Privacy Policy | Enable Ireland

Enable Ireland is committed to protecting your privacy and the personal information you and others provide to us. This statement outlines what we do with the personal information you provide to us, why we gather it and what it means to you. If you are under 16 years of age, please read this statement with a parent or guardian and ensure you understand it. This statement outlines our approach to Data Protection to fulfil our obligations under the General Data Protection Regulation (GDPR).

Who we are:

We are Enable Ireland Disability Services, a Company Limited by Guarantee registered under company number 13909 with a registered address at 32F Rosemount Park Drive, Rosemount Business Park, Ballycoolin Road, Dublin 11, Ireland.

We are a partly state funded charitable organisation which provides services to children and adults with physical, sensory and intellectual disabilities in 15 counties across Ireland. We process personal data and special category personal data about people to carry out this core work. We are also engaged in training, research, fundraising, direct marketing, office administration, finance and HR administration including payroll and recruitment. We manage relationships with volunteers, contractors and authorities such as the HSE.

For the purpose of the GDPR, the data controller is Enable Ireland Disability Services, Limited by Guarantee (“Enable Ireland”).

What Personal Information do we collect from you?

Enable Ireland processes personal data about service user/owners and their carers/family members/representatives, prospective volunteers, donors, advocates, supporters, contractors, suppliers and individuals in sponsor companies or partner organisations job applicants or former employees/colleagues and users of Enable Ireland's Assistive Technology e-learning site (https://enableirelandat.ie).

Enable Ireland does not engage in profiling or automated decision making. However, if you are a member of the Friends of Enable Ireland Network, a fundraiser, volunteer or donor of Enable Ireland, we may analyse the outcomes of our fundraising campaigns, your preferences and engagements with you to tell you about fundraising events, activities or volunteer opportunities that may be of specific interest to you. You may opt-out of your personal data being used for this type of analysis by contacting friends@enableireland.ie, or by contacting the Data Protection and Compliance Officer (details are below).

Enable Ireland processes different types of personal data and special category personal data depending on how and why you are interacting with us.

Purpose	Categories of data processed
Health & Social care services when attending our service centres located across Ireland	Health data (referral letter from a third party, medical records and assessments, diagnosis, medical/physical history and medication details, hospital details, physician/healthcare professionals details, vaccination status), contact names and initials, addresses, telephone numbers, email, date of birth, country of birth, gender, next of kin contact details and relationship to service user/owner, photographs, videos received from service users/owners and voice recording, face image and IP addresses while in virtual consultations with service users/owners, attendance records, healthcare professional reports and update reports for carers/guardians, medical card numbers, social preferences, dietary, social, sleep and spiritual needs, assistive technology needs and personal care needs, funding applications.
Communications	Contact names, addresses, telephone numbers, email, social media identifiers such as Facebook®, twitter®, Instagram®, photographs, videos, stories and health data, completing forms on www.enableireland.ie (our site) such as the 'Contact Us' form or when subscribing to receive our Newsletter or other such websites that are within our control.
Training & research	Contact names, addresses, telephone numbers, email, assignments, training records, health data.
Office Administration & Finance Management	Contact names, contact details, tax identifiers (e.g. VAT number for service providers), bank details, legal claims, timesheets and payment data, data associated with accounts receivable or accounts payable.
Direct Marketing & Fundraising	Contact names, contact details, PPSN for donors, bank details, health data, photographs, stories, video or audio footage, donor, volunteer and supporter preferences and interests, service region and additional contact names and addresses.
Donations	Contact name and address; email address; credit/debit card details; PayPal details; bank account details/direct debit mandate form; age group; tax payer status and PPSN number (where you wish to avail of tax relief in respect of your donation)
Human Resources Recruitment	Application form, references, CVs (employment history and education), Garda/Police vetting declarations, professional qualifications and other recruitment documents and if we conduct interviews using a virtual platform, then we will process your face image, voice recording and IP address.
Wellbeing, Safety & Security	Occupational health data, accident & incident reports, safeguarding/ risk assessment information, location data and CCTV recordings.
Website management	Google Analytics data including IP addresses (see cookie policy).
Assistive Technology e-learning site	When you create an account on https://enableirelandat.ie we require the following data: Name, age (for verification purposes), country of residence (for verification purposes) and email address. Optional personal data we collect if you choose to provide additional profile information: Profile photo, residence (town/county), any interests, professional background information or other personal details you choose to add to your account profile. Engaging in one of the courses on this site we may also collect the following data: Assignments, training records, logs (activity on the course), video and/or still image you upload, forum posts (this could include special category personal data that you have shared such as health, race and ethnicity, religious or philosophical beliefs), quiz results, survey and feedback answers.

Where do we get this information from?

We obtain personal data about you if:

you apply for a job in Enable Ireland;
you or your parent/guardian/ carer contact us to request you become a service user/owner. If someone gives us information about you, we may add it to any personal information we already hold and use it in the ways described in this Notice. Before you disclose information to us about another person, you should be sure that you have their consent to do so. You should also show them this Notice. You need to ensure that they confirm that they know you are sharing their personal information with us for the purposes described in this Data Protection Notice;
a health or social care professional shares data with us by way of a referral;
you contact us to become a volunteer, donor, course participant or advocate or subscriber to fundraising campaign or website;
we complete a business transaction with you as a supplier of products / services, or as a customer of our shops;
you engage with Enable Ireland's Assistive Technology e-learning site.

We may have your personal data because your company or organisation has entered into a partnership with Enable Ireland. In limited circumstances data is publicly available and there would be a reasonable expectation that an organisation such as Enable Ireland would process it, for example, you are a journalist, medical expert, academic, politician, business leader or celebrity.

Why do we collect this information?

We collect the information in order to provide you with our services, to market our services, to fundraise, to improve our organisation and to recruit staff and volunteers. We will use this information to:

carry out our obligations arising from any agreements entered into between you and us e.g. to provide you with our disability services where you are a service user;
communicate with you as part of our relationship with you or in accordance with our agreement with you;
carry out fundraising and marketing activities which include to market you according to your preferences, process your donation, process volunteer opportunities and process your subscriptions.
set you or your company up as a supplier on our systems and to pay you for products/services provided to us;
liaise with you about projects that we are undertaking with you;
create a candidate profile for you if you are a job applicant;
administer and improve our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
deliver information about our services and our organisation, where you have subscribed to receive same;
As part of our efforts to keep our organisation safe and secure;
Operations of the Assistive Technology e-learning site.

The legal bases for the processing of your data are:

Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract;
Processing necessary for compliance with a legal obligation to which we are subject, for example, providing information to Health Information Quality Authority (HIQA) or Health Service Executive (HSE);
Processing necessary in order to protect the vital interests of you or of another natural person;
That you have provided consent for the processing for one or more specified purposes such as marketing, for example, when you subscribe to our newsletter or opt to receive information from us in respect of our organisation;
Processing necessary for the purposes of the legitimate interests which we pursue for example administer and record your donation, providing you with information about fundraising campaigns you have agreed to take part in, provide you with information necessary for any training event, workshop or event you sign up for, follow up on your queries, assess our fundraising activities or efficiently and effectively providing suitable e-learning training via Assistive Technology e-learning site.

The legal basis for the processing of your Special Category Personal Data (i.e. your medical/health data) are:

That the processing is necessary for the provision of health care, treatment or social care and for the purposes of medical diagnosis;
That the processing is necessary in order to protect your vital interests or that of another person where you are physically or legally incapable of giving consent.

Who do we share this information with?

We may share your personal data and where necessary, Special Categories of Personal Data, with selected third parties as listed below* including suppliers and contractors in order to provide you with our services. For example, these suppliers may include our web hosting provider and our IT service providers.

In addition, we may disclose your personal information (including Special Categories of Personal Data) to third parties:

Which are part of the Progressing Disability Services (‘PDS’) framework. As part of this arrangement Enable Ireland has formed partnerships with a number of other service providers with the aim of improving access to disability services across Ireland;
If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our service user/owner/customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
As part of projects with other companies in the Enable Ireland group of companies if applicable.
Where solicitors or your elected power of attorney have your written authorisation to be provided with the personal data we hold about you
When you are under age of eighteen, we will share your personal data with your legal guardians.

*Note:

Where we engage third parties to process data on our behalf we will ensure the appropriate data processing agreements are in place.
The table below captures some of the third parties we engage with.
We reserve the right to update the list as the need arises.
Where you have a query regarding third parties we engage with, please contact Enable Ireland's Data Protection & Compliance Officer for information.

PDS Partner Organisations;
-   St. Michael’s House;
-   Stewarts Care Limited;
-   Central Remedial Clinic;
-   Muiriosa Foundation;
-   Daughters of Charity;
-   Brothers of Charity;
-   CoAction;
-   St. Gabriel’s School and Centre;
-   Western Care Association;
-   Ability West;
-   Cope

-   St. Joseph’s foundation
- St. Catherine's Association Ltd.(Wicklow)
-   Cheeverstown (Dublin)
-   Health Services Executive (HSE)

Provision of health care and services to service user/owners under the PDS Partnership arrangement.

HIQA

Legal obligation to disclose certain information

TUSLA/HSE safeguarding

Legal obligation to disclose certain information

Health Service Executive