AHR Privacy Policy
Last updated [4th June 2020]
INTRODUCTION
Associated HR Services Ltd (Reg no: 311027), “AHR”, takes your privacy very seriously. This Privacy Notice is intended to set out your rights and to answer any queries you may have about your personal data. If you need more information, please contact: privacy@ahr.ie
The controller of your data will be Associated HR Services Ltd.
Our personal information handling policy and procedures have been developed in line with the requirements of the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.
1. What information do we collect?
We collect and process personal data about you when you interact with us via our websites and during the administration and processing of our Employee Assistance Programs (EAP) and other services. The personal data we process includes:
- For general web/mobile app users
- information related to the browser or device you use to access our website, internet browser and operating system, IP address.
- For Organisations
- Contact name, telephone number and email address, HR/OH referral contact information;
- For EAP/EWP Clients
- Name, address, telephone number, employing organisation, emergency contact name and telephone number, GP contact information, presenting issue requiring EAP service response, availability for counselling, self-harm status, previous service contact status, current work attendance status, HR/OH referral contact information, suitable and actual counsellor assignment, service engagement information, service feedback information. Each client is assigned a client code;
- For Affiliated and Prospective Counsellors
- Name, business address, business telephone number, business email address, professional qualifications, bank account details (affiliates only), counselling techniques used and specialities treated, membership of professional affiliations/governing bodies, optionally, (according to Revenue rules) PPS number and home address ;
- For Job Applicants and Employees
- Name, address, telephone number, CV, bank account details, PRSI number
2. How do we use this information and what is the legal basis for this use?
We process the personal data listed in paragraph 1 above for the following purposes:
- For general web/mobile app users
- to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
- we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
- For Organisations
- We may contact you directly regarding services you have signed up to or purchased from us, such as necessary to deliver service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests.
- For EAP/EWP Clients
- we use the information on the basis of an EAP/EWP contract with the client’s employer organisation to provide telephone or face-to-face counselling with the most suitable counsellor near to where they live and/or work. The assigned client code is used to distinguish between clients with the same name.
- For Affiliated and Prospective Counsellors
- we use the information to assess suitability for affiliation to AHR based on location near to one of our contracted organisations, techniques used and specialities treated;
- we use the information to assess suitability for case referral based on location, techniques used and specialities treated.
- For Job Applicants and Employees
- we use career information to assess suitability to fulfill an existing job vacancy with AHR for job applicants. For Employees we use personal information to assist in the HR functioning of the organisation.
3. With whom and where will we share your personal data?
Your individual data is not shared with any third party unless we are legally obliged to do so.
For individual clients availing of EAP counselling with an affiliate counsellor, your name, telephone number, assigned client code, date of first appointment and presenting issue synopsis are shared with the counsellor to facilitate the initial appointment.
For affiliate counsellors, your name, telephone number and date of first appointment are shared with client to facilitate the initial appointment.
We may share your web personal data with the other third parties:
- search engine and web analytics.
- our suppliers, business partners and sub-contractors; and/or
- our professional advisors such as our auditors and external legal and financial advisors;
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of AHR for the purposes above. Such third parties include, but are not limited to, providers of website hosting and maintenance. In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
4. How long will you keep my personal data?
The personal data of individual clients relating to the psychological intervention provided is retained for a commensurate period in accordance with the ethical obligation placed on us by virtue of our professional body membership (the Psychological Society of Ireland). AHR have determined this to be seven years.
We will not keep your personal information for any other purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose.
We are required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
In the case of any contact you may have with our customer services team, we will retain those details for as long as is necessary to resolve your query and for two weeks after the query is closed.
We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require AHR to hold certain information for specific periods other than those listed above.
5. Where we store the data?
All personal data that is collected directly by us is stored securely in the Republic of Ireland. Any personal data that is collected from you via our websites may be transferred to, and stored outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the third country’s data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our Privacy Team.
6. What are my rights in relation to my personal data?
Where you have consented to us using your personal data, you can withdraw that consent at any time.
If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.
You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data:
- by withdrawing your consent for us to use it;
- if it is no longer necessary for us to use your personal data;
- if you object to the use of your personal data and we don’t have a good reason to continue to use it; or
- if we haven’t handled your personal data in accordance with our obligations.
7. Where can I find more information about AHR’s handling of my data?
Should you have any queries regarding this Privacy Notice, about AHR’s processing of your personal data or wish to exercise your rights you can contact AHR’s Privacy Team using this email address: privacy@ahr.ie.
If you are not happy with our response, you can contact the Data Protection Commissioner: https://www.dataprotection.ie/