EIL INTERCULTURAL LEARNING – PRIVACY POLICY
EIL Intercultural Learning collects and processes personal data about a range of people including participants, potential participants, host families, alumni, employees, volunteers and suppliers. The purpose of this policy is to explain how we collect this personal data, how we use it and how we keep it secure.
When and how we collect personal information?
What kinds of personal information do we collect?
Why do we need to collect this information?
Who do we share information with?
Garda Vetting and Personal information
How do we keep your information safe?
How can I obtain a copy of the Personal Information held by EIL Intercultural Learning?
What are my privacy rights relating to my Personal Data?
Where can I get further information?
Is this policy updated from time to time?
The Experiment in International Living trading as EIL Intercultural Learning is a company limited by guarantee not having a share capital, registered in Dublin, Ireland with registered offices at Classic House, 11 – 13 Washington Street, Cork. Registered company number is 136044. The Experiment in International Living is also a charity (Charity Reg. No 20107390).
EIL Intercultural Learning is in membership of the following international organisations: http://federationeil.org/ AFS International https://afs.org/
EIL Intercultural Learning operates three distinct websites located at the following domains:
https://www.globalcitizenaward.ie/
Any one of these websites may ask for and/or collect personally identifiable information in order to provide you with the information and services you seek or to improve your experience, as detailed further below.
When and how we collect personal information?
- When you make an enquiry about any of our programmes or activities whether by phone, email, social media or via an enquiry form(s)
- When you make an application to join any of our activities or programmes by completing an online or offline application form
- We also collect information through our website, blog pages and social media channels including Facebook, Twitter, Youtube and Instagram
- Our websites use ‘cookie’ technology. A cookie is a little piece of text that our server places on your device when you visit any of our websites. If you visit our web site, we may use session cookies while your browser is open, or while you are logged into our site. To facilitate our registration, login functions and support messaging system, we may use cookies to recognize you when you return to our website.
- We may also use Google Adwords remarketing cookies to advertise online to similar audiences, interest categories or other types of interest-based advertising. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings.
What kinds of personal information do we collect?
Personal data means information that identifies you as an individual, such as:
- personal details including address, age and phone number
- family details
- lifestyle information
- education and employment
- photos
We also collect special categories of personal data that may include some or all of the following:
- health information
- ethnic origin
- educational
- religious or other beliefs of a similar nature
- offences and alleged offences
- criminal proceedings, outcomes and sentences
Any use of collected information will be in accordance with the data protection principles of good practice. This means that EIL Intercultural Learning will at all times strive to ensure data will be:
- processed fairly and lawfully
- processed for limited purposes and in an appropriate way
- adequate, relevant and not excessive for the purpose
- accurate
- not kept longer than necessary for the purpose
- processed in line with data subjects’ rights
- secure
Why do we need to collect this information?
We collect data for a range of different purposes
- to respond to your request for information
- to provide you with newsletters or details of events
- to deliver contractual arrangements
- to process applications and to make appropriate placements
- to ensure safety and the vital and medical interests (in the case of illness, accident or hospitalization) of participants it can be necessary to collect special categories of personal data
- to engage you as a volunteer and make any appropriate arrangements
- to keep a record of your contact details
- to promote EIL, in the event photographs and video footage are submitted
- to contact you with current and future information about our work, events, and activities,
- to ensure legal compliance when working with children
Any use of collected information will be in accordance with the data protection principles of good practice. This means that it will be:
- processed fairly and lawfully
- processed for limited purposes and in an appropriate way
- adequate, relevant and not excessive for the purpose
- accurate
- not kept longer than necessary for the purpose
- processed in line with data subjects’ rights
- secure
We will retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal information was obtained, but should be determined in a manner consistent with good practice data retention guidelines.
Who do we share information with?
Personal data will never be sold or otherwise transferred to third parties without a lawful basis.
EIL will share personal and special categories of data with third parties where:
This is necessary to organize and fulfill responsibilities in relation to the delivery of local placements, services, programmes and activities as agreed or contracted.
Depending on the location or destination of the programme, placement or activity these third parties may be located outside of the European Economic Area and can include partner organisations in membership of Federation EIL http://federationeil.org/ AFS International https://afs.org/ or other independent organisations contracted to deliver local in country placements, services, programmes and activities as agreed or contracted with data subjects.
EIL may also disclose personal information to others in the following circumstances:
- When we have received your consent to do so.
- In situations where sharing or disclosing your information is required in order to offer you services you desire (e.g., a volunteer or programme or hosting opportunity)
- When companies or service providers that perform business activities on behalf of EIL require such information (e.g., credit card processing, customer support services, market research administration or database management services)
- To comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena
- In case of emergency such as to safeguard the life, health, or property of an individual
Garda Vetting and Personal information
Under The Children First Act 2015 anybody who interacts with children through EIL, whether participants, host family members, staff or volunteers, must be vetted by An Garda Siochana. The vetting process requires the provision of verified proof of identify and proof of address by all vetting candidates and, subsequently, checks by An Garda Siochana of their records.
- Personal information isfurnished by EIL Intercultural Learning to An Garda Siochana for the completion of the vetting process via The National Youth Council of Ireland. EIL is part of a consortium of youth organisations who have contracted the National Youth Council (NYCI) to manage the Garda Vetting process on their behalf.
- Your Personal Data (proof of identity and address) will be held for the duration of your vetting application.
- Some Personal Data (name, address, date of birth) will be held for the duration of your vetting approval period (currently three years).
How do we keep your information safe?
Data is stored at the EIL Ireland office based in Summerhill North in Cork city and on Google G Suite and Google Cloud Platforms that fully meet requirements under the General Data Protection Directive.
We use reasonable organisational, technical and administrative measures to protect personal information, sensitive information and any other information collected by us. We keep our computers, files and the EIL building is protected by 24 hour monitored alarm.
Two Factor Authentication, also known as 2FA, two step verification, is an extra layer of security that requires not only a password and username and a physical token / randomly generated unique ID number.
We train staff to ensure information is kept secure. When personal data kept in hard copy is to be destroyed we engage a “confidential shredding” provider to carry out the work on site.
How can I obtain a copy of the Personal Information held by EIL Intercultural Learning?
You have the right to request a copy of all of your Personal Data and can do so by contacting our Compliance Officer at [email protected] or by writing to them at: Compliance Officer, Classic House, 11 – 13 Washington Street, Cork. This information will be provided to you within one month.
What are my privacy rights relating to my Personal Data?
You have the right to have your Personal Data updated, rectified, or deleted if you so wish. You have the right to object to your Personal Data being processed and to withdraw your consent to processing – You can do so by contacting us.
Where can I get further information?
Further information regarding your rights can be obtained through the Office of the Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, or on the website www.dataprotection.ie
Is this policy updated from time to time?
Yes, this policy may be updated, without prior notice, from time to time.
Updated July 10th 2018