This Privacy Statement covers the processing of personal data in the course of the performance of Services by the Ibec TU, and Ibec CLG and its affiliate entities. Unless otherwise stated, when we refer to “Ibec”, “we”, “us” or “our” in this Privacy Statement we mean:
- Irish Business and Employers Confederation, a registered trade union (“Ibec TU”);
- Ibec Company Limited by Guarantee (“Ibec CLG”);
- The Irish Whiskey Association; and
- Ibec Global Graduates Company Limited by Guarantee (“Ibec Global Graduates”).
This Privacy Statement also applies to processing undertaken by Ibec trade associations and policy groups. Some of these associations or groups may have supplemental privacy notices specific to their roles, in which case they apply in addition to this Privacy Statement. When we refer to “Services” in this Privacy Statement we mean the full range of Ibec services that are described in detail in Section 2 below.
1. Types of information collected by Ibec
We collect and process two types of information, personal data and non-personal data.
"Personal Data": This is data that identifies you or can be used to identify you. It includes the following:
- Personal Data Collected Directly From You
We receive personal data from you when you provide it to us through a variety of means including via the Ibec website, when you communicate with us directly or through our social media channels, when you apply to join a particular group or association within Ibec or when you attend Ibec events or training courses.
- Personal Data We Automatically Collect
Some personal data is automatically collected when you use our website, such as IP address, device identifiers, browser information and cookie data (see our Cookies Policy for further details).
- Personal Data We Receive from Others
We also receive personal data from third parties where it is relevant to, or necessary for, the performance of our Services. For example, employers may give us the names and contact details of staff they wish to nominate to participate on Ibec committees or groups and we source business contact data from publicly available sources where it is relevant to Ibec’s business.
“Non-Personal Data”: We also gather statistical and other analytical information collected on an aggregate basis in relation to, for example, visitors to our website, attendance at our online or in person events etc. We use this to develop and improve our Services. As this “non-personal data” does not identify any specific individuals, it is not subject to this Privacy Statement.
2. Purposes for which Ibec Processes Personal Data
Ibec processes personal data to offer, operate, improve, understand and personalise our Services.
Below is a description of Ibec Services and the lawful basis that Ibec relies on to support the use of personal data in each case.
Purposes of processing/Lawful Basis under GDPR
This processing is necessary for the performance of a contract between Ibec and its members in accordance with the Ibec Membership Contract and Ibec Rules. For example, we process membership applications, event bookings, training or publication purchases. (We refer to this as “Service Delivery”).
Trade Associations Services
Service Delivery. In addition, Ibec relies on its legitimate interests to process personal data for purposes relevant to Ibec’s trade associations. Because this data is mainly publicly available contact data which is used for its intended business contact purposes, we are satisfied that such use does not infringe on the rights or freedoms of data subjects. (We refer to this as “Legitimate Interests”).
Service Delivery and Legitimate Interests. It is in Ibec’s legitimate interests to provide training services. Where training is for non-members the terms of any applicable training services contract govern the Service.
Business Representative Purposes
Legitimate Interests. To represent our members and to provide information on relevant developments. This includes performing our lobbying campaigns on behalf of Irish businesses.
Legitimate Interests. Ibec offers and provides online and in–person training, education services, awards ceremonies and a range of other webinars and events for members and non-members. It is in Ibec’s legitimate interest as a business representative organisation to offer such events to its members and to encourage non-members to join Ibec or participate in non-member events.
eZines and Direct Marketing
Legitimate Interests and Consent. Our eZines are part of our Services to our members. We include relevant members in our distribution lists based on the relevance of their roles and/or their consent. Even though they do not constitute “direct marketing” communications, we ensure that all such communications include an unsubscribe option (see section 7 below).
Quality Control and Service Improvement
Legitimate Interests. We evaluate our Services regularly to ensure they are relevant and of interest to our members.
Legitimate Interests. For example, we use virus control software to scan communications in and out of Ibec for malware.
Legitimate Interests. Communicating with those who contact us directly, through our website or via social media channels.
Enforcing and Defending Our Rights
Legitimate Interests. Ensuring that our Services are used lawfully, for their intended purposes and in accordance with our policies. We will also process personal data where it is necessary for the purpose of complying with our legal obligations or for the purpose of establishing, exercising or defending actual or prospective legal claims or legal proceedings.
Recruitment and Selection Purposes
Legitimate Interests. Recruitment of new employees. Selection of contractors e.g. for the delivery of training or education programmes.
Below is a description of Ibec TU Services and the lawful basis that Ibec TU relies on to support the use of personal data in each case.
Service Delivery. For those of our members who avail of our HR and employer services, including legal services. This includes representing our members and advocating on behalf of our members in front of third parties at workplace negotiations and before the Workplace Relations Commission and the Labour Court.
Below is a description of Ibec Global Graduates’ Services and the lawful basis that Ibec Global Graduates relies on to support the use of personal data.
This processing is necessary for the performance of a contract between Ibec Global Graduates and graduates availing of our graduate placement programme.
Legitimate interests. To advertise placements available to graduates and for graduates to apply to such placements.
Below is a description of The Irish Whiskey Association Services and the lawful basis that The Irish Whiskey Association relies on to support the use of personal data.
The Irish Whiskey Association Member Services
Legitimate interests. Members may receive communications relating to the business of The Irish Whiskey Association Services or Ibec. Such communications may include commercial offers from third parties where is it is directly linked to the business of The Irish Whiskey Association.
3. Disclosure of information to third parties
Ibec may share personal data with third parties including organisations Ibec partners with (for example, to run events with), industry groups, national and international officials, media and commentators. This personal data will generally consist of name and contact details. Ibec Global Graduates may share personal data with companies that are part of Ibec Global Graduates’ graduate placement programme. Ibec Global Graduates may also share personal data with service providers such as CV and graduate placement advertising service providers, educational service providers, talent consultancy providers and others. If you are attending an Ibec event, Ibec may share your name, job title and company with other delegates attending the event.
In respect of employment relations services provided by Ibec TU, personal data may be included in submissions made to third party dispute resolution fora such as the Workplace Relations Commission and the Labour Court.
Contact details for independent contractors that provide training or other services on Ibec’s behalf may be shared with third parties such as education providers and Ibec’s members where reasonably necessary for the purposes of identifying potential training or other opportunities or arranging and delivering the relevant courses.
Ibec may engage the services of third parties to assist it in the performance of its Services. For example, we may partner with third level or other education or training providers and we may engage contractors to assist in the design and delivery of our events or in supporting our IT or other systems. Where these third parties are processing personal data on our behalf we will apply the appropriate data processing clauses in our contracts with the third parties as required by data protection laws. Where those third parties operate as independent controllers, they, and not we, are responsible for the processing of your data.
Ibec may be required to disclose personal data to third parties, including law enforcement agencies, where it is necessary to comply with our legal obligations, to protect the vital interests of Ibec or third parties or for the purpose of establishing, exercising or defending actual or prospective legal claims.
Personal data may also be transferred in the context of any re-structure or reorganisation of Ibec’s business. In that case, we will notify people if there is a material change to the purposes outlined in Section 2.
In some instances (i) Ibec CLG and Ibec TU; (ii) Ibec CLG and The Irish Whiskey Association; and (iii) Ibec CLG and Ibec Global Graduates may act as joint controllers. In addition, Ibec CLG may act as a processor for the purpose of providing business support services to Ibec TU, The Irish Whiskey Association and Ibec Global Graduates. In the interests of clarity, Ibec CLG will manage these arrangements and Ibec CLG will deal with any questions, complaints, investigations or enquiries arising from this Privacy Statement (see “Your Rights” and “Contact” below).
4. Data transfers
We may occasionally transfer personal data outside the EEA. Any such transfers will be in accordance with applicable law and appropriate safeguards such as the standard contractual clauses approved under EU law from time to time. If you require further information please contact email@example.com.
Personal data is held on Ibec’s secure servers on Ibec premises and also on third party cloud Software as a Service (SaaS) platforms. The nature of the Internet is such that Ibec cannot guarantee or warrant the security of any information transmitted to us via the Internet as no data transmission over the Internet can be guaranteed to be 100% secure. However, once we receive personal data, we implement appropriate security measures to protect it.
We process payment card or bank transfer details using a secure on-line payment service and Ibec does not have access to this information. Credit card payments by telephone or email will only be retained until payment for the event has been successfully completed.
We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as described in this Privacy Statement) and for a reasonable period thereafter to enable Ibec maintain records of its business and interactions. For example, in respect of members, we keep employer relation files for seven years from file closure (to allow for any potential legal or other claims) while member contacts are generally retained for as long as the member organisation remains a member and for a period of 2 years thereafter. We may be required to retain personal data for longer periods in the event of legal proceedings or investigations.
Ibec will retain contact details of independent contractors that provide training or other services for Ibec until such time as the contractor ceases to offer relevant services.
7. Newsletters and eZines
We offer online subscription to a number of newsletters and eZines on our website, for example Ibec Agenda and Ibec HRLink. We record and save the subscriber’s data to:
- send the newsletters; and
- analyse the number of subscribers and the types of industries that are interested in our publications in order to tailor future content.
Recipients can stop receiving our newsletters or eZines at any time by using the ‘unsubscribe’ link in every issue. Email addresses may be retained to avoid inadvertently re-subscribing a person who has opted out.
9. Your rights
Data protection laws confer certain rights in favour of data subjects (the “Data Subject Rights”). Data Subject Rights include the right of a data subject to:
- be informed about processing of personal data as outlined in this Privacy Statement
- access personal data
- object to personal data processing in certain circumstances;
- withdraw consent to processing where processing is based on consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal;
- object to any direct marketing – either use the ‘unsubscribe’ button on our emails or contact us directly by email at firstname.lastname@example.org
- personal data portability
- rectify or erase personal data (i.e. right to be forgotten)
- restrict processing.
These Data Subject Rights are subject to certain exceptions and limitations as provided for under data protection laws. To exercise any of these rights, including in respect of processing for which Ibec TU and Ibec CLG, Ibec CLG and The Irish Whiskey Association or Ibec CLG and Ibec Global Graduates act as joint controllers please email us at email@example.com. Where applicable, Ibec will ensure that the request is dealt with by the appropriate controller.
If you are not happy with the way we have handled your data, and are unable to resolve the issue with us directly, you can complain to the Data Protection Commission.
10. Changes to this Privacy Statement
Any changes to this Privacy Statement will be posted on the Ibec website. If we decide to use Personal Data in a manner significantly different from that stated in this Privacy Statement, or otherwise disclosed at the time it was collected, we will notify the relevant individuals by e-mail, and they will have a choice as to whether or not we use the information in the new manner proposed.
If you have any questions regarding the above statement please contact us at firstname.lastname@example.org
Ibec TU is registered in Ireland with registration number 454T and having its registered address at Confederation House, 84/86 Lower Baggot Street, D02 H720, Ireland. Ibec CLG is incorporated in Ireland with company registration number 8706 and having its registered address at Confederation House, 84/86 Lower Baggot Street, D02 H720, Ireland. The Irish Whiskey Association is registered in Ireland with registration number 539839 and having its registered address at 84/86 Lower Baggot Street, D02 H720, Ireland. Ibec Global Graduates is incorporated in Ireland with company registration number 306809 and having its registered address at Confederation House, 84/86 Lower Baggot Street, D02 H720, Ireland.