Privacy

1. Introduction

Trinity Motor Group needs to collect and use certain types of information about the Individuals or Service Users who come into contact with Trinity Motor Group in order to carry on our work. This personal information must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

2. Disclosure

Trinity Motor Group may share data with other agencies such as Manufacturers, the local authority, funding bodies and other voluntary agencies.

The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows Trinity Motor Group to disclose data (including sensitive data) without the data subject’s consent.

These are:

Carrying out a legal duty or as authorised by the Secretary of State

Protecting vital interests of an Individual/Service User or other person

The Individual/Service User has already made the information public

Conducting any legal proceedings, obtaining legal advice or defending any legal rights

Monitoring for equal opportunities purposes – i.e. race, disability or religion

Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures. regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.

3. Personal Data Protection Principles

Trinity Motor Group intends to ensure that personal information is treated lawfully and correctly. To this end, Trinity Motor Group will adhere to the Principles of the General Data Protection Regulation ((EU) 2016/679).

Specifically, the Principles require that personal information:

Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,

Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,

Shall be adequate, relevant and not excessive in relation to those purpose(s)

Shall be accurate and, where necessary, kept up to date,

Shall not be kept for longer than is necessary

Shall be processed in a manner that ensures its security using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage,

Not transferred to another country without appropriate safeguards being in place

Made available to Data subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data

Trinity Motor Group, through appropriate management and strict application of criteria and controls:

Observe fully conditions regarding the fair collection and use of information

Meet its legal obligations to specify the purposes for which information is used

Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements

Ensure the quality of information used

Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:

The right to be informed that processing is being undertaken,

The right of access to one’s personal information

The right to prevent processing in certain circumstances and

The right to correct, rectify, block or erase information which is regarded as wrong information)

Take appropriate technical and organizational security measures to safeguard personal information

Ensure that personal information is not transferred abroad without suitable safeguards

Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information

Set out clear procedures for responding to requests for information

4. Data collection

Informed consent is when

An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data

And then gives their consent.

Trinity Motor Group will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.

When collecting data, Trinity Motor Group will ensure that the Individual/Service User:

Clearly understands why the information is needed

Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing

As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed

Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress

Has received sufficient information on why their data is needed and how it will be used
5. Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.

Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is Trinity Motor Group responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

6. Data access and accuracy

All Individuals/Service Users have the right to access the information Trinity Motor Group holds about them. Trinity Motor Group. will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.

In addition, Trinity Motor Group will ensure that:

It has an individual with specific responsibility for ensuring compliance with Data Protection
Everyone processing personal information understands that they are contractually responsible for following good data protection practice
all data breaches must be reported to the data protection commissioner within 72 hours and where there is a risk to the privacy rights of the individual concerned, then to that individual without delay.
Everyone processing personal information is appropriately trained to do so
Everyone processing personal information is appropriately supervised
Anybody wanting to make enquiries about handling personal information knows what to do
It deals promptly and courteously with any enquiries about handling personal information
It describes clearly how it handles personal information
It will regularly review and audit the ways it holds, manage and use personal information

It regularly assesses and evaluates its methods and performance in relation to handling personal information
All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the General Data Protection Regulation ((EU) 2016/679).
In case of any queries or questions in relation to this policy please contact Mary Cullen data@trinitymotors.ie

Trinity Motor Group incorporating

E. Murphy Motors Ltd

Tony Roche Car Sales Ltd

Trinity Motors Mazda Ltd.
Glossary of Terms
Data Controller – The person who (either alone or with others) decides what personal information Trinity Motors will hold and how it will be held or used.
General Data Protection Regulation ((EU) 2016/679) – The legislation that provides a framework for responsible behaviour by those using personal information.
Individual/Service User – The person whose personal information is being held or processed by Trinity Motors for example: a client, an employee, or supporter.
Explicit consent – is a freely given, specific and informed agreement by an Individual/Service User in the processing of personal information about her/him. Explicit consent is needed for processing sensitive data.
Notification – Notifying the Information Commissioner about the data processing activities of Trinity Motors, as certain activities may be exempt from notification.

Processing – means collecting, amending, handling, storing or disclosing personal information.
Personal Information – Information about living individuals that enables them to be identified – e.g. name and address. It does not apply to information about organisations, companies and agencies but applies to named persons, such as individual volunteers or employees within (GROUP).
Sensitive data – refers to data about:

Racial or ethnic origin

Political affiliations

Religion or similar beliefs

Trade union membership

Physical or mental health

Sexuality

Criminal record or proceedings