Last Revision 23/05/2018
Pathfinder is committed to protecting our customer privacy and takes its responsibility regarding the security of client information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us as a client and through your use of our website
- How we manage any personal data we may collect on your customers as part of our work
- Where we obtain the data from
- What we do with that data
- How we store the data
- Who we transfer/disclose that data to
- How we deal with your data protection rights
- And how we comply with the data protection rules.
All personal data is collected and processed in accordance with Irish and EU data protection laws.
Pathfinder is the “data controller” of all personal information that is collected and used about Pathfinder clients for the purposes of the Irish Data Protection Act 2018. Pathfinder is registered in Ireland with registration number 428486 and registered offices at Pathfinder Dublin office, Ferry House, 48 Mount Street Lower, Dublin 2.
Personal Information we Collect
Personal data means any information relating to you or your customers, which allows us to identify you or your customers, such as name, contact details and information about access to our website.
We may collect personal data from you when you interact with our website, if you are a client, or you have passed your details to one of our staff members.
Specifically, we may collect the following categories of information:
- Employee name, address, e-mail address, telephone number.
- Customer personal data shared during the course of an engagement for assessment purposes.
- Pathfinder events you have attended.
- Information about your use of our website. For more information on this please refer to our Privacy Statement and Cookies Policy here.
- The communications you exchange with us or direct to us via letters, emails, calls, and social media.
What do we use your Personal Data for?
Your data may be used for the following purposes:
- Providing services you request: we use the information you give us to perform the services you have asked for in relation to management consultancy services
- Administrative or legal purposes: we use your data for statistical and marketing analysis.
- Marketing: from time to time we may contact you to invite you to a Pathfinder event and/or send you business service information.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
We may also process your personal data for one or more of the following:
- In accordance with a contract agreement we have with you.
- You have consented to us using your personal data (e.g. for marketing related uses).
- To comply with a legal obligation (e.g. Revenue).
- It is in our legitimate interests in operating as an management consultancy (e.g. for administrative purposes).
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal or regulatory obligations or to deal with complaints, queries and to protect our legal rights.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
All personal data is stored securely within software applications with password protection and encryption.
International Data Transfer
Pathfinder operates businesses in Ireland and the UK and our third-party application providers store data within the EEA.
Sharing your Personal Information
- Government authorities, law enforcement bodies, regulators for compliance with legal requirements.
- Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation to our contract with clients.
Cookies and Site Tracking
Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. If you choose to change these settings, you may find that certain functions will not work as intended.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org.
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request deletion of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please contact Pathfinder at firstname.lastname@example.org with Data Protection in the email subject bar.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and 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.