Privacy Statement

IPHA Website Data Privacy Statement

Introduction

The purpose of this policy is to provide you with details of how we, The Irish Pharmaceutical Healthcare Association (IPHA), collect and hold personal data about you, how we process it and who we share it with. It also explains your rights under data protection law in relation to our processing of your data.

Who controls the use of your personal data and contact details?

The Irish Pharmaceutical Healthcare Association, a company limited by guarantee exempt from the requirement to use ‘CLG’ in its name (with the registered business name ‘IPHA’), whose registered address is 7 Clanwilliam Terrace, Dublin 2, is the company that controls and is responsible for personal data that is covered by this privacy statement. IPHA is therefore a ‘data controller’ of the personal data collected via its website www.ipha.ie and the personal data provided by you to IPHA in the context of our dealings with you. Our contact details are:

Our Data Protection Representative is Oliver O’Connor and may be contacted by email at chiefexecutive@ipha.ie. You may also contact info@ipha.ie with your queries.

Overview

This privacy statement sets out how we use your personal data. It applies to personal data we collect from you as a data controller when you engage with this website and when you engage with us by subscribing to our newsletter or by signing up to attend in-person and online conferences and events. Please note that this privacy statement does not apply to where we act as a data processor.

You can also choose to provide your Personal Data to us via email, by telephone, or by request via forms on the Website, which we will process for the purposes of responding to your queries.  We also process Personal Data obtained via third parties.

We share your Personal Data with other parties in order to provide you with the website, to improve our website, to respond to your queries, for marketing purposes, to provide you with requested services and in other circumstances as set out below. We will also share your Personal Data with law enforcement agencies, public bodies or other parties where necessary, including by Court order or if we are required by law to do so. We may also share your Personal Data (limited to the extent that is necessary) between affiliates and or member groups. We may also share your Personal Data (first and last name and company name) to the speakers at our events and conferences.

What personal data do we collect:

We have categorised types of Personal Data we collect about you as set out below:

• Contact Data includes contact information such as first name, last name, email address, company name, email address, telephone number, other contact details provided directly by you – in person, by email and/or via our website.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Usage Data includes information about how you use our Website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

Generally and subject to the below, we do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data in accordance with the law. Most commonly, we will use your personal data in the following circumstances:

• Where you have given consent.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where we are contacting you with updates and or marketing.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting chiefexecutive@ipha.ie or info@ipha.ie.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at chiefexecutive@ipha.ie or info@ipha.ie. if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

NEWSLETTERS, BULLETINS AND INFORMATION FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which email correspondence may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or used our services before, in each case, and you have not opted out of receiving that marketing.

EVENTS

We will invite you to IPHA and our affiliates events. If you sign up to attend such an event, we will use your contact details to contact you about the details of the event and its speaker(s). Limited details may be shared with an event sponsor or event speaker(s) in order to comply with our contractual obligations with them and in order to inform our event sponsors and speakers of the expected audience for their legitimate interests and for their business development. Event sponsors and speakers are always informed that no further processing of your data is permitted (unless you have consented at the time of signing up to the event or at the event itself).

To the extent that your personal data is processed by an event sponsor or speaker (or an event speaker’s employer), please refer to their privacy notices.

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any company outside of IPHA for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing emails at any time by following the opt-out links on any marketing email sent to you or by contacting us at chiefexecutive@ipha.ie or info@ipha.ie.

Where you opt-out of receiving these marketing emails, this will not apply to personal data provided to us as a result of a service provided by us for other reasons.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us at chiefexecutive@ipha.ie or info@ipha.ie.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We will share your personal data with third parties for the purposes set out in the table in paragraph 4 above.

The type of third parties we share your personal data with are:

• IT service providers (such as Microsoft);
• Website hosting services (such as WordPress) ;
• Cloud storage providers (such as Google Cloud);
• Marketing agencies and platforms (such as Mailchimp);
• Online survey sites (such as Survey Monkey);
• Website analytics services (such as Google Analytics);
• Speakers at IPHA and IPHA affiliate hosted events and conferences;
• Event sponsors.

Third party service providers we use to run our business may be subject to change in accordance with our business needs.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only allow third parties to handle your personal data if we are satisfied that they take appropriate measures to protect your data. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will also share your personal data where we are required to do so by law.

We or the third parties mentioned above occasionally also share your personal data with:

• Our and their external auditors, in which case the third party will be bound by confidentiality obligations;
• Our and their professional advisors (such as lawyers) in which case the third party will be bound by confidentiality obligations;
• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with legal and regulatory obligations.

If you would like further information about who we share your data with and why, please contact our Data Protection Representative Oliver O’Connor at chiefexecutive@ipha.ie. You may also contact info@ipha.ie with your queries.

INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure that it is transferred in compliance with Chapter V of the General Data Protection Regulation, further details of which are available on request by contacting chiefexecutive@ipha.ie or info@ipha.ie.  Typically, we rely on an adequacy decision of the European Commission, Standard Contractual Clauses or a derogation as set out in Article 49 of the GDPR, namely your consent, or, in the exercise or establishment or defence of a legal claim.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We set out below the different retention periods applicable for different types of personal data:

These retention periods are strictly complied with unless a longer retention period is required by statute or for the purpose of a legal claim, in which case personal data will be held for a longer, but limited, period.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you and is not considered personal data) for statistical purposes in which case we may use this information indefinitely and share with a third party without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• NO FEE USUALLY REQUIRED
  You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
• WHAT WE MAY NEED FROM YOU
  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• TIME LIMIT TO RESPOND
  We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month, in this case, we will notify you and keep you updated.

RAISING A COMPLAINT TO THE IRISH DATA PROTECTION COMMISSION

You have the right to make a complaint about the way we use your personal data to the Data Protection Commissioner (DPC) at their website www.dataprotection.ie or by post at:

21 Fitzwilliam Square S, Dublin 2, D02 RD28

Before you make a complaint to the DPC, we would be grateful if you contacted us first in order to allow us the chance to deal with your complaint first at chiefexecutive@ipha.ie or info@ipha.ie.

CHANGES TO THIS PRIVACY STATEMENT

If we amend this Privacy Statement, in whole or part, any changes will be posted on this page and, where appropriate, notified to you by email or when you use the Website. The new Privacy Statement may be displayed on-screen and you may be required to read and accept it to continue your use.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Statement, or otherwise disclosed to you at the time it was collected, we will notify you of same

Dated October 2023

See more info about the Cookies we use on our website here