1. Purpose of this Data Protection Notice (“Notice”)
The Irish Banking Culture Board CLG (“IBCB“, “we” or “us“) of Pembroke Hall, 38/39 Lower Baggot Street, Dublin 2, Ireland fully respects your right to privacy and data protection. We actively seek to preserve your data protection rights when you share personal information about you (“Personal Data“) with the IBCB. This Notice sets out the basis upon which we use, process, store or disclose your Personal Data. The Personal Data provided by you will be held by the IBCB as a controller.
In most cases, the IBCB will only collect your Personal Data when you voluntarily provide it to us via e-mail (e.g. when you submit a query to us) or when you complete one of our surveys/register for an event. When we respond to your queries (e.g. via e-mail) and when we carry out surveys/events, which you voluntarily complete, we process your Personal Data on the basis that it is necessary for the purposes of our legitimate interests.
Please see section 9 of this Notice for our contact details.
2. Your Personal Data
We may process the following types of Personal Data in relation to you:
| Query Information | You may choose to give us your Personal Data, such as your first name, last name, e-mail address, address, telephone/mobile number and other details when you contact us or submit enquiries/queries to us by e- mailing info@IBCB.ie. |
| Survey Information | You may choose to give us your Personal Data, such as your first name, last name, e-mail address, position/role, personal options, surveyresponses or related information, when you complete one of our surveys. For example, if you are a staff member at one of our retail banks acting as our funding partners. |
| Event Information | You may choose to give us your Personal Data, such as your first name, last name, job title, e-mail address, address, telephone/mobile number and other details when you register for/attend an event we organise. |
| Device Information | When you use our website, www.irishbankingcultureboard.ie (“Website“), or avail of the services related to the Website, Personal Data will be collected from you by Google Analytics and by us. This includes information about: • your device browser including your IP address and other information derived from cookies used on the website. Please see our Cookies Policy https://www.irishbankingcultureboard.ie/cookie-policy/ for further information; and • the details of your visits to the Website such as traffic data, location data and the resources that you access on the Website. |
3. How and Why We Use Your Personal Data
The following table details the key context for which (“Legal Basis“) and the reasons why (“Purposes“) we process your Personal Data:
| Legitimate Interests | |
| Legal Basis | It is necessary for the purpose of our legitimate interest to obtain, collect and process your Personal Data. |
| Purposes | Website: To provide you with use of the Website and allow you to optimally browse the Website. Queries: To process and respond to queries (or requests) you submit to us when you e-mail info@IBCB.ie. Surveys: To issue a survey to you in order to assess your views on banking culture. Cognitive Diversity: To support us in ensuring we achieve cognitive diversity when you complete one of our surveys. Events: To invite you to events, seminars, webinars and meetings. To gain your feedback following an event. Updates: To send you newsletters, legal updates and other information. |
| IMPORTANT | When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You have certain rights when we process your Personal Data on this basis, such as the right to object. For more information on exercising this right please see section 7 of this Notice (Your Data Protection Rights). |
| Compliance with a Legal Obligation | |
| Legal Basis | We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject. |
| Purposes | Compliance with mandatory law requirements To comply with our obligations under Irish and/or European Union Member State laws. |
Please note that it is necessary for us to process your Personal Data for the purposes set out in Section 3 of this Notice. It is neither a statutory obligation nor a requirement to enter into a contract to provide us with your Personal Data. In the event that you do not wish to provide us with your Personal Data for the purposes outlined in this Notice, we will not be able to address your queries, assess your survey responses or otherwise process your Personal Data.
4. Sharing of Your Personal Data
We will share your Personal Data between employees of the IBCB.
We will only disclose your Personal Data as reasonably necessary to third parties outside the internal IBCB network. The third parties with whom we may share your Personal Data are:
- Our third-party service providers such as our external content management system provider;
- Our member banks (Allied Irish Banks, Bank of Ireland, KBC Bank Ireland, PTSB and Ulster Bank); and
- Our professional advisors such as legal advisors and consultants.
5. Transfers of Your Personal Data
When we store your Personal Data on our systems, it will be stored either on the IBCB premises (in Dublin, Ireland) or on secure IT platforms within the European Economic Area (“EEA“).
Some external recipients (e.g. our third-party service providers) who process your Personal Data on our behalf may transfer yourPersonal Data outside the EEA to a country that does not provide an adequate level of protection to your Personal Data. Where such transfers occur, we ensure that: a) they do not occur without our prior written authority; and b) that an appropriate transfer mechanism or agreement is put in place to protect your Personal Data (e.g. the European Commission’s Standard Contractual Clauses). If you would like to find out more about any such transfers, please e-mail gdpr@IBCB.ie.
6. How Long Do We Keep Your Personal Data?
Any Personal Data we collect from you will be stored confidentially and securely. In general, we will only store your Personal Data for as long as is necessary, but no more than 12 months after the completion of a survey or after we have dealt with your query.
Please note that in certain circumstances, we may hold your Personal Data for a longer period. For example, if we are processing an ongoing claim or Irish/European Union law or a relevant regulator may reasonably, in our view, expect or require us to retain your Personal Data.
7. Your Data Protection Rights
You have a number of rights in relation to your Personal Data, which are set out in the table below. In particular, these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that in certain circumstances these rights are not absolute.
| Right | Further Information |
| Right to Object | You have the right to object at any time to the processing your Personal Data where we process your Personal Data based on the legal basis of pursuing our legitimate interest. |
| Right of Access | You have the right to request a copy of the Personal Data held by us about you and to access the information we hold about you. |
| Right of Restriction | You have the right to restrict the processing of your Personal Data where:(a) you are contesting the accuracy of your Personal Data stored by us; (b) your Personal Data is processed unlawfully; (c) we no longer need your Personal Data however, you need it to establish, exercise or defend a legal claim; or (d) you have objected to the processing of your Personal Data based on our legitimate interests and wish to restrict our processing where we do not have an overriding legitimate interest to continue to process yourPersonal Data. If you validly exercise this right, we will only store your Personal Data and will not carry out any other processing until the issue is resolved. |
| Right of Erasure | In certain circumstances, you may also have your Personal Data deleted. For example, if you exercise your right to object and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this Notice. |
| Right to Rectification | You have the right to have any inaccurate Personal Data which we hold about you updated or corrected. |
You can exercise any of these rights by submitting a request to gdpr@IBCB.ie.
We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to two months if necessary, however we will inform you if this arises.
You have the right to lodge a complaint with the Data Protection Commission with regard to our processing of your Personal Data. See https://forms.dataprotection.ie/contact.
8. Changes to this Notice
If we amend this Notice, in whole or part, any changes will be posted on the Website.
If at any time we decide to use your Personal Data for a purpose significantly different from that stated in this Notice, or otherwise disclosed to you at the time it was collected, we will notify you, and you will have a choice as to whether or not we use your Personal Data for such a new purpose.
9. Contact Us
If you have any queries relating to the processing of your Personal Data for the purposes outlined in this Notice or you wish to make a request in relation to your data protection rights, you can contact Candie Malone, IBCB Office Manager at 01 905 8780 or gdpr@IBCB.ie.
