What is the purpose of this document?
- The Template will act as a guide only and members should seek legal advice if their processing activities differ from those listed in the Template, or contact VFI Head Office for further guidance.
- The Template should be read with the accompanying guidance note in relation to the GDPR.
- The Template aims to address the main processing activities that publicans engage in and how publicans process personal data about individuals (e.g. customers, vendors and suppliers). The Template does not, however, provide an exhaustive list of members’ data processing activities.
- The Template assumes that the purposes for which the personal data are collected are for: (1) use on social media, (2) CCTV monitoring, (3) reservations and bookings; (4) loyalty and reward schemes.
- Publican members should ensure that they make the completed Template easily accessible to individuals (e.g. by making it available on the publican’s website).
- This Template has been drafted on the assumption that publicans do not rely on the consent of individuals’ to process their personal data (but rather largely rely on the publicans’ legitimate business interests).
- The Template assumes that no sensitive personal data (which includes data about race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data or data about a person's sex life or sexual orientation) is collected from individuals.
- The Template assumes that no personal data is collected from persons other than the individuals themselves. If you obtain personal data about individuals from other sources, then separate considerations apply.
- The Template contains drafting notes and certain optional processing activities. These should be deleted before use or if not applicable to the member’s business.
- Purpose and scope
- What kinds of personal information do we collect and process?
We collect and process your personal data including, but not limited to, the following types of personal data:
- contact details such as phone number, email address, postal address, social media profile;
- [demographic information such as age, gender, employer, profession, geographic location;
- [audio or visual recordings;
- [CCTV images or footage;
- [financial details such as credit or debit card information which you provide us to secure a booking.
6. Your Rights
You have certain rights as a data subject in relation to your information. While some of these rights are general and unrestricted, other rights only apply in certain circumstances.
Your rights include:
- Access – you are entitled to obtain a copy of the personal data which we hold about you.
- Rectification – you can request rectification of your personal data if it is inaccurate or incomplete.
- Restriction – you can restrict our use of your personal data.
- Deletion – you are entitled to request that we erase your personal data.
- Objection – you can object to the processing of your personal data where our legal basis for processing your data is our legitimate interests.
These rights may be restricted in certain circumstances for instance where they may be needed to comply with our legal obligations or for the defence or exercise of legal claims.
You can exercise these rights by contacting us at firstname.lastname@example.org
In circumstances where you are not satisfied with our use of your personal data or you are not satisfied with how we have responded to your request to exercise your rights, you have the right to lodge a complaint with the Office of the Data Protection Commission who can be contacted at email@example.com or Lo Call 1890 25 22 31.
- Policy updates
This Policy may be updated from time to time. If we make changes that are material we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.