ABOUT OCCUPATIONAL PHYSIOTHERAPY SOLUTIONS (OPS) Limited
Occupational Physiotherapy Solutions with the registered address of 96 Lower Kilmacud Road, Stillorgan,Co. Dublin, Ireland A94 X5X5 and the company registration number of 396453, (also referred to as “we”, “our”, “us”) is the Data Controller when you provide information to us.
This Privacy Statement defines how we collect, use, share, store, our legal basis, how long we keep your data and your rights. Any information that we process will be held in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act, 2018 and other Irish or EU Data Protection legislation.
LEGAL BASIS FOR USING YOUR INFORMATION
All businesses must have a legal reason to use your personal information, if they do not have one, they cannot use your data. There are several legal grounds that enable data processing. Outlined below are the most relevant grounds you should be aware of.
WHEN YOU ARE A CLIENT OR A POTENTIAL CLIENT
When you use are a potential client or a client, we will process the following personal data about you:
To provide our services, we collect and process your personal data. We process information about you when you begin using our services and we process it on an on-going basis, should you become a client.We will process the following:
- Name, address, phone number, email;
- A record of the information that you provide to us;
- Conversations you have when you call us;
- When you book to attend and pay for a course;
- When you complete a feedback form, either manually or online; and
- For Quality and Qualifications Ireland (QQI) certification. Some of our training courses lead to a QQI qualification and for this we are required to look for additional information on behalf of QQI. We collect this information via our Course Application Form. This form includes your PPS number and your date of birth and the signifier of Male or Female. These must match the name on the QQI database. If a difficulty arises, proof of identity will also be sought, e.g. a copy of your passport or driving licence etc., These are destroyed once the matter is resolved with QQI.
We also look for relevant work details including if the applicant has the relevant people handling experience and is suitable to undertake the course in question to comply with Health and Safety Legislation.
For course participants to be submitted for certification with QQI, they are required to complete assessments and question papers relevant to their particular course. These must be hand delivered/posted or emailed to us for marking by our internal assessor. These assessments are held until QQI External Authentication is undertaken and are then destroyed in accordance with our Secure Disposal Policy. We also retain results sheets for each cohort of participants, which list, name, PPS number, mark and grade obtained. These result sheets are retained indefinitely.
Where you provide information to us about other people, you need to make sure you have their permission to do so.
Lawful basis relied upon: The processing is necessary for the performance of a contract, consent or legitimate interest.
Contract is where we either have a contract with you or you wish to enter into a contract with us. For example, when you order services from us, we will process your information to administer that transaction.
There may be situations where we need to use your information to comply with legal obligations. We are required by law to keep your information on file for the purposes of complying with the Revenue Commissioner, Health and Safety legislation and also for Professional Indemnity Insurance purposes.
We process the following data because we have a legitimate interest:
- Keeping your data in our system to keep it secure;
- Your email in a suppression list so that we do not email you again by accident;
- The date on which you started using our services;
- The date on which you ceased to use our services;
- A record of any complaints or compliments made by you and the action taken in respect of any such complaint or compliments; and
- The IP address and the MAC address when you visit our website enables us to keep our website secure.
We process the following data because we have your consent:
- Training Feedback Form
On the completion of a course, all participants are requested to complete a feedback form. The purpose of this is to evaluate the training delivered and to make improvements to course delivery if necessary. On occasion, we may use quotations from our courses on our promotional materials. Such use is always anonymized. If we require a direct quotation, we will always contact you for your permission. We retain this information for a year following completion of a course.
When providing our services, we may process specific sensitive data for instance, when completing workplace and office ergonomic assessments, as well as Patient & Manual Handling Training we might process information relating to health (e.g., your medical condition). We rely on exceptions contained in Article 9 of the GDPR and the Data Protection Act 2018 to process this information.
WHY DO WE NEED YOUR DATA?
Occupational Physiotherapy Solutionsneeds to process personal data about our clients to provide effective and high-quality service and to fulfil our legal obligations. We will process your data to:
- Provide you with the services or information that you have asked for;
- Keep a record of your relationship with us;
- Send you correspondence and communicate with you;
- Meet our legal obligations;
- Respond to or fulfil any requests, complaints or queries that you may have; and
- Understand how we can improve our services or information;
WHEN AND HOW WE COLLECT YOUR INFORMATION
We may collect information you provide to us directly and indirectly when interacting with our products and services. This may include such interactions as:
- Make an initial approach to us by email or on the phone;
- Interact with us by email, text, or on social media; and
Occupational Physiotherapy Solutionsis a business-to-business service directed to and intended for use only by those who are 18 years of age or over. We do not aim our services at children, and we do not knowingly collect any personal data from any person under 16 years of age.
FINANCE & HUMAN RESOURCES
We process the following data because we have a legal obligation such as Employment Law and Taxation laws. Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract.Legitimate interest: processing is necessary to ensure Occupational Physiotherapy Solutions is effective and efficient in its regular business activities.
Contact details (first name, surname, postal address, email, phone number), CVs, medical certificates, bank details and PPSN for employees.
The information you provide will be held securely by us and our data processors whether the data is in electronic or physical format. We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for. The information we ask for is used to assess your suitability for employment.
If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks. You must complete pre-employment checks to progress to a final offerof employment. We are required to confirm the identity of our employees, their right to work in Ireland and seek assurance as to their trustworthiness, integrity and reliability. You will, therefore, be required to provide, proof of your identity,you will be asked to attend our office with original documents andwe will make copies. Evidence of your qualifications,you will be invited to attend our office with original documents, we will make copies. We will contact your referees, using the details you provide in your application, directly to obtain references. If we make a final offer, we will also ask you for the following:emergency contact details, so we know whom to contact in case you have an emergency at work.
YOUR BUSINESS FINANCE INFORMATION
Processing is necessary for compliance with a legal obligation such as Taxation laws. We collect financial data required to comply with Irish Tax law such as VAT numbers, PPSN, account details to pay and sending invoices.
USE OF OUR WEBSITE
We process the following data because we have a legitimate interest:
We have a legitimate interest in understanding how our clients and potential clients use its website. This assists us with providing more relevant services and communicating value to our clients.
See the Cookie Notice on our website for more details.
We collect personal information relating to you when you contact us through the contact forms on this website. This information may include your name, email and your phone number. We will only use this information to respond to your request. We will never use this information to market to you unless you have specifically requested us to reach out to you through the contact form.
We use a third-party provider, MailJet, to deliver our newsletter. As a part of MailJet’s services, it collectsstatistics around email opening and clicks using industry-standard technologies. If you no longer wish to receive marketing emails or newsletters from us, you have the right to ask us to stop processing your data for direct marketing purposes. Please send an email to firstname.lastname@example.org with ‘UNSUBSCRIBE’ in the subject line or click the Unsubscribe button in the newsletter email you received from us.
There are some activities where we process personal information with your permission, which you can withdraw at any time, although if you do, we may not be able to provide the product or service you have requested. An example is where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. We will indicate in this Privacy Statement where we rely on consent.
Where we may rely on consent to use your information, you have the right to revoke that consent for that processing activity at any time. However, we may have the right to rely on an alternative legal basis for the processing activity and will inform you of that.
A withdrawal of consent may still allow the processing of your data if:
- Processing is necessary for the performance of a contract with you.
- Processing is necessary for compliance with a legal obligation.
- Processing is necessary to protect yourvital interest or that of another person.
- Processing is necessary for the performance of a task carried out in the public interest.
- Processing is necessary for the legitimate interests pursued by the controller or a third party; except where such interests are overridden by your interests or fundamental rights and freedoms.
If you do withdraw consent, we may not be able to provide you with the product or service you have requested.
We want to send you information about our services, training and events from time to time which may be of interest to you. If you have consented to receive such marketing information, you may opt-out at a later date. You have a right at any time to ask us not to contact you for marketing purposes.
In addition to sending you information about the services you use, and where we have your permission, we may send you direct marketing communications about our services, events and offers.
Direct marketing communications may be sent by post, email, telephone, social media (such as LinkedIn, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our website.
We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our services.
You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
LINKED SERVICES, THIRD-PARTY SITES AND CONTENT
In some of our articles and blogs, we may reference other websites and provide linkswhich are outside of our control. This Privacy Statement doesnot cover these other websites and links. Occupational Physiotherapy Solutionsdo not accept any responsibility or liability for other sites’ Privacy Notices/Statements or Privacy Policies. If you access other websites using the links provided, please read their policies before submitting any personal information.
Ourwebsite uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to “like” or share information from the OPS website through these services, you should review the Privacy Statement/Notice of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.
DISCLOSURES REQUIRED BY LAW
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
When we have answered your query and there is no opportunity for a follow-up – you may not wantErgonomic and/or Manual Handling Training servicesso we will hold onto your email for six calendar months, just in case you have forgotten something and come back to us.
RETAINING YOUR DATA
We shall keep your information perour Data Retention & Erasure Policy, or for as long as necessary for the uses set out in this Privacy Statement or while there is a legitimate business reason for doing so.
We hold your data:
- For enquires – 6 months.
- For marketing – until you withdraw consent or until we see that you are no longer opening the emails. We review our consents every year.
- For security – 1 year.
- After ceasing to be a client – 7 years.
- QQI – theresult sheets are retained indefinitely.
- Course Application Forms – these forms are retained indefinitely.
- Unsuccessful job applicants – 1 year.
- Successful job applicants – the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment.
If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. As an example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
YOUR RIGHTS UNDER THE GDPR & THE DATA PROTECTION ACT, 2018
You have rights in respect of our processing of your personal data which are:
- To access to your personal data and information about our handling of it. You also have the right to request a copy of your personal data (but we will need to remove information about other people).
- To rectify incorrect personal data that we are processing.
- To request that we erase your personal data if:
- We no longer need it;
- If we are processing your personal data by consent and you withdraw that consent;
- If we no longer have a legitimate ground to process your personal data; or
- We are processing your personal data unlawfully
- To object to our processing if it is by legitimate interest.
- To restrict our processing if it was by legitimate interest.
- To request that your personal data be transferred from us to another company if we were processing your data under a contract or with your consent and the processing is carried out automated means.
If you want to exercise any of these rights, please contact us at email@example.com.
WHO DO WE SHARE YOUR INFORMATION WITH?
We share your information with cloud service providers.
DATA TRANSFERS OUTSIDE OF THE EU OR EEA
We do not transfer any personal data outside of the EU or EEA.
CHANGES TO OUR PRIVACY STATEMENT
We reserve the right to modify this Privacy Statement at any time. Each time you use this website, you shall be bound by the then current Privacy Statement and accordingly you should review the Privacy Statement each time you use this website. This is a live document, under regular review. This policy was last updated in August 2018.
COMPLAINTS, QUESTIONS AND ASSISTANCE
If you have any comments, concerns or complaints about our uses of your information, we would ask that you contact us first, sothat we can try and resolve the matter.
You are encouraged to raise any issues with the Directors Murial Johnson & Lelia Jennings:
Post: 96 Lower Kilmacud Road, Stillorgan, Co. Dublin, Ireland, A94X5X5
Telephone: +353 (0) 1 2885855
COMPLAINING TO THE DATA PROTECTION COMMISSION (DPC)
Where we are unable to help, you can complain to the Data Protection Commission (DPC) in Ireland or the Statutory Authority in your country of residence, who will be able to liaise with the Data Protection Commission.
The Data Protection Commission (DPC) can be contacted at:
Post: Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, Ireland, R32 AP23.
Telephone: +353 (0) 57 8684800
Telephone: +353 (0)761 104 800
Lo Call Number:1890 252 231