privacy notice), is a data controller due to our professional obligations which oblige us to take responsibility for your personal data.
Each client is also a Data Controller (referred to as “the Client”, “You”, or “Yours” in this privacy notice). Michael F. Dolan & Co. and each client are not Joint Controllers.
Our email address is: email@example.com
Our postal address is: Park House, Main Street, Loughrea, Co. Galway.
Our firm’s GDPR owner is Michael F. Dolan.
We are not required to appoint a Data Protection Officer. If you have any questions about this privacy notice, including any requirements to exercise your legal rights please contact Michael F. Dolan.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org.
3. THE DATA THAT WE COLLECT ABOUT YOU, THE PURPOSE FOR WHICH WE COLLECT IT AND THE GROUNDS UPON WHICH WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
For the purposes of this privacy notice the firm provides the following services:
You shall only disclose client personal data to us where:
We shall only process your personal data:
We may process the following categories of personal data about you:
We need to collect the following Special Categories of Data in order to provide the agreed services for which we have been engaged. (e.g. some data regarding employees, their spouses, children and dependent relatives may be processed for the purposes of calculating personal tax credits and allowances. Details of trade union membership of employees may be processed in order to calculate deductions from payroll.)
If your Engagement Data includes special categories of data such as medical or health data we will only process such special categories of data for the purposes of providing you with compliance advice and acting for you as your accountant/auditor in connection with the agreed engaged services
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the agreed service for which we have been engaged (for example, to continue to act for you in Revenue enquiries). If you don’t provide us with the requested data, we may have to cease to act for you but if we do, we will notify you at the time.
We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
4. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our website or in our offices or by sending us emails and correspondence by post or by speaking with us on the telephone and in meetings). We may collect data from third parties who you authorise us to obtain the data from on your behalf (for example the Revenue Commissioners, the Companies Registration Office, financial institutions or another professional or adviser).
5. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either by your consent or our legitimate interests (namely to grow our business).
Under the Data Protection Legislation, we may send you electronic marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
We will not share your personal data with any third party for their own marketing purposes without your express consent.
You can request us to stop sending you electronic marketing messages at any time by following the opt-out links on any marketing message sent to you.
You can request us to stop sending you marketing messages by post at any time emailing us at email@example.com, by writing to us at Park House, Main Street, Loughrea, Co. Galway or by telephoning us at 091-841518.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided in connection with a matter on which we are acting or have acted on your behalf and are obliged to obtain a record of for the purposes of complying with our legal obligations.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
7. DATA SECURITY
We have put in place commercially reasonably and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep data for six years after the conclusion of any engagement in order to comply our regulatory and tax obligations. In order to be in a position to establish, exercise and defend our legal rights, the firm has a policy of retaining all documentation in relation to engagements for seven years and half years from the date that the documentation was first received or created by the firm, or the completion date of the agreed service for which we have been engaged.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for legal know-how, research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:
By consenting to this privacy notice you are giving us permission to process your personal data for the purposes identified.
If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.
You can see more about these rights at:
Should you require any further details regarding our treatment of personal data, please contact Michael F. Dolan & Co.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). Please contact us first if you do have a complaint so that we can try to resolve it for you.