DATA PROTECTION POLICY

Contents

• Introduction
• Information covered by the Act 
• Data Protection Principles 
• Conditions 
• Individuals’ Rights 
• Legal Requirements 
• No commercial disposal to third parties 
• Our commitment to Data Protection 
• Further information

Introduction

In order to operate efficiently, we must collect information about people with whom we work or contact for the day to day running of our business. This may include current and past clients, members of the public, current, past and prospective employees, funded bodies and suppliers.  In addition, we may be required by law to collect and use information in order to comply with the requirements of government bodies.

From 25^th May 2018 this personal information must be handled, processed and secured properly according to the General Data Protection Regulation 2018 (“GDPR”).

We consider that the correct treatment of personal data is integral to our successful operations and to maintaining trust of the persons we deal with.  We fully appreciate the underlying principles of the Act and support and adhere to its provisions.

Information covered by the Act

The Act uses the term ‘personal data’.  For information held by Monaghan, personal data essentially means any recorded information held by us and from which a living individual can be identified.  It will include a variety of information including names, addresses, telephone numbers, email addresses and other personal details.  It will include any expression of opinion about a living individual or any indication of our intentions about that individual.

Data protection principles

We will comply with the eight enforceable data protection principles by making sure that personal data is:

1. fairly and lawfully processed
2. processed for limited purposes
3. adequate, relevant and not excessive
4. accurate and kept up to date
5. not kept longer than necessary
6. processed in accordance with the individual’s rights
7. secure
8. not transferred to countries outside the European Economic area unless the country to which the data is to be transferred has adequate protection for the individuals

Conditions

We will ensure that at least one of the following conditions is met before we process any personal data:

1. the individual has consented to the processing
2. the processing is necessary for the performance of a contract with the individual
3. the processing is required under a legal obligation (other than one imposed by a contract)
4. the processing is necessary to protect vital interests of the individual
5. the processing is necessary in order to pursue our legitimate interests or those of third parties (unless it could unjustifiably prejudice the interests of the individual)

Under the Act, one of a set of additional conditions must be met for ‘sensitive personal data’.  This includes information about racial or ethnic origin, political opinions, religious and other beliefs, trade union membership, physical or mental health condition, sex life, criminal proceedings or convictions. We will ensure that one of the following additional conditions is met before we process any sensitive personal data:

1. the individual has explicitly consented to the processing
2. we are required by law to process the information for employment purposes
3. we need to process the information in order to protect the vital interests of the individual or another person
4. the processing is necessary to deal with the administration of justice or legal proceedings

Individuals’ rights

We will ensure that individuals are given their rights under the Act including:

• the right to obtain their personal information from us except in limited circumstances
• the right to ask us not to process personal data where it causes substantial unwarranted damage to them or anyone else
• the right to claim compensation from us for damage and distress caused by any breach of the Act

Legal requirements

While it is unlikely, Monaghan may be required to disclose your data by a court order or to comply with other legal requirements. We will use all reasonable endeavours to notify you before we do so, unless we are legally restricted from doing so.

No commercial disposal to third parties

Monaghan shall not sell, rent, distribute or otherwise make data commercially available to any third party, except as described above or with your prior permission.

Our commitment to data protection

We will ensure that:

• everyone managing and handling personal information understands that they are responsible for following good data protection practice
• there is someone with specific responsibility for data protection in the organisation
• staff who handle personal information are appropriately supervised and trained
• queries about handling personal information are promptly and courteously dealt with
• people know how to access their own personal information
• methods of handling personal information are regularly assessed and evaluated
• any disclosure of personal data will be in compliance with approved procedures.
• we take all necessary steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure
• all contractors who are users of personal information supplied by Monaghan will be required to confirm that they will abide by the requirements of the Act with regard to information supplied by us. 

We have appointed a head of information compliance to lead on data protection for Monaghan.  This person is responsible for ensuring that the policy is effectively implemented. 

Newsletter and Marketing

• All people signing up to our marketing and newsletters will have opted in to be part of the list
• We use MailChimp as our email marketing provider and they also comply with the GDPR regulations. Read their policy here: https://mailchimp.com/legal/privacy/
• To opt out of our Newsletter please use the unsubscribe button at the bottom of the newsletter you receive from us.

Corrections and errors

If you receive any communication from Monaghan that was not intended for you or if there is an error in our communication, please accept our apologies and email us back so that we can rectify the error.

Cookies Policy

Monaghan uses cookies on CHANGE THIS ,  by using the Service you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies?

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognise you and make your next visit easier and the Service more useful to you.

Cookies can be “persistent” or “session” cookies.

How Monaghan uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes: to enable certain functions of the service, to provide analytics and to store your preferences.

We use both session and persistent cookies on the service and we use different types of cookies to run the Service:

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service. An example of this being Google Analytics.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.