Last Updated: 2nd November 2018
2. Personal data – what is it?
Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which when collected together can lead to the identification of a particular person also constitute personal data. Examples of personal data include a person’s name, a home address, a personal email address, location data, an Internet Protocol (IP) address etc.
3. Contact details – Who is the data controller?
The data controller responsible for this Website is Dunleer Parish Ltd of the Armagh Diocese. If at any time you have questions or concerns about the privacy practices of Dunleer Parish Ltd, please write to Very Rev. Fr. Michael Murtagh, Parochial House, Old Chapel Lane, Dunleer, Co Louth, or by email using firstname.lastname@example.org.
Our website domain is owned by Dunleer Parish and powered by a company named Parish Websites who form part of Action BV internet consultancy firm located at Suite 1, Information Age Park, Ennis, Co. Clare. Acton BV is a registered business name of Byrne Ventures Ltd (Company Registration Number 403195)
4. What do we use your personal data for?
The Dunleer Parish website is primarily a content driven site designed to promote the interests of the charity and communicate who we are and what we do. We may use your personal data on our website to enable Dunleer Parish to promote its services for the benefit of the Parish community for example to co-ordinate volunteers and groups, to inform you of news, events, activities and services scheduled.
5. How do we process your personal data on our website?
Dunleer Parish complies with its obligations under the “GDPR” by keeping personal data up to date on our website and by ensuring that appropriate technical measures are in place to protect it. In addition we do not collect excessive amounts of data and avoid collecting it directly through our Website. For example our downloadable registration form for the sacrament of Baptism contains only what is needed to achieve its purpose. In addition such forms are required to be completed offline but may be sent to the Parish Office by a method of your own choosing. Dunleer Parish stores and destroys personal data securely and protects it from unauthorised access and disclosure.
6. How do we collect, use and store your personal data?
Dunleer Parish will process your personal data when you submit it in the following ways:
6.1 Information About Your Device
When you use our Website we will automatically receive technical information including the name of your internet service provider, the website that you used to link to our Website, the type of device you use, your Internet Protocol Address (IP), dates and times of site visits, country, language code, the pages visited, page response times, type of browser and version along with cookie information. This data is collected and processed for statistical purposes through Google Analytics and may be analysed for example to measure and report the aggregate number of visitors to the site. This helps us to maintain a superior and informative website and will not be used to identify you.
6.2 Third Party Data
To facilitate online donations through the Dunleer Parish Website we use Paypal as our payment service provider. Paypal is a third party producer and a separate Data Controller to Dunleer Parish i.e. we do not process your payment information directly it is sub-contracted to Paypal. If you click on the ‘Donate via Paypal’, button on the Dunleer Parish website you will be automatically linked out to the Paypal website www.paypal.com to provide your personal data using their secure data collection functionality.
From time to time we upload created video content containing personal data of individuals to the Dunleer Parish Media Youtube channel. These videos are later embedded onto the Website. The legal basis for processing this data is pursuance of our legitimate interests.
6.3 Website Providers
We may employ third party companies and individuals to facilitate our Website, to provide the Website on our behalf or to assist us in analyzing how our Website is used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Examples of such third party sites are as follows:
6.3.1 Parish Websites
Our Website is hosted by Parish Websites with design support by Acton BV (see section 3). Parish Websites and Action BV must have access to all data on the Website in compliance with their legal obligation to host the site. Parish Websites determine causes of faults, detect or block suspicious traffic, provide support and maintenance and take and restore backups of data.
6.3.2 Google Analytics
We use Google Analytics to track visitor interaction with our site to produce statistical reports using the data in 6.1 in order to improve our site and our services. However, we have enabled IP anonymisation so that Google will not store your complete IP address on their servers. The legal basis for processing this data is pursuance of our legitimate interests.
Visitors may decide to send an email to the website domain email address i.e. email@example.com which may include personally identifying information. Such information is only used to enable a suitable response. Dunleer Parish adheres strictly to permission-based email policy. Except as mentioned above, Dunleer Parish will not send you unsolicited email information, commercial offers or advertisements. Dunleer Parish will not sell, rent, or loan its contact list to any 3rd party company.
6.5 Sensitive Information
Our Website has a clear Catholic ethos. Although we do not specifically seek to collect data relating to a person’s religion (sensitive data) we do promote various groups in our Parish with points of contact for various individuals. If you provide such information to be loaded on our Website a person could reasonably infer that you are a member of the Catholic Church. Therefore, we seek to ensure that those people whose contact details are on our Website are aware of same and have given their permission. Additionally, if at any time you wish the personal information you have supplied for a specified purpose to be removed from the Website please contact Very Rev. Fr. Michael Murtagh.
6.6 Photographs & Video Artefacts
Photographs and video artefacts/clips may be considered personally identifying information and are used on our Website to promote events and share celebrations in our Parish community.
Non-identifiable photographs or video e.g. group or background photographs we will process without prior consent under the legal grounds of pursuing our legitimate interests. However, any photo, when used with associated information e.g. names of babies and parents at a Christening event which uniquely identifies an individual will require consent before it may be published on the Website.
6.7 News Bulletin
Personal data collected for our weekly news bulletin is distributed in the traditional paper format as flyers to the Parish churches i.e. Dromin, Philipstown and Dunleer. In addition, a digital version of the news bulletin will be posted both to our Website and the Dunleer Parish Facebook Page. The weekly Parish news bulletin once uploaded to our Parish Website will be retained in archive for a period of 4 weeks. The news bulletin will remain on the Parish Facebook page but will be pushed further down the timeline as new content is loaded. The lawful basis of processing this personal data is in pursuance of our legitimate interests.
6.8 Parish Webcam
Our Parish webcam provides a live data stream 24 hours per day and 7 days per week to St. Brigid’s Church in Dunleer, Co Louth. It takes a wide angle view of the central aisle of the Church as per the screen shot below. It is designed primarily so that the ministry of the Parish reaches everyone even if they cannot make it in person and it also functions as a security surveillance measure in between services. Both video and audio are recorded which counts as personal data. Notices are present in the Church at each entrance to alert parishioners and visitors alike that the recording is streaming live on Youtube and the data stream may be made available on social media such as Facebook and our Website. Note that the recording remains in buffer for a 4 hour period on Youtube and is deleted thereafter. The lawful basis of processing this data is in pursuance of our legitimate interests.
6.9 Death Notices
Death notices are made available on our Website and social media platforms. At the time of death, personal data of living members of the family of the deceased person may be included in the notice to inform the wider community. These details will usually be drawn from a public source e.g. www.rip.ie.
Dunleer Parish deletes from the Website the personal data of the living members of the family after one month of posting and leaves a permanent record on the Website of the following details pertaining to the deceased for public record.
Name of the deceased
Date of death
Town/area of residence
Place of burial
8 Policy Modifications
8 Your Rights as a Data Subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right to be informed
- Right of access to information
- Right of rectification
- Right to erasure
- Right to data portability
- Right to object to processing of personal data
- Right to restriction
- Right to object to automated decision making, including profiling
- Retention of your personal data
In the event that you wish to make a complaint about how your personal data is being processed by Dunleer Parish or how your complaint has been handled, you have the right to lodge a complaint directly with the Parish Office and the Office of the Data Protection Commissioner.