Introduction
This policy explains how iScoil will use personal information that is collected when you visit our website, contact us, submit a referral, or apply for a position at iScoil.
Our Privacy Policy is provided to embrace our obligations under the Data Protection Act 2018 and General Data Protection Regulation (GDPR).
If you are a young person or parent/guardian of a young person referred to, or accepted on iScoil, you can learn about how we protect your information in our Privacy Policy for Young People, Parents & Guardians.
1. Who We Are
Throughout this policy, “we”, “us”, “our” and “ours” refers to iScoil:
- A Quality and Qualifications Ireland (QQI) registered education provider, offering accreditation within the NFQ framework of qualifications and an alternative path to education for young people who may not be in mainstream education
- A registered charity and company located at the office address of:
iScoil, Acorn Centre, Warrenmount, Blackpitts, Dublin 8, D08 W2X8 - A provider of education in a place other than a recognised school under Section 14 of the Education Welfare Act 2000,
whose staff are “Mandated Persons” under the Children First Act 2015 - An equal opportunities employer under the Employment Equality Act 1998-2015
2. What Personal Data We Collect
When you visit iScoil.ie your IP address will be logged, this includes your approximate location, along with technical information such as your browser and device type, for security and traffic analytics purposes.
If you accept our Cookie & Privacy Notification, you consent to our use of 3rd party cookies and services like Google Analytics and Google Maps. When loaded these services utilise 3rd party cookies to gather information about you.
Like most websites, we use Google Analytics and Google Adsense to gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This includes anonymous IP addresses, approximate location, demographic information, statistical data of how visitors use our site and technical information such as a visitor’s browser and device type.
More information about how Google uses your information can be found on Google’s Privacy Policy and How Google Uses Cookies.
If you contact us by phone or email we keep a record of the details of the enquiry so we can get back to you. We also do so to keep statistics on the nature of enquiries we receive such as the level of interest for our service.
The referral form on our website is intended for official use only, referrals submitted by parents directly or anyone we believe to not have authorisation to do so will be anonymised and/or deleted where appropriate.
If you contact us to apply for a position at iScoil we will keep a record of your details and any supporting documents you send us as part of your application process.
Personal Information
If you visit iScoil.ie our webserver logs your:
- IP address
- approximate location
- technical information such as a your browser and device type
If you accept our Cookie & Privacy Notification you share the following personal information with Google Maps:
- IP address
- approximate location
- technical information such as a your browser and device type
- ad tracking information
If you make an enquiry to iScoil we collect and store:
- name and contact details
- nature and details of the enquiry
- records of any data protection requests
If you submit a referral to iScoil through our referral form we collect and store the following information:
- referrer name, contact details, position
- all information submitted in relation to the referral
If you apply for a position with iScoil we collect and store:
- name and contact details
- any supporting documents you send us as part of your application
- any information we use or create during your interview process
Non-personal data:
If you accept our Cookie & Privacy Notification you share the following information, in an anonymised form, on an aggregate basis, with us, Google Analytics and Google Adsense:
- IP address
- location
- technical information such as a your browser and device type
- demographic information
- ad tracking information
3. What Do We Use Personal Data For
iScoil uses your personal information for the following:
- for security and traffic monitoring purposes
- to help us provide the best experience on our website
- to gather statistical data of types of users, and how you found and use our site
- to contact you regarding your request for information
- for keeping statistics on the nature of enquires iScoil receives
- to process a referral
- to consider a job application for a position at iScoil
In addition, for reassurance, the results of any statistical analysis iScoil carries out are presented anonymously and will not contain any personally identifiable information. Our use of Google Analytics and Google Adsense is done anonymously, in aggregate, and only with your consent.
4. Lawful Basis on Which We Use This Data
We collect and use personal information to meet legal requirements and legitimate public interests as set out in the Education Welfare Act 2000 and/or the Children First Act 2015, Employment Equality Act 1998-2015, Data Protection Act 2018, General Data Protection Regulation (GDPR).
To comply with GDPR, the information iScoil has collected, fulfils one of the following reasons from Article 6 of GDPR:
- 1(b) it is necessary to evaluate your job application prior to entering into a contract
- 1(c) it is necessary for compliance with a legal obligation to which iScoil is subject
- 1(d) it is necessary to protect the vital interests of a person. This would apply if iScoil became aware that you, or anybody else, were at risk of serious danger for any reason
- 1(e) it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in iScoil under the acts mentioned above
- 1(f) it is necessary for the purposes of iScoil’s legitimate interests of security, statistical analysis, providing you with information about our service, recruitment, or providing and developing quality education and accreditation
In the case that we want to use your information for anything other than these reasons we will contact you to confirm your consent in accordance with Article 6 1(a).
Processing of Special Categories of Personal Data
Information such as, ethnicity, health and mental health or PPSN are categorised as “special categories of personal data”.
Visitors to iScoil.ie: iScoil do not process any special category data for general visitors to iscoil.ie
Enquiries & Referrers: iScoil only process special category data which you specifically make known to us.
Referral Information: Any special category data submitted as part of a referral of another individual, is processed inline with our Privacy Policy for Young People Referred to or Accepted on iScoil, Parents & Guardians.
Job Applicants: iScoil only process special category data which you specifically make known to us. However, prior to any job offers, iScoil is required to process special category data related to Garda vetting such as your PPSN and anything made known to us by you or within the resulting report.
When we hold and use this type of special or sensitive information we do so for the following reasons as covered in Article 9 of GDPR:
- 2(b) it is necessary for the purposes of meeting our legal obligations in the field of employment and social security and social protection law
- 2(c) it is necessary to protect the vital interests of a person
This would apply if iScoil became aware that you, or anybody else, were at risk of serious danger for any reason - 2(f) it is necessary for the establishment, exercise or defense of any appeals or legal claims
- 2(g) it is necessary for reasons of substantial public interest as per the acts mentioned above
- 2(j) it is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
Where the above do not apply iScoil will contact you to confirm your consent to use special category data as noted in Article 9 2(a).
You may withdraw this consent at any time. We will make this clear when we ask for consent, and explain how to go about withdrawing consent.
5. How We Store Personal Data & For How Long
We take the storage and security of your personal information very seriously.
In particular:
- iScoil requires any platforms or service providers we may contract to store or manage your information to have strict confidentiality and data protection policies with industry standard security and technical measures in place to protect your and our information. However, the nature of the Internet is such that we cannot guarantee or warrant the security of any information transmitted via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. We will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal information
- we ensure robust iScoil staff login and access policies are in place on these platforms
- any physical hard copy information is kept in locked cabinets
- any information that is referred to us from other agencies is done so through encrypted means
The following outlines how long we hold personal information:
- we will not retain your information for longer than is necessary to fulfil the purpose it is being used for
- to determine the appropriate retention periods, we consider the amount, nature and sensitivity of the information and the purposes for which we use it, such as for legal, statistical or research purposes
- where possible we endeavour to minimise the amount of information we hold and use during these retention periods and will anonymise and/or securely delete such information after the expiration
- for visitors to iScoil.ie: iScoil maintain webserver logs for a period of 18 months. If you accept our Cookie & Privacy Notice, we retain aggregated anonymous analytics data for a period of 26 months from the last date you visited. For more information on Google’s retention policy and data collected from the use of their cookies, please see Google’s Privacy Policy and How Google Uses Cookies.
- for enquiries: We maintain a log of enquiries for a period of 3 years after which the record is deleted. If the enquiry is a data protection request we will need to keep the details of the request for period of 7 years or if the request is in relation to a young person until the young person is 25 years of age, whichever is longer
- for referrers and referrals submitted: All referrer information is retained until the young person referred is 25 years of age, or for a period of 7 years from the time of the last contact/interaction with iScoil, whichever is longer. Referral information submitted is retained inline with our Privacy Policy for Young People Referred to or Accepted on iScoil, Parents & Guardians
- for job applications: For a period of 18 months after the conclusion of the recruitment process or inline with our Staff Privacy Policy upon successful recruitment
6. Who We Share Personal Data With
In general iScoil does not share your information with anyone outside of iScoil without a valid reason or your permission where needed. However, on occasion we will need to share certain information to meet our legal obligations, provide our service or for reasons in the best interest of the young person.
These include:
- to trusted platform and service providers who deliver and maintain the systems iScoil uses to provide and administer our service and organisation. As mentioned previously, these service providers are contracted by iScoil subject to strict confidentiality and data protection policies with industry standard security and technical measures in place to protect your and our information
- to other regulatory or statutory bodies, lawful agencies or emergency services in order to comply with our legal obligations and rights
7. International Transfers & Automated Processing
Certain service providers who store information on behalf of iScoil may transfer personal information for processing outside the EU.
Where this is the case, iScoil ensures that the same GDPR appropriate policies are in place to protect this information.
iScoil does not engage in automated decision making/profiling in relation to your information.
8. How We Use Cookies
To find more about how we use cookies please visit the link below:
9. Your Data Protection Rights & Contacts
Under data protection legislation, you have the right to request access to personal information iScoil holds about you.
If we receive a request iScoil will need confirmation of your identity to ensure your right to access the information (or to exercise any of your other rights).
This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Other Rights
You also have the right to:
- object to processing of personal information that is likely to cause, or is causing, damage or distress
- object to decisions being taken by automated means
- in certain circumstances, have inaccurate personal information corrected, deleted or destroyed, or restrict iScoil from using it
- request transfer of your personal information in an electronically useable format you or another party can easily use
- as previously mentioned, in the limited circumstances where you may have provided your consent for iScoil to use particular information, you have the right to withdraw your consent for that specific information at any time, unless we have another legitimate basis for keeping it
To make an access request for your personal information or exercise any of your rights, contact iScoil’s Data Protection Officer dpo@iscoil.ie or call the iScoil office on 01 4537570.
In certain circumstances, iScoil may not be able to comply with the request for legal or practical reasons, but we will give a full explanation why at that time.
If you have a concern about the way we are collecting or using your personal data, we ask that you raise your concern by contacting us first.
You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at https://www.dataprotection.ie/docs/Contact-us/b/11.html
10. Updating Our Privacy Policy
Our Privacy Policy may change from time to time and any changes to the policy will be communicated to you by way of an e-mail, SMS or on our website.