Privacy Policies: Website - Clients - Employees
2) Types of Information Collected
The personal data collected depends on how you use our website. You can browse the site, you can fill in forms on the website to contact us / request information or quotes from us, subscribe to our emails, or download documents from us. Our website collects personal data to provide these services.
We collect information about you when you instruct us to provide advice, visit our website, subscribe to our newsletters or to receive our publications, apply for employment with us, and engage in business dealings with us.
Types of information we retain:
- Google Analytics: When someone visits https://test.owlpestcontrol.ie we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website.
- “Personal Data”: This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, user IP addresses in circumstances where they have not been deleted, clipped or anonymised, telephone number, and billing and credit card information. Such information is only collected from you if you voluntarily submit it to us.
- “Non-Personal Data”: Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
3) What we do with the information we gather
- Non-Personal Data:
We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website.
- Personal Data:
We will process any Personal Data you provide to us for the following purposes:(a) to provide you with the goods or services you have ordered; (b) to contact you if required in connection with your order or to respond to any communications you might send to us; (c) to contact you by email in relation to news, events, services, products and offers available within Owl Pest Control and other related third party offerings where appropriate.
The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.
|What we do||Our legal basis under GDPR|
|Use the personal data that you provide on our web forms||When you provide us with your personal data, for instance, to obtain a quote for our services, this is a necessary step to take at the request of the data subject prior to entering into a contract|
|Provide our Pest Control services and products, as well as technical advice||This is necessary for the performance of a contract with you, our data subject|
|To assess the information you have provided and make a decision as to whether we can provide you with a service/product and at what price||Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract|
|Contact you regarding the services we provide||We need to contact you for our legitimate interests so that we can gather more information for the provision of our services, or to deliver those services most effectively|
|Retain your data under our data retention policy after your contract has expired||We need to retain your personal data for only as long as necessary under the law to protect our legitimate interests|
|Where you require us to make Reasonable Adjustments to enable you to attend a meeting or interview, we may require further information from you.|
If this includes information about your physical or mental health, such information (being sensitive personal data, Special Category data), will only be used by us, with your explicit consent, to assess your eligibility for Reasonable Adjustments. We will not share or disclose it to others.
You can withdraw your consent as anytime by contacting us. Please note that we may not be able to process your request for Reasonable Adjustments if you do this.
The following table sets out the categories of personal data that we obtain.
|Name, postal address, email address, website, identification number, location data, online identifier – these are classed as personal data|
This data is provided by you on our web forms and questionnaires, either to obtain a quote from us, subscribe to one of our newsletters, request a service from us or as part of the provision of your existing contractual services.
This data may be provided if you apply for a job opportunity at Owl Pest Control.
We may collect, hold, use and disclose the information collected to compile statistical data and to; maintain our database; develop/improve our website; respond to any email enquiries; notify you of any upcoming marketing, training or other events that you have opted in to; provide you with publications; manage quality control; manage systems administration; attend to compliance issues; provide you or your organisation with advice and determine suitability for employment.
We will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent unless otherwise authorised, required or permitted under the Irish laws. Owl Pest Control does not sell your data to third parties.
4) Disclosure of Information to Other Parties
We may provide Non-Personal Data to third parties such as Google, Facebook or Twitter, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of the community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.
We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required to fulfil your order (in such circumstances, the third party is bound by similar data protection requirements). We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirements.
5) Payment processing
We use a third-party provider, PayPal (Europe) S.à.r.l. et Cie to process payments on our www.owlpestcontrol.ie website. For more details on how PayPal use your personal data, please visit: https://www.paypal.com/ie/webapps/mpp/ua/privacy-full We do not retain any credit card details you supply but may access the Paypal Payments system to review your transaction for the purposes of account management (in the context of our contract(s) with you and on the basis of our legitimate business interests) and fraud detection (on the basis our legitimate business interests).
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
7) What are your rights?
Subject to limitations set out in EEA data protection laws, you have certain rights in respect of your Personal Data. In particular, you have a right of access, rectification, restriction, opposition, erasure and data portability. Please contact us in writing if you wish to exercise these rights. If you wish to complete an access request to all personal data that Owl Pest Control Ltd. holds on you, please note that photo identity will be required for security purposes. We will complete your request within thirty days.
If you wish to learn more about these rights and how they operate, please look at the DPC’s website https://www.dataprotection.ie/
Objecting to processing
Where we process your personal information for purposes we consider to be in our legitimate interest, you have the right to object to this processing. You may exercise this right by writing to us at our address or by emailing us. If you do object, this may affect our ability to provide our products and services to you.
8) Contact us about Data
The data controller is Owl Pest Control Ltd. You can write to us at: Unit 19, Tallaght Business Centre, Whitestown Road, Tallaght, Dublin 24. You can email us at: [email protected]
In accordance with the General Data Protection Regulation (GDPR), Owl Pest Control has implemented this privacy information notice to inform you, our current and former clients (Services, Products online and Trade Counter), of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
We are a Data Controller of the personal data that you supply to us under your contract with us.
1) Principles in Data Protection
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- processing is fair, lawful and transparent
- data is collected for specific, explicit, and legitimate purposes
- data collected is adequate, relevant and limited to what is necessary for the purposes of processing
- data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisational measures we comply with the relevant GDPR procedures for international transferring of personal data
2) Types of Data we hold
We keep several categories of personal data on and from our customers in order to carry out effective and efficient processes. We hold the data within our computer systems and on a paper form.
Specifically, we hold the following types of data:
- personal details such as name, address, phone numbers, job title, email addresses, etc. for the main contact and other contacts for the delivery of the service
- personal details such as name, address, phone numbers, email addresses, property details, etc. provided to us for the delivery of the service
- bank account details and Direct Debit mandates
- IT service use including online service access records.
3) Collection of Your Data
You provide several pieces of data to us directly when the contract is signed, during the onboarding process and during the contract and after the contract has ended. Personal data is kept in files or within the Company’s IT systems.
4) Lawful Basis for Processing
The law on data protection allows us to process your data only for specific reasons. We mainly process your data in order to comply with a legal requirement or in order to effectively manage the service contract we have with you, including ensuring we can deliver the service to you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
|Activity requiring your data||Lawful basis|
|Set up your account||Performance of the contract|
|Carry out the delivery of the services/products you have on your account||Performance of the contract|
|Ensuring payments are made under your account||Performance of the contract|
|Ensuring VAT and insurance premium tax is paid||Legal obligation|
|Carrying out checks in relation to your company status and validating the information supplied to us||Legal obligation|
|Making financial decisions in relation to entering both initial and subsequent contracts||Our legitimate interests|
|Making decisions about service/product delivery methods||Our legitimate interests|
|Ensuring efficient administration of contractual services to you||Our legitimate interests|
|Effectively monitoring the service provided including adherence to commitments and service entitlements||Our legitimate interests|
|Maintaining up to date records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in place||Our legitimate interests|
|Dealing with legal claims made against us||Our legitimate interests|
|Preventing fraud||Our legitimate interests|
|Ensuring our administrative and IT systems are secure and robust against unauthorised access||Our legitimate interests|
5) “Special Categories” of Data
Special categories of data are data relating to: health; sex life; sexual orientation; race; ethnic origin; political opinion; religion; trade union membership; genetic and biometric data.
We carry out processing activities using special category data for the purposes of delivering services and products. This data will be provided to us or requested by us for the purposes of providing our services & products, to ensure you receive appropriate advice and support. For instance, certain pest control products may be more suitable than others if you suffer from respiratory conditions.
Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
6) Failure to Provide Data
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you. This could include being unable to offer you services or administer existing contractual services.
7) Who we Share Your Data With
All employees within the Business that handle your personal data are trained in ensuring data is processed in line with GDPR.
Your data is not shared with third parties, except for other reasons to comply with a legal obligation placed upon us. We have a data processing contract in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We may share your data with bodies outside of the European Economic Area. These countries are USA and from March 2019 the United Kingdom. The reason for sharing with these countries is to facilitate our legitimate business interests in providing you with the contracted services where the Business employees responsible for the provision of the service are based outside the EEA. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU data protection laws: The data processing systems in use at other companies within the Business have comparable levels of security and safety to the systems in operation in countries within the European Economic Area.
8) Protection of Your Data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
9) Periods of Retention
We only keep your data for as long as we need it for, which will be at least for the duration of your service contract plus 7 years from the date that service contract with us terminates, although in some cases we will keep your data for a longer period after your contract has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:
|Record||Recommended Retention Period|
|Assessments under health and safety regulations and records of consultations with safety representatives and committees||Permanently|
|Money purchase details||6 years after transfer or value taken|
|Health data||30 or 50 years|
|Litigation cases||7 years from the conclusion of the litigation case|
|All other data||7 years from the date the service contract with us terminates|
10) Client Rights
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it
- the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on “Subject Access Requests”
- the right for any inaccuracies in the data we hold on you, however, they come to light, to be corrected. This is also known as “rectification”
- the right to have data deleted in certain circumstances. This is also known as “erasure”
- the right to restrict the processing of the data
- the right to transfer the data we hold on you to another party. This is also known as “portability”
- the right to object to the inclusion of any information
- the right to regulate any automated decision-making and profiling of personal data
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
12) CCTV monitoring
Customers visiting our office or trade counter should be aware that we operate a CCTV monitoring system at the office and trade counter. Images are being monitored and recorded for the purpose of crime prevention, the prevention of anti-social behaviour, for the safety of our staff and customers and for the protection of the Company and its property. This system will be in operation 24 hours a day, every day. Images may be passed to An Garda Síochána. This scheme is controlled by Owl Pest Control. For more information please check our CCTV Policy HERE.
13) Contact us about Data
The data controller is Owl Pest Control Ltd. You can write to us at: Unit 19, Tallaght Business Centre, Whitestown Road, Tallaght, Dublin 24. You can email us at: [email protected]
1) Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photograph, video, email address, or address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual (e.g. a list of staff may contain personnel ID numbers rather than names but if you use a separate list of the ID numbers which give the corresponding names to identify the staff in the first list then the first list will also be treated as personal data). The processing of personal data is governed by legislation relating to personal data which applies in Ireland including the General Data Protection Regulation (the “GDPR”) and other legislation relating to personal data and rights.
2) Who are we?
This Privacy Notice is provided to you by Owl Pest Control Ltd. which is the Data Controller and the Data Processor for your data. Owl works together with:
- Other data controllers, e.g. local authorities, public authorities, central government and agencies such as Revenue
- Staff pension providers
- Former and prospective employers
- Payroll services providers
- Recruitment Agencies
- Credit reference agencies
We may need to share personal data we hold with them so that they can carry out their responsibilities to the Company. The organisations referred to above will sometimes be “joint data controllers”. This means we are all responsible to you for how we process your data where for example two or more data controllers are working together for a joint purpose. If there is no joint purpose or collaboration then the data controllers will be independent and will be individually responsible to you.
3) Owl Pest Control will comply with data protection law. This says that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
4) What data do we process?
- Names, titles, and aliases, photographs.
- Start date / leaving date
- Contact details such as telephone numbers, addresses, and email addresses.
- Where they are relevant to our legal obligations, or where you provide them to us, we may process information such as gender, age, date of birth, marital status, nationality, education/work history, academic/professional qualifications, employment details, hobbies, family composition, and dependants.
- Non-financial identifiers such as passport numbers, driving licence numbers, vehicle registration numbers, taxpayer-identification numbers, staff identification numbers, tax reference codes, and national insurance numbers.
- Financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers.
- Financial information such as National Insurance number, pay and pay records, tax code, tax and benefits contributions, expenses claimed.
- Other operational personal data created, obtained, or otherwise processed in the course of carrying out our activities, including but not limited to, CCTV footage, vehicle tracking, recordings of telephone conversations, IP addresses and website visit histories, logs of visitors, and logs of accidents, injuries and insurance claims.
- Next of kin and emergency contact information
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process and referral source (e.g. agency, staff referral))
- Location of employment or workplace.
- Other staff data (not covered above) including; level, performance management information, languages and proficiency; licences/certificates, immigration status; employment status; information for disciplinary and grievance proceedings; and personal biographies.
- CCTV footage and other information obtained through electronic means such as swipecard records.
- Information about your use of our information and communications systems.
5) We use your personal data for some or all of the following purposes: –
Please note: We need all the categories of personal data in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations.
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking that you are legally entitled to work in Ireland.
- Paying you and deducting tax and other contributions.
- Providing any contractual benefits to you
- Liaising with your pension provider.
- Administering the contract we have entered into with you.
- Management and planning, including accounting and auditing.
- Conducting performance reviews, managing performance and determining performance requirements.
- Making decisions about salary reviews and compensation.
- Assessing qualifications for a particular job or task, including decisions about promotions.
- Conducting grievance or disciplinary proceedings.
- Making decisions about your continued employment or engagement.
- Making arrangements for the termination of our working relationship.
- Education, training and development requirements.
- Dealing with legal disputes involving you, including accidents at work.
- Ascertaining your fitness to work.
- Managing sickness absence.
- Complying with health and safety obligations.
- To prevent fraud.
- To monitor your use of our information and communication systems to ensure compliance with our IT policies.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To conduct data analytics studies to review and better understand employee retention and attrition rates.
- Equal opportunities monitoring.
- To undertake activity consistent with our statutory functions and powers including any delegated functions.
- To maintain our own accounts and records;
- To seek your views or comments;
- To process a job application;
- To provide a reference.
Our processing may also include the use of CCTV systems for monitoring purposes.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
We may also use your personal data in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest [or for official purposes].
6) How we use sensitive personal data
We may process sensitive personal data relating to staff including, as appropriate:
- Information about your physical or mental health or condition in order to monitor sick leave and take decisions on your fitness for work;
- Your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation;
- In order to comply with legal requirements and obligations to third parties.
These types of data are described in the GDPR as “Special categories of data” and require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations.
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our pension scheme.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
7) Do we need your consent to process your sensitive personal data?
- We do not need your consent if we use your sensitive personal data in accordance with our rights and obligations in the field of employment and social security law.
- In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
- You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
8) Information about criminal convictions
- We may only use personal data relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
- Less commonly, we may use personal data relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
- We will only collect personal data about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect personal data about criminal convictions as part of the recruitment process or we may be notified of such personal data directly by you in the course of you working for us.
9) What is the legal basis for processing your personal data?
Some of our processing is necessary for compliance with a legal obligation. We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. We will also process your data in order to assist you in fulfilling your role in the council including administrative support or if processing is necessary for compliance with a legal obligation.
10) Sharing your personal data
Your personal data will only be shared with third parties including other data controllers where it is necessary for the performance of the data controllers’ tasks or where you first give us your prior consent. It is likely that we will need to share your data with:
- Our agents, suppliers and contractors. For example, we may ask a commercial provider to manage our HR/ payroll functions , or to maintain our database software;
- Other data controllers, such as local authorities, public authorities, central government and agencies such as Revenue
- Staff pension providers
- Former and prospective employers
- Payroll services providers
- Recruitment Agencies
- Credit reference agencies
- Professional advisors
- Trade unions or employee representatives
11) How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently the best practice to keep financial records for a minimum period of 6 years to support Revenue audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations or to defend or pursue claims. In some cases, the law imposes a time limit for such claims (for example 10 years from the date of an accident – The Safety Health and Welfare at Work (General Applications Regulation 1993, section 60)). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
12) Your responsibilities
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.
13) Your rights in connection with personal data
You have the following rights with respect to your personal data:
- The right to access personal data we hold on you
At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within one month.
There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.
- The right to correct and update the personal data we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your personal data erased
If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
When we receive your request we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).
- The right to object to the processing of your personal data or to restrict it to certain purposes only
You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
- The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to lodge a complaint
You can lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data.
14) Transfer of Data Abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
15) Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing, if we start to use your personal data for a purpose not mentioned in this notice.
16) Changes to this notice
We keep this Privacy Notice For Employees under regular review and we will place any updates on this page.
All questions, concerns, and other feedback relating to this Policy should be communicated to the Operations Director.