Security Policy 07

DATA PROTECTION POLICY
Introduction
At IDA Ireland privacy and data protection rights are very important to us.
IDA Ireland is registered under the Data Protection Acts 1988 and 2003 as a data
controller and data processor and all personal data will be maintained in accordance
with the obligations of that Act.
Data Protection is the safeguarding of the privacy rights of individuals in relation to

the processing of personal data, in both paper and electronic format. The Data
Protection Acts 1988 and 2003 (the “Data Protection Acts”) lay down strict rules
about the way in which personal data and sensitive personal data are collected,
accessed, used and disclosed. The Data Protection Acts also permit individuals to
access their personal data on request, and confer on individuals the right to have their
personal data amended if found to be incorrect.
This document outlines IDA Ireland’s policy to help ensure that we comply with the
Data Protection Acts.
Inquiries about this Data Protection Policy should be made to: Manager, Compliance
& Information Management, IDA Ireland, Wilton Park House, Wilton Place,
Dublin 2.
Data Protection Policy
Purpose of this policy
This policy is a statement of IDA Ireland’s commitment to protect the rights and
privacy of individuals in accordance with the Data Protection Acts.
Individuals’ Responsibilities
Any staff member of IDA Ireland who is involved in the collection, storage or
processing of personal data has responsibilities under the legislation:.
Any staff member involved in the processing/storing of personal data should make
sure;
 to obtain and process personal data fairly.

 to keep such data only for explicit and lawful purposes.
 to disclose such data only in ways compatible with these purposes
 to keep such data safe and secure.
 to keep such data accurate, complete and up-to-date.
 to ensure that such data is adequate, relevant and not excessive.
 to retain such data for no longer than is necessary for the explicit
purpose.
 to give, on request, a copy of the data to the individual to whom they
relate, such a request is known as an ACCESS REQUEST (sample
access request letter is attached in Appendix II)
Any data access requests received should be forwarded immediately to the Manager,
Compliance & Information Management. A fee of €6.35 applies to any application
for information under the Data Protection Acts.
Individual Rights
The individuals for whom IDA Ireland stores personal data have the following rights:
 to have their personal data obtained and processed fairly

 to have personal data kept securely and not illegitimately disclosed to others.
 to be informed of the identity of the Data Controller and of the purpose for
which the information is held.
 to get a copy of their personal data.
 to have their personal data corrected or deleted if inaccurate.
 to prevent their personal data from being used for certain purposes: for
example, one might want to have the data blocked for research purposes where
it is held for other purposes.
 under Employment Rights, not to be forced to disclose information to a
prospective employer. No one can force another person to make an access
request, or reveal the results of an access request, as a condition of
recruitment, employment or provision of a service. Where vetting for
employment purposes is necessary, this can be facilitated where the individual
gives consent to the data controller to release personal data to a third party.
 It should be noted that under the Freedom of Information Act 2014, records
containing personal information may be released to a third party, where the
public interest so requires.
Principles of the Acts
IDA Ireland will administer its responsibilities under the legislation in accordance
with the eight stated data protection principles outlined in the Act as follows:
1. Obtain and process information fairly.

IDA Ireland will obtain and process personal data fairly and in accordance with the
fulfilment of its functions.
2. Keep data only for one or more specified, explicit and lawful purposes.
IDA Ireland will keep data for purposes that are specific, lawful and clearly stated and
the data will only be processed in a manner compatible with these purposes.
3. Use and disclose data only in ways compatible with these purposes.
IDA Ireland will only disclose personal data that is necessary for the purpose/s or
compatible with the purpose/s for which it collects and keeps the data.
4. Keep data safe and secure.

IDA Ireland will take appropriate security measures against unauthorised access
to, or alteration, disclosure or destruction of, the data and against their accidental loss
or destruction. IDA Ireland is aware that high standards of security are essential for all
personal data.
5. Keep data accurate, complete and up-to-date.

IDA Ireland will have procedures that are adequate to ensure high levels of data
accuracy. IDA Ireland will examine the general requirement to keep personal data
up-to-date. IDA Ireland will put in place appropriate procedures to assist staff in
keeping data up-to-date.
6. Ensure that data are adequate, relevant and not excessive.

Personal data held by IDA Ireland will be adequate, relevant and not excessive in
relation to the purpose/s for which it is kept.
7. Retain data for no longer than is necessary for the purpose or purposes for which
they are kept.
IDA Ireland will have a policy on retention periods for personal data.
8. Give a copy of his/her personal data to that individual, on request

IDA Ireland will have procedures in place to ensure that data subjects can exercise
their rights under the Data Protection legislation.
Roles/Responsibilities of IDA Ireland
IDA Ireland has overall responsibility for ensuring compliance with the Data
Protection legislation. However, all employees of IDA Ireland who collect and/or
control the contents and use of personal data are also responsible for compliance with
the Data Protection legislation. IDA Ireland will provide support, assistance, advice
and training to all relevant Departments, Offices and staff to ensure it is in a position
to comply with the legislation.
IDA Ireland is registered as a Data Controller in compliance the Act and the following
roles are included in the registration,
Contact Person: Manager, Compliance & Information Management

Compliance Person: Manager, Compliance & Information Management
Procedures and Guidelines
This policy supports the provision of a structure to assist in IDA Ireland’s compliance
with the Data Protection legislation, including the provision of best practice
guidelines and procedures in relation to all aspects of Data Protection.
Review
This Policy will be reviewed regularly in light of any legislative or other relevant
indicators.
Appendix I
Definitions
The following definitions are taken from the Data Protection Acts 1998 and 2003
Full copies of the act are available at the Data Protection Commissioner web site
www.dataprotection.ie.
Personal data means data relating to a living individual who is or can be identified
either from the data or from the data in conjunction with other information that is in,
or is likely to come into, the possession of the data controller;
Sensitive personal data means personal data as to -
(a) The racial or ethnic origin, the political opinions or the religious or
philosophical beliefs of the data subject.
(b) whether the data subject is a member of a trade-union.
(c) the physical or mental health or condition or sexual life of the data subject.
(d) the commission or alleged commission of any offence by the data subject, or
(e) any proceedings for an offence committed or alleged to have been committed
by the data subject, the disposal of such proceedings or the sentence of any court
in such proceedings.
Appendix II
Sample Letter
Please see below, sample wording for letter to access data held under the Data
Protection Acts 1988 and 2003.
When requesting information, it is important to give any details that will help the
person to identify you and find your data – for example a staff number, any previous
address or your date of birth; and be clear about which details you are looking for if
you only want certain information. This will help IDA Ireland to respond more
quickly.
A fee of €6.35 applies to any application for information under the Data Protection
Acts.
Manager
Compliance & Information Management
IDA Ireland
Wilton Park House
Wilton Place
Dublin 2
Dear Manager,
Under the Data Protection Acts 1988 and 2003, I wish to make an access request for a
copy of any information you keep about me, on computer or in manual form.
[Insert relevant information to assist IDA Ireland to identify you and find your data]
Yours faithfully,
[Name]

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DATA PROTECTION POLICY

Data Protection is the safeguarding of the privacy rights of individuals in relation to

 to obtain and process personal data fairly.

 to have their personal data obtained and processed fairly

Principles of the Acts

1. Obtain and process information fairly.

4. Keep data safe and secure.

5. Keep data accurate, complete and up-to-date.

6. Ensure that data are adequate, relevant and not excessive.

8. Give a copy of his/her personal data to that individual, on request

Contact Person: Manager, Compliance & Information Management

Procedures and Guidelines

Sensitive personal data means personal data as to -

(b) whether the data subject is a member of a trade-union.

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