Waterford and South Tipperary Local Area Employment Service (WSTLAES) Privacy Statement

Scope

We respect the right to privacy of individuals and to the protection of personal information. The purpose of this page is to provide information related to the processing of personal data by Waterford & South Tipperary Local Area Employment Service as a Data Processor and agent of the Department of Social Protection (DSP).

Website Cookies

Our site also uses Cookies to enhance the experience for members/users, as follows: When you first visit this website, you will see a message informing you about cookies. If you click the ‘I agree’ button, a cookie will be set that records your preference. Most browsers allow you to turn off cookies or to customise your settings for cookies. To find out how to do this, see the ‘Help’ menu on your browser. Please note that if you turn off cookies or change your settings, some features of the website may not work correctly.

Visit http://www.aboutcookies.org for a guide on how to control and delete cookies on a wide range of web browsers and operating systems.

Examples of Cookies we use:

  • Session Cookies
  • These are necessary for the operation of the website
  • Preference Cookies
  • We use preference Cookies to remember your preferences and settings
  • Security Cookies
  • Security Cookies are used for security purposes
  • Please refer to our ‘Cookies policy’ at the bottom of the website for further information

Your Personal Rights

  • Right to have your details used in line with data protection regulations.
  • Right to information about your personal details.
  • Right to access your personal details.
  • Right to know if your personal details are being held.
  • Right to change or remove your details.
  • Right to prevent use of your personal details.
  • Right to remove your details from a direct marketing list
  • Right to object.
  • Right to freedom from automated decision making.
  • Right to refuse direct marketing calls or mail.

WSTLAES uses the following cookies on this website, for the following purposes:

Google Analytics

WST uses Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers.

The information generated relating to our website is used to create reports about the use of the website. Google will store and use this information.  Google’s privacy policy is available at: http://www.google.com/privacypolicy.html

Social Media Sharing and Integration (3rd party)

We use Facebook, Twitter & Linkedin functionality within this site so that you can share items of interest, or become a fan of our Social Media Profiles. You can find out more about Facebook’s Cookie use here: http://www.facebook.com/help/?faq=115180708570932 , Twitter’s here: https://twitter.com/privacy & Linkedin here: https://www.linkedin.com/legal/cookie-policy

We also sometimes use video embedding, like YouTube or Vimeo (3rd party) to enhance your experience of content on our site.

You can find out about YouTube’s Cookie policy here: https://www.google.com/chrome/browser/privacy/, and Vimeo’s here: http://vimeo.com/privacy

WSTLAES is not responsible for the content or privacy practices of other websites or social media sites which may be accessed through the WST website. It is WSTLAES policy to clearly identify links to external websites/social media sites and it is your responsibility to satisfy yourself as to the adequacy of the practices of linked sites.

Usage Data

We may also collect information about visitors to our website that your browser sends when you visit our site or access it through a mobile device. This usage data may include information such as your computer’s internet protocol address, browser type, browser version, the pages of our site that you visit, time spent on the site, unique identifiers and other diagnostic data. When accessed via a mobile device, the data may include your mobile device unique id, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser used, unique identifiers and other diagnostic data.

Data Controller

The Department of Social Protection (DSP) on whose behalf we process Customer data is the Data Controller and is responsible to the Data Protection Commissioner for the security of your data. A ‘data controller’ means “the natural or legal person, public authority, agency, or other body which, alone or in conjunction with others determines the purposes and means of the processing of personal data”.

Data Processor

Waterford & South Tipperary Local Area Employment Service is the Data Processor we act as an agent of the Department with regard to the processing of personal data collected under the Local

Area Employment Service program. A data processor means “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”.

Waterford & South Tipperary Local Area Employment Service complies with the principles of the General Data Protection Regulations and Irish Data Protection Acts 2003 – 2018. We also comply with the instructions of the Data Controller (DSP) in relation to the processing of customer personal data.

Data that is shared with Waterford & South Tipperary Local Area Employment Service

The Department (DSP) provide Waterford & South Tipperary Local Area Employment Service with personal data at the time of referral to the Local Area Employment Service program. The data categories that may be shared include the following:-

  • Name
  • Address
  • Gender
  • Date of birth
  • Contact details
  • Your Personal Public Service Number (PPSN)
  • Visual images which are used for identification purposes
  • The Intreo Center where you are registered
  • Your curriculum vitae (if available)

Waterford & South Tipperary Local Area Employment Service collect additional data while you are on program with us, this may include the following:-

  • Data relating to your employment history
  • Education, training, qualifications
  • Data relating to any change of your circumstances, such as change of address
  • Special category data such as health

Purpose of Processing

We will process the information you give us and information that is provided to us about you by DSP fairly and lawfully, and we shall ensure that this data is adequate, relevant and limited to what is necessary for the purposes for which the data is processed in accordance with the GDPR and Irish Data Protection Acts 2003 – 2018 for the purposes of:

Providing you with advice and professional services. This may include data that helps us to identify any barriers to employment you may be facing, which may include some special category data, ,building your c.v., job applications, participation in training courses either internal or external.

  • The Intreo Center where you are registered
  • Data relating to your employment history
  • Data relating to changes to your unemployment claim such as a change of circumstance, or a change of claim status

*Special category data is defined as “data relating to racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, biometric or genetic data, data concerning health, sex life or sexual orientation”. Such processing is prohibited unless it meets the requirement of GDPR Article 9, 2 (b) “processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorized by a Union or Member State law or a collective agreement pursuant to Member State law providing for the fundamental rights and the interests of the data subject”.

Lawful/Legal Basis for Processing

The main legislation under which personal data is legally processed is the Social Welfare Consolidation Act 2005, as amended. The lawful basis for processing personal data under GDPR is Article 6.1(e) – necessity “for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller [the DSP]. This legal and lawful basis applies to the processing of data by Waterford & South Tipperary Local Area Employment Service as an agent of the DSP. Such processing does not require the consent of the data subject.

Consent

  • Customers referred to Local Area Employment Service program are asked to provide specific written consent in three areas, they are:
  • Consent to send your c.v. to potential employers
  • Consent to contact your employer to verify your employment*
  • Consent to process health data as per GDPR Art. 9.2(a)
  • *This consent provides the lawful basis for employers as data controllers to provide requested job sustainment data.

General health questions (special category) may be asked as part of the completion of a questionnaire which helps us to identify any barriers to employment you may have. You will be asked by your Caseworker if you wish to complete these questions, It is not mandatory for you to provide this data, by answering these questions you are consenting to the use of this data.

Where consent is the lawful basis relied upon for processing, you have the right to revoke this consent as freely as it was given without detriment or sanction. You may revoke consent in writing or email to the Data Protection Officer at the address listed below or directly to your Caseworker. Where oral consent was given e.g., during a phone appointment, an oral request to revoke consent shall be acceptable

Waterford and South Tipperary Local Area Employment Service Data Security have implemented appropriate technical and organizational measures to ensure a very high level of security and encryption for the personal data that we hold. We use industry standard technologies and security measures to safeguard your information, and we keep strict security monitoring standards to ensure the confidentiality and integrity of the data and to protect the data against accidental loss, destruction or damage. This data protection policy is supported by our Information Security policies, and ongoing employee training and awareness programs.

Sharing of Data

We will only disclose your information with the Department of Social Protection, and where necessary only relevant information may be shared with organization’s who provide services to allow us to fulfill our obligations, and with whom written legal agreements containing the legal data protection clauses are in place. Generally these types of organizations are:-

  • Training partners
  • Accreditors
  • Employers and prospective employers where you have consented
  • Market research organizations who conduct customer satisfaction surveys on our behalf, will if necessary be provided with limited personal data only if you consent to such processing.
  • Where we are required by law or law enforcement agencies, judicial bodies, government authorities or regulatory bodies.

Transfer of Data

Waterford and South Tipperary Local Area Employment Service shall not permit any party to process (including holding, rendering, transferring or storing) any personal data outside of the European Economic Area, nor shall we permit any party, to process (including holding, rendering, transferring or storing) any unencrypted Personal data outside Ireland. Any processing activity that may occur in the UK following Brexit is covered under an ‘Adequacy Decision’ which has been adopted by the EU Data Protection Commission in June 2021.

Data Retention

Waterford and South Tipperary Local Area Employment Service shall act only on the instructions of the Data Controller (DSP) in relation to the retention of the data that we hold. We will only hold the data as long as is necessary in accordance with GDPR Article 5 1(e) i.e., “kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are being processed”. We shall comply with data retention periods as determined by the data controller i.e., for a minimum of 6 months after the end of program. The maximum data retention period of the DSP is 7 years. It may be necessary for the DSP to retain certain employment related data for the purposes of administration and determination of pension data (please refer to the DSP for further information). We shall act on the instruction of the Data Controller to either delete, destroy or return the data to the Data Controller when the data is no longer required by Waterford and South Tipperary Local Area Employment Service for the purpose for which it was collected, or when Waterford and South Tipperary Local Area Employment Service reaches the end of the contract term as required.

Right of Access

You have the right to request a copy of the information we hold about you. We will provide the information as required in GDPR Article 12 (1) in a concise, transparent, intelligible and easily accessible form. To obtain a copy of this personal information, you can email or write to us at at the address listed below. As an agent and Data Processor of DSP, Waterford and South Tipperary Local Area Employment Service is required to provide the requested data to the Data Controller, we will gather the data you requested and send it to (DSP), who will then fulfill the data subject access request in accordance with the provisions of GDPR Article 15

Waterford and South Tipperary Local Area Employment Service ‘Right of Access by the data subject’. Your written authorization is required when another party makes a request on your behalf. The DSP will require proof of identity prior to release of the data file.

Right to have inaccuracies corrected

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. You can do this during an appointment with your Caseworker, or you can email or write to us at the address listed below. You should also notify the Data Controller of any amendments you may require by contacting your local Intreo office.

Right to the erasure of personal data

Waterford and South Tipperary Local Area Employment Service cannot erase your data unless we are instructed to do so by the Data Controller. We will comply with any instruction received from DSP to erase your personal data from our systems. Please refer to the Data Controller at dpo@welfare.ie if you wish to exercise this right, or to request further information.

Right to object to processing of personal data

Waterford and South Tipperary Local Area Employment Service will respond to any instruction received from the Data Controller in relation to the exercise of this right. Please refer to the DSP website Section 10.4 for further information on this right (see address below)

Right to object to automated decision making

An automated decision is a decision which is made entirely by a computer system, without the intervention of a person. Waterford and South Tipperary Local Area Employment Service systems do not use automated processes to make decisions about our customers without the intervention of a Caseworker.

Right to data portability

Data subjects have the right to request their data from one controller so that it can be given to another controller (company). Please note that pursuant to GDPR Article 20.1, this right only applies to personal data being processed of consent and/or contractual necessity. The majority of DSP’s processing of customer data is processed under Article 6.1(e) – necessity “for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller [the DSP].” Please refer to the Data Controller website Section 10.5 for further information on this right. (see address below).

Right to be notified of a data breach

Waterford and South Tipperary Local Area Employment Service will without undue delay notify the Data Controller (DSP) when we reasonably believe that there has been a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data processed by Waterford and South Tipperary Local Area Employment Service. We will investigate the Incident, take necessary steps to eliminate or contain the impact of the Incident and keep the Data Controller advised of the status of the Incident and all related matters. The Department will assess the level of risk and if deemed necessary will write out to you to confirm what happened and which of your data was affected. The DSP are responsible for notifying the Office of the Data Protection Commission of any high risk breaches.

Waterford and South Tipperary Local Area Employment Service Right to complain

As well as the rights detailed above, you also have the right to complain if you feel that your personal data has been illegally accessed, please contact:-

Waterford and South Tipperary Local Area Employment Service During your time on the Local Area Employment Service, we aim to deliver­ a first-class professional experience that supports you on your journey towards employment.

Complaints and compliments are used to improve the service we deliver to you. Our Complaints Procedure is displayed in our centre and on our website and is included in your Welcome Pack. Please follow the steps below to tell us about your experience:

We aim to acknowledge your complaint within three working days and assign an investigating manager who will be happy to assist you.

We will provide you with a written response within 15 working days, or an update on when to expect an official response if it will take longer.

If you remain dissatisfied, you can escalate your complaint to a more senior manager within 10 workings days of receipt of your response letter.

Where a complaint remains unresolved, you can request the Department of Social Protection to carry out a review.

Following the review, if you remain dissatisfied with the outcome, you can refer the matter to the office of the Ombudsman.

We treat each client fairly and as an individual. If you ever feel this is not the case, please let us know.

If you have any concerns or questions, we want to hear them so please raise them with your Caseworker

or

If any issue is not resolved to your satisfaction, then please put your concerns in writing to: WST LAES Manager Presentation Building, 2nd Floor, Mitchell Street, Dungarvan, Co Waterford X35 DE98

or email to info@wst.ie

You also have the right to complain to the Supervisory Authority at the Office of the Data Protection Commissioner (ODPC)

Waterford and South Tipperary Local Area Employment Service Data Protection Training and Awareness

In addition to the technical and organizational security measures we have in place, every Waterford and South Tipperary Local Area Employment Service staff member completes data protection training at induction. Data production training is further enhanced by the completion by all staff of a data protection training module and assessment which is completed on an annual basis. Data protection is supported through ongoing reviews of all our office locations .

Changes to our privacy policy

Waterford and South Tipperary Local Area Employment Service keeps our privacy policy under regular review, any updates made are placed on this web page.

Further information on your data protection rights can be found on the Data Protection Commission website www.dataprotection.ie and also on the Department of Social Protection website.

Queries and Concerns

Any queries or concerns you may have about the processing of personal information on this website should be made in writing and addressed to:

Data Compliance Officer
Presentation Building,
2nd Floor,
Mitchell Street,
Dungarvan,
Co Waterford X35 DE98

or email to info@wst.ie