1. Who we are:
We are HUME BROPHY COMMUNICATIONS of 14 Herbert Street Dublin 2 Ireland. You can contact us at this address by post or by email at firstname.lastname@example.org.
To contact our data protection representative please email GDPR@humebrophy.com.
2. Why we process your data, the lawful basis for processing your data and who we share it with
A. For our clients, we process data:
- in order to perform the service for which we are contracted and to provide consulting advice
The legal basis for the processing of this data is processing necessary for the performance of a contract to which they are a party. There may also be limited circumstances where our legal basis for processing is consent (where we have sought it and the client has provided it to us), in which case such consent can be withdrawn at any time.
We share this data with our practice management system provider. We may also send our clients emails through our email service provider. They may only process this data for the purpose of providing us with their services, and no other purpose.
We will retain this data for the period as defined by the consultancy service agreement.
B. For our potential clients, we process data:
- in order to market the services of our firm
- to provide you with updates and newsletters to which you have subscribed
The legal basis for the processing of this data is processing necessary for the purpose of the legitimate interests of our firm in promoting our services. We always include an unsubscribe button in our communications, so you can opt out of receiving such communications at any time.
We share information such as your name and email address with our newsletter services provider who sends out our newsletters. This provider is not permitted to use this data other than on our behalf.
We will retain this data for twenty-four months.
C. For job applicants to the firm, we process data:
- to recruit new employees
- to ascertain your suitability for a specific role
The legal basis for this processing is processing necessary for the purpose of the legitimate interests of our firm in recruiting new staff. Please see the privacy notice in the job advertisement for further information about how we process applicant data.
We share the information you provide in your application with our contracted recruiter in order to make a shortlist of candidates. This recruiter is not permitted to use this data other than on our behalf. We may also send you emails about your application through our email service provider.
We will retain this data for one month.
D. For other industry and political stakeholders, we process data:
- In order to market the services of our firms
- In order to provide updates and newsletters
The legal basis for this processing is our legitimate interest in the administration and operation of our services as well as our legitimate interest in marketing and promoting our firm’s services. We always include an unsubscribe button in our communications, so you can opt out of receiving such communications at any time.
We share this data with our client relationship management system provider. They may only process this data for the purpose of providing us with their services, and no other purpose.
We will retain this data for twelve months.
3. Transfers of data outside the European Economic Area
We transfer data relating our consultancy services to other Hume Brophy offices located in Singapore, Hong Kong and New York as required. The safeguard we have put in place for this transfer is to enter into European Commission approved standard contractual clauses with the provider.
4. Information received from third parties and the source of that data
We receive personal data direct clients under contractual terms.
We receive personal data from individuals under commercial relationships.
We receive personal data from individuals and organisations who subscribe to our newsletter and events programs.
We gather personal data from publicly accessible sources in furtherance of our commercial interests.
5. Your rights relating to personal data
You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:
• right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
• right to rectification- you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
• right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
• right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
• right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.
In order to exercise any of the rights set out above, please contact us at the contact details at the start of this privacy notice.
If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.
If you are unhappy with how we process personal data, we ask you to contact us so that we can rectify the situation.
You may lodge a complaint with a supervisory authority. The Irish supervisory authority is the Data Protection Commission www.dataprotection.ie.
6. Requirement to process personal data
You may browse our website without providing us with any personal data and this will not affect your ability to view our website.
If you do not provide us with your information for the purposes described above, we cannot send you our newsletter, respond to your queries sent through our contact us form, liaise with you on client matters or assess your suitability for a role within our firm.
7. Automated decision-making and profiling
We do not use any personal data for the purpose of automated decision-making or profiling.