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      1. UNIVERSITY
      2. Legal Documentation

      Privacy Policy

      How we manage your information

      We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

      We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in Ireland) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

      Key terms

      It would be helpful to start by explaining some key terms used in this policy:

      We, us, our

      i3pt Certification Association Limited trading as Catalyst and our group companies

      Personal information

      Any information relating to an identified or identifiable individual

      Special category personal information

      Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

      Genetic and biometric data

      Data concerning health, sex life or sexual orientation

      Personal information we collect about you

      We may collect and use the following personal information about you:

      • your name and contact information, including email address and telephone number and company details
      • Information to enable us to check and verify your identity, eg your date of birth
      • your gender information, if you choose to give this to us
      • location data, if you choose to give this to us
      • your billing information, transaction and payment card information
      • your personal or professional interests
      • your professional online presence, eg LinkedIn profile
      • your contact history, purchase history and saved items
      • information from accounts you link to us, eg Facebook
      • information to enable us to undertake credit or other financial checks on you
      • information about how you use our website, IT, communication and other systems
      • your responses to surveys, competitions and promotions

      This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

      How your personal information is collected

      We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

      • from publicly accessible sources, eg Companies Registration Office or the Property Registration Authority;
      • directly from a third party, eg:
        • sanctions screening providers;
        • credit reference agencies;
        • customer due diligence providers.
      • from a third party with your consent, eg your bank or building society
      • from cookies on our website;
      • via our IT systems, eg:
        • door entry systems and reception logs;
        • automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

      How and why we use your personal information

      Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

      • to comply with our legal and regulatory obligations;
      • for the performance of our contract with you or to take steps at your request before entering into a contract;
      • for our legitimate interests or those of a third party; or
      • where you have given consent.

      A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

      The table below explains what we use (process) your personal information for and our reasons for doing so:

      What we use your personal information for

      Our reasons

      		  

      To provide services to you

      For the performance of our contract with you or to take steps at your request before entering into a contract

      		  

      To prevent and detect fraud against you or i3pt

      For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you

      		  

      Conducting checks to identify our customers and verify their identity

      Screening for financial and other sanctions or embargoes

      Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator

      To comply with our legal and regulatory obligations

      		  

      Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

      To comply with our legal and regulatory obligations

      		  

      Ensuring business policies are adhered to, eg policies covering security and internet use

      For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you

      		  

      Operational reasons, such as improving efficiency, training and quality control

      For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price

      		  

      Ensuring the confidentiality of commercially sensitive information

      For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information

      To comply with our legal and regulatory obligations

      		  

      Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures

      For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price

      		  

      Preventing unauthorised access and modifications to systems

      For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you

      To comply with our legal and regulatory obligations

      		  

      Updating and enhancing customer records

      For the performance of our contract with you or to take steps at your request before entering into a contract

      To comply with our legal and regulatory obligations

      For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products

      		  

      Statutory returns

      To comply with our legal and regulatory obligations

      		  

      Ensuring safe working practices, staff administration and assessments

      To comply with our legal and regulatory obligations

      For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

      		  

      Marketing our services and those of selected third parties to:

      —existing and former customers;

      —third parties who have previously expressed an interest in our services;

      —third parties with whom we have had no previous dealings.

      For our legitimate interests or those of a third party, ie to promote our business to existing and former customers

      		  

      Credit reference checks via external credit reference agencies

      For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services

       

      External audits and quality checks, eg for ISO accreditation and the audit of our accounts

      For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards

      To comply with our legal and regulatory obligations

       

       

      The above table does not apply to special category personal information, which we will only process with your explicit consent.

      Promotional communications

      We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

      We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

      We will always treat your personal information with the utmost respect and never share it with other organisations outside the i3pt group for marketing purposes.

      You have the right to opt out of receiving promotional communications at any time by:

      • contacting us at info@catalyst-group.com
      • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

      We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

      Who we share your personal information with

      We routinely share personal information with:

      • companies within the i3pt/Catalyst group
      • third parties we use to help deliver our services to you, eg payment service providers;
      • other third parties we use to help us run our business, eg marketing agencies or website hosts;
      • third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
      • credit reference agencies;
      • our insurers and brokers;
      • our banks.

      We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO accreditation and the audit of our accounts.

      We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

      We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

      We will not share your personal information with any other third party.

      Where your personal information is held

      Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

      Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of Ireland and EEA’.

      How long your personal information will be kept

      We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

      • to respond to any questions, complaints or claims made by you or on your behalf;
      • to show that we treated you fairly;
      • to keep records required by law.

      We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

      When it is no longer necessary to retain your personal information, we will delete or anonymise it.

      Transferring your personal information out of the UK and EEA

      To deliver services to you, it is sometimes necessary for us to share your personal information outside Ireland and/or European Economic Area (EEA), eg:

      • with our offices or other companies within our group outside Ireland/EEA;
      • with your and our service providers located outside Ireland/EEA;
      • if you are based outside Ireland/EEA;
      • where there is an international dimension to the services we are providing to you.

      These transfers are subject to special rules under European and Irish data protection law. This means we can only transfer your personal information to a country or international organisation outside Ireland/EEA where:

      • the European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
      • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
      • a specific exception applies under data protection law

      These are explained below.

      European Commission adequacy decision

      The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from Ireland/EEA to that country without any further safeguards being necessary.

      It can take several years for the European Commission to issue an adequacy decision and only a small number of countries currently benefit from one.

      We may transfer personal information to the following countries that have the benefit of a European Commission adequacy decision: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

      Other countries or international organisations we are likely to transfer personal information to do not have the benefit of an adequacy decision. This does not necessarily mean they provide inadequate protection for personal information, but we must look at alternative grounds for transferring the personal information, such as implementing safeguards or relying on an exception, as explained below.

      Transfers with appropriate safeguards

      We may transfer your data to a third country or international organisation on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

      The safeguards will usually include using standard data protection contract clauses approved by the European Commission.

      Transfers under an exception

      In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, eg:

      • you have explicitly consented to the proposed transfer after having been informed of the possible risks;
      • the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
      • the transfer is necessary for a contract in your interests, between us and another person; or
      • the transfer is necessary to establish, exercise or defend legal claims

      We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.

      Further information

      If you would like further information about data transferred outside Ireland or EEA, please contact us (see ‘How to contact us’ below).

      Your rights

      You have the following rights, which you can exercise free of charge:

      Access

      The right to be provided with a copy of your personal information (the right of access)

      		  

      Rectification

      The right to require us to correct any mistakes in your personal information

      		  

      To be forgotten

      The right to require us to delete your personal information—in certain situations

      		  

      Restriction of processing

      The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data

      		  

      Data portability

      The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

      		  

      To object

      The right to object:

      —at any time to your personal information being processed for direct marketing (including profiling);

      —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.

       

      Not to be subject to automated individual decision making

      The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

       

       

      If you would like to exercise any of those rights, please:

      • email, call or write to us —see below: ‘How to contact us’; and
      • let us have enough information to identify you (eg your full name, address and customer or matter reference number);
      • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
      • let us know what right you want to exercise and the information to which your request relates.

      Keeping your personal information secure

      We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

      We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

      How to complain

      We hope that we can resolve any query or concern you may raise about our use of your information.

      The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Ireland is the Data Protection Commissioner who may be contacted at https://forms.dataprotection.ie/contact or telephone: 076104800.

      Changes to this privacy policy

      This privacy notice was published on 01/03/2021

      We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email.

      How to contact us

      Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

      Our contact details are:

      i3pt T/A Catalyst, 60 Northumberland Road, Dublin, D04 YT91, 019053900, info@catalyst-group.com