Privacy Policy

PRIVACY POLICY

Destination People Ltd (‘Destination People Ltd’) is committed to protecting all personal, special, and criminal categories of data held on you.

Destination People Ltd is the controller and responsible for your personal data.

As such, Destination People Ltd wants you, the ‘data subject’, to understand how Destination People Ltd collects, uses, stores, and shares your personal data. Destination People Ltd also wants you to understand what rights you can invoke to help you to protect your privacy. In this regard, it is important that you read this Privacy Notice and understand how Destination People Ltd uses your personal data. Please note that Destination People Ltd reserves the right to update this Privacy Notice as required.

Legislation

All personal data processed by Destination People Ltd is done so in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Queries and Complaints

If you are unhappy with the way Destination People Ltd handles your personal data and wish to complain, or if you simply want further information about the way your personal data will be used, please contact Destination People Ltd at [email protected]

Breaches

Destination People Ltd will take all appropriate technical and organisational steps to safeguard your personal data. In the unlikely event of a data breach, Destination People Ltd will contact you in line with Destination People Ltd’s legal obligations.

How Does Destination People Ltd Collect Information?

Destination People Ltd collects personal data to enable the provision of services to support the Destination People Ltd purpose. The following non-exhaustive methods of data collection are an indication of ways in which Destination People Ltd may obtain your information:

Obtain personal data directly from you;and
Personal data that Destination People Ltd receives from other sources.

It is important that the personal data you provide Destination People Ltd is up to date and accurate. If personal data Destination People Ltd holds on you is inaccurate or incomplete, please contact Destination People Ltd and Destination People Ltd will update the information.

What Does Destination People Ltd Use Information For?

Process, Purpose, and Lawful Basis

Destination People Ltd uses personal data collected to fulfil Destination People Ltd’s obligations to provide its services and to enable the provision of services to support Destination People Ltd’s purpose.

Destination People Ltd uses personal data for any of the following purposes:

Process	Purpose	Lawful Basis
Pre-Program Information	To register a prospective data subject’s interest in any of The Lost Vet’s courses.	Processing is necessary in order to take steps at the request of the data subject prior to entering into a program.

Voice of the Customer	To obtain the data subject’s feedback by survey on the Destination People Ltd program, services and for research purposes.	Processing is based on request of consent which will be taken from the data subject.
Regulatory Compliance	To comply with financial regulations and any other relevant laws and regulations.	Processing is necessary for compliance with a legal obligation to which Destination People Ltd is subject.
Third Party Data Sharing	To allow Destination People Ltd to conduct and carry out functions with third party service providers that enable Destination People Ltd to deliver services.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Back-ups	To store personal data and make back-ups of that data in case of emergencies and for disaster recovery purposes.	Processing is necessary for compliance with a legal obligation to which the Destination People Ltd is subject.
Evidence Submissions	To gather information for dispute resolution services and legal proceedings.	Processing is necessary for compliance with a legal obligation to which the Destination People Ltd is subject.
Transfer of Information for Parties Legal Proceedings	To allow parties to commence legal proceedings.	Processing is necessary for compliance with a legal obligation to which the Destination People Ltd is subject.

Who Does Destination People Ltd Share Information With?

Destination People Ltd may share personal data with other parties in the course of Destination People Ltd’s duties. When this is done, Destination People Ltd adheres to the following principles:

The transfer is based on a legal obligation, the performance of a contract, or explicit consent.
Where data is transferred to another party, Destination People Ltd ensures appropriate technical and organisational safeguards are used to protect your personal data.
Where Destination People Ltd engages a third party to provide a service to Destination People Ltd, Destination People Ltd ensures the provider has taken appropriate technical and organisational measures to process, store, and safeguard your personal data.
Destination People Ltd, as a Data Controller, will not sell your data to any third party and will take all appropriate steps to ensure the security of your data in dealings with third parties.

While the parties Destination People Ltd engage in may change occasionally, Destination People Ltd believe it is important you are aware of the types of parties Destination People Ltd shares data with. The categories and types of third parties outlined below is a non-exhaustive list but provides an indication of the parties Destination People Ltd shares data with.

Other Third Parties

Third parties for the purposes of internal and external audits, carrying out research and or third parties who may improve Destination People Ltd’s processes and services.

Government Departments, Bodies or Agencies

Destination People Ltd is legally obligated to share personal data with state actors which is outlined in the Data Protection Act 2018.

Recipients of this data include Government departments, agencies, bodies, investigatory bodies, local authorities, and the Gardaí.

International Transfers

Where personal data is transferred outside the European Economic Area, Destination People Ltd use safeguards known as Standard Contractual Clauses (SCCs).

What Type of Information is Collected?

To fulfil Destination People Ltd’s mandate and perform tasks as outlined in this statement, Destination People Ltd needs to collect various types of personal data.

While the type of personal data may change occasionally, Destination People Ltd believes it is important you are aware of the types of data Destination People Ltd gathers and uses. The following table is a nonexhaustive list and provides an indication of the categories and types of data Destination People Ltd uses to perform Destination People Ltd’s tasks.

Please note that information listed under one category may be used for the performance of a task or in relation to activities under another heading.

Category	Type of Data
Candidates	Name, education, date of birth, phone number, address, email address, job title, bank details, PPS number and training records. Medical data, health screening, health diagnosis, blood test results and immunisations, health / medical declarations. Criminal data such as garda vetting documents.
Employees	First name, last name, date of birth, address, contact details, email address, family details, financial, tax, pension, remuneration details, performance details, visual images details, employee ID, CCTV footage, lifestyle and social circumstances, education, and training details, grievance and disciplinary documents such as incident reports and complaints. Special data such as medical checks, medical records, sick leave details. Criminal data such as garda vetting documents.
Other Stakeholders	Contact details, first name last name, email address, images, bank details and payment details.

How Long Does Destination People Ltd Retain Information?

Destination People Ltd has developed a record retention schedule for all the personal data Destination People Ltd holds. Each retention period varies dependent on the nature and the purpose of the processing.

The main factors which determine retention periods are as follows:

How long it is required to perform the task;
Any legal requirements to hold onto the data;
Any pending legal actions.

What Are Your Rights?

As a data subject, you will have the following rights. However, restrictions may apply in certain situations.

Where do I send requests?

Please send all your requests to [email protected] with as much detail as possible about your requirements to allow Destination People Ltd to deal with your request efficiently. To answer your request, Destination People Ltd may ask you to provide identification for verification purposes.

How long will a request take?

Upon receipt of a request, Destination People Ltd will have 30 days to provide an answer with an extension of two further months if required. If Destination People Ltd requires more time to deal with your request, Destination People Ltd will notify you of the delay and the reasons behind it within 30 days of the receipt of the request. If Destination People Ltd refuses your request, Destination People Ltd will also notify you within 30 days of the receipt of the request accompanied by the reasons for the refusal.

Destination People Ltd will not charge a fee for any requests, provided Destination People Ltd does not consider them to be unjustified or excessive. If Destination People Ltd considers these to be unjustified or excessive, Destination People Ltd may charge a reasonable fee (also applicable for multiple copies) or refuse the request.

You are entitled to contact the Data Protection Commission if Destination People Ltd refuses your request.

Right of Access

You have a right to know what personal data Destination People Ltd holds on you, why Destination People Ltd holds the data, and how Destination People Ltd is processing your personal data.

When submitting your request, please provide Destination People Ltd with information to help verify your identity and provide as much detail as possible to help Destination People Ltd understand the information you wish to access (i.e. date range, subject of the request) and email [email protected].

Please note that an access request is free of charge, however, where Destination People Ltd determines a request to be unjustified or excessive, Destination People Ltd may charge you a reasonable fee.

Right to Rectification

You have a right to request that Destination People Ltd information held on you is up to date and accurate.

Where information is inaccurate or incomplete, Destination People Ltd encourage you to contact Destination People Ltd to have this information rectified. Upon receipt of request, Destination People Ltd will ensure that the personal data is rectified and as up to date as is reasonably possible.

Right to be Forgotten

You have the right to seek the erasure of your personal data in the following circumstances:

The personal data is no longer required for the purposes for which is was obtained;
Where data is being processed on the basis of consent, you withdraw consent to the processing and no other lawful basis exists;
The personal data is being unlawfully processed;
You object to the processing of personal data and there are no overriding legitimate grounds for the processing;
Your personal data requires deletion in line with legal requirements.

However, Destination People Ltd will be unable to fulfil an erasure request if the processing of personal data is necessary for the following:

Exercising the right of freedom of expression and information;
Compliance with a legal obligation or for the performance of a task carried out in public interest;
Reasons of public interest in the area of public health;
Archiving or statistical purposes in the public interest;
The establishment, exercise, or defence of legal claims;

Please note that where the legal basis for Destination People Ltd’s processing of personal data is on the basis of a legal obligation, some processing in relation to your data may not be subject to the right to erasure.

To determine your request for erasure, Destination People Ltd will carry out an assessment of the justification for retaining your personal data where a legal requirement applies and contact you if Destination People Ltd is unable to fulfil your request.

Please be aware that in some circumstances Destination People Ltd may need to retain some information to ensure all your preferences are properly respected. For example, Destination People Ltd cannot erase all information about you where you have also asked Destination People Ltd not to send you marketing material. Otherwise, Destination People Ltd would delete your preference not to receive marketing material.

Right to Restriction

You have the right to restrict the extent of personal data processed by Destination People Ltd in circumstances where:

You believe the personal data is not accurate (restriction period will exist until Destination People Ltd updates your information);
The processing of the personal data is unlawful, but you wish to restrict the processing of data rather than erase it;
Where the personal data is no longer required by Destination People Ltd, but you require retention of the information for the establishment, exercise, or defence of a legal claim;
You have a pending objection to the processing of the personal data;

When processing is restricted, your personal data will only be processed: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest.

Destination People Ltd will contact you confirm where the request for restriction is fulfilled and will only lift the restriction after Destination People Ltd has informed you that Destination People Ltd is doing so.

Right to Data Portability

You have the right to the provision of all personal data held in relation to you in a structured, commonly used and machine-readable format where:

Processing is completed on the basis a contract;
Processing is completed based on consent by the you;
Processing is carried out by automated means.

You may also request that Destination People Ltd sends this personal data to another data controller where technically feasible.

Right to Object

You have the right to object to the processing of your personal data; however, the processing must have been undertaken on the basis of public interest or legitimate interest by Destination People Ltd.

If you wish to object to the processing of data, please contact Destination People Ltd with your request. Destination People Ltd will then stop the processing of personal data unless it is required for legal proceedings.