Privacy Notice

This Privacy Notice is issued by Westmeath Support Service Against Domestic Abuse of 7 Grove Street, Mullingar, Co. Westmeath (“Westmeath Support Service”, “WSSADA” “we”, “our”).

During the course of our work, we are required to collect and process personal information from many stakeholders, including our service users, our donors and training attendees. At WSSADA, we are committed to ensuring that personal data collected and processed is treated lawfully and correctly and complies with data protection law, including the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The controller (as defined in the GDPR) of your personal data, for all purposes outlined in this Privacy Notice, is WSSADA. Information provided by you is held in strict confidence.

WSSADA is not responsible for the content or privacy practices of any linked sites.

Definitions

“Personal data” means any information relating to an identified or an identifiable person (‘data subject’); an identifiable person is one who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion or philosophical beliefs, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

How we collect, use and retain your Data

The information we collect and how we process your data will depend on your relationship with Westmeath Support Service Against Domestic Abuse. If you avail of our One-to-One Support Services (Outreach and Court Accompaniment), our staff will review the Information and Confidentiality Notice with you during your initial meeting and prior to collecting any personal data relating to you. Due to the nature of this service and the level of distress some women may be in on contact with this service, it may be difficult to provide this information to every woman. Due to the nature of this service and the level of distress some women may be in on contact with this service, it may be difficult to provide this information to every woman. Due to this, we encourage service users to read our ‘Information and Confidentiality Notice’.

If you avail of our One-to-One Support Services (Outreach and Court Accompaniment) we will collect information about you and your family, including:

Personal details about you, for example your name, age, your health.
Safe ways to contact you.
Personal details about your children.
Details about what is happening or has happened.
Any risks that you or your family are experiencing.
Information about anyone else supporting you.

Retention of your personal data by WSSADA

WSSADA will hold your data for a period of three years. If after that period of time, you are not in contact with our Service, we will delete your records in line with our GDPR Policy.

Website Usage Data

Technical details in connection with visits to this website are logged for our statistical purposes. When you visit our website, the following information is retained about that visit:

the IP address of your internet connection;
the type of browser you are using;
the date and time you accessed our site;
the pages you accessed on our website and any documents you downloaded;
the previous website from which you reached us, including any search terms used.

How WSSADA use this data:

WSSADA will make no attempt to identify individual visitors, or to associate the technical details listed above with any individual. This information is used to allow us improve the information we are supplying to our users, find out how many people are visiting our sites and for statistical purposes. Some of the above information is used to create summary statistics which allow us to assess the number of visitors to the different sections of our site, discover what information is most and least used, inform us on future design and layout specifications, and help us make our site more user friendly.

Legal basis for Processing Special Category Data

Depending on the service that we are providing, WSSADA may collect Special Categories of personal data relating to you such as your racial or ethnic origin, nationality and data relating to your health.

The legal bases on which we process special categories of personal data relating to you are that:

You have given your explicit consent to the processing of your personal data;
Where we need to protect the vital interests of you or another;
The processing is carried out in the course of our legitimate activities as a non-for-profit body;
The processing is necessary for the provision of health or social care;

Special Category Data may be processed for statistical purposes on the condition it meets conditions set out to safeguard the identification of the Data Subject in addition to adhering to the principle of data minimisation. WSSADA ensures that all personal and special categories of data are anonymised for reporting purposes.

Processing Criminal Data

To deliver an effective level of service, it is necessary for the organisation to record information deemed relevant to the Woman’s circumstances. We do not record personal information about women or third parties that is not deemed relevant, for example, data relating to criminal convictions such as shoplifting. An exception, however, is where there are implications for safety of women or staff and where this is the case, we may process personal data relating to criminal convictions and offences in accordance with section 55(1)(b) of the Data Protection Act.

Data Security

To protect the security of all personal data, WSSADA have appropriate technical and organisational security measures in place. These include:

Encryption, and where appropriate and feasible, pseudonymisation of personal data.
WSSADA ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
We have processes for regular testing, assessing and evaluating the effectiveness of both technical and organisational measures for ensuring the security of data processing.
Personnel who have access to the data are trained to ensure our work is carried out with complete confidentiality.

Sharing your information with Third Parties

WSSADA’s Direct ‘Face-to-Face’ Services:

Generally, the information you share with us about yourself, your family and others and your situation will be treated as confidential by WSSADA. This means that only WSSADA staff will have access to this information unless you say otherwise.

Sometimes during our support work with you, you may request us to speak/ we may suggest that we speak, to other agencies outside of WSSADA on your behalf (for example the Court Services, An Garda Síochána, Local Housing Authority, the Department of Social Protection). You do not have to give your permission; you can say no.

Sometimes we are legally required to share information to keep you and your family safe. We do not need your permission to do this but we will always try to discuss this with you as soon as we can, unless it risks safety to do this. The agencies that we usually share information with, in these cases are An Garda Síochána, social services, or other emergency services.

WSSADA receives funding for our services. WSSADA has to give reports to our funders to show the number of people we work with and how we are working with them. This shows numbers of clients; it does not give any names. It is not possible to identify you from the numbers we give to our funders.

We might make your and other women’s stories anonymous, use pseudonyms and remove/change any identifying information and share this with funders, other agencies and researchers outside the organisation.

We share information in this way to ensure that your or your family’s identity will never be released.

Requirement to Provide Personal Data

You are not under a statutory or contractual obligation to provide us with any personal data. However, if you wish to avail of our services, to attend our training events or to donate to WSSADA, we will require certain personal details relating to you. If you do not provide us with the information required, we may not be in a position to assist you.

Your Data Protection Rights

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

Right of Access: you have a right to request a copy of any personal data held by a controller about you.
Right of Rectification: you have the right to request controllers to rectify inaccurate or incomplete data they hold about you.
Right to erasure: you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
Right to restrict or to object to processing: You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
Data portability: You can request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used, machine-readable format.

For further detailed information about your data protection rights please visit the website https://www.dataprotection.ie/

If you wish to exercise any of the rights set out above, you can talk to your Support Worker.

Data Access Request Procedure

Due to the nature of Personal Data held by the organisation and in keeping with our mission to safeguard women, WSSADA stipulate that data access requests are made in writing. If you wish to make a data access request you can contact WSSADA by emailing manager@wssada.ie or by post to Service Manager, 7 Grove Street, Mullingar, Co. Westmeath, N91 Y6W8.

You will be required to include the following details with your request to ensure WSSADA can accurately identify the appropriate records:

Full name provided when using our services
Relevant time period(s) you accessed our services
Any other information which may help us to locate your record
Contact telephone number

Due to the sensitive nature of our services and the importance of confidentiality, you will be required to verify your identity in person to access the information requested. The following verification documents are required and must be dated within the previous 3 months:

Proof of identity, such as passport, driving licence or birth certificate
Proof of address, such as utility bill, bank or credit card statement or revenue tax document.

Upon receipt of your request, WSSADA will contact you to make an appointment for verification purposes within 2 to 3 weeks from the date your request was received. Within 30 calendar days from the date, we verify your identity, WSSADA will provide you with the information requested. However, where requests are complex or numerous, WSSADA may extend the period of compliance by a further two months.

Data access requests are free of charge. However, we will charge a ‘reasonable fee’ when the request is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information. This fee is based on the administrative cost of providing the information.

f you have concerns regarding your data

If you are concerned with how your data is being collected, processed or stored or if your rights about your data are not adhered to by an organisation, you can contact the Data Protection Commission online or by post as follows:

Online: https://www.dataprotection.ie/en/contact/how-contact-us

Post: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.

Updates

WSSADA may occasionally update our Privacy Notice. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.

Privacy Notice for External Parties

This is a general privacy notice for anyone who may be connected to a woman who uses our services.

In general, WSSADA only collects the personal data of women who access and use our services. We may retain information about other individuals from women availing of our services but in these cases, we only retain the minimum amount of information necessary for the purposes of complying with a legal obligation that applies to us, for the purposes of defending litigation, or for our legitimate interests in providing services to our users. This information may include names, addresses, dates of birth, details about family circumstances and other information we may be legally obliged to collect, such as for any referral made to Tusla under child protection obligations. In general, however, this information is recorded anonymously. We may transfer personal data to regulatory authorities and law enforcement agencies. We only store this information for the length of time necessary to comply with our legal obligations or to defend legal claims.

Anyone whose personal data is collected and processed by WSSADA has the following rights: the right to access, rectification, objection, deletion, and portability. These rights are only available in certain circumstances and may not be available in some cases. WSSADA takes the confidentiality of its service users very seriously and does not generally discuss any individual case with third parties. Due to this confidentiality and the nature of WSSADA of working with women experiencing abuse, it is WSSADA policy, where we are entitled to do so under applicable law, not to grant data protection requests made by other individuals as a result of the possible risk to women who use our services.

If you proactively contact us regarding the recipient of our service, then we may inform the woman who avails of our service of this contact if it is in the interests of the woman to do so.

If you are not happy with the way we have used your information or addressed your rights, you have the right to make a complaint to the Irish Data Protection Commission: https://www.dataprotection.ie/.