PRIVACY POLICY

 

CS CONSULTING PRIVACY POLICY

INTRODUCTION

This Privacy Policy explains what we do with your personal data, whether we are providing you with a service, receiving a service from you, working with you as part of a project team or you are visiting our website.

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies to the personal data of our Website Users, Clients, Project Partners, Suppliers, and other people whom we may deal with in the course of carrying out our services. It also applies to the emergency contacts of our Staff. To be clear, if you are a member of CS Consulting Staff, you should refer to the CS Consulting Staff Privacy Policy which is available in the Employee Handbook.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), the company responsible for your personal data ("CS Consulting" or "us") is the “CS Consulting Group” (inclusive of KP & Associates Consulting Engineers Ltd. T/A Cronin & Sutton Consulting and CS Consulting, Cronin Sutton Cotter Ltd., KP & Associates Engineer Services Ltd., CS Consulting Engineers Ltd.).

It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.

What kind of personal data do we collect?

CLIENT DATA: If you are a CS Consulting Client, we need to collect and use information about you, or individuals at your organisation, in the course of providing you Consulting Engineering services.

The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know.  

SUPPLIER DATA: We don't collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we (or our Client) can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

PROJECT PARTNER DATA: The data we collect about Project Partners is very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know. 

PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS: We only ask for very basic contact details, so that we can get in touch with you because you’ve been listed as an emergency contact for one of our Staff members.

WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes anonymous information such as how our website is used, the frequency our website is accessed, and the times that our website is most popular. As we do this through Squarespace Analytics, all information is anonymous, and we do not receive specific information or details regarding any Website Users.

A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Where appropriate, some, are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.

How do we collect your personal data?

CLIENT DATA: There are two main ways in which we collect your personal data:

1.       Directly from you; and

2.       From third parties (e.g. Project Partners) and other limited sources (e.g. online and offline media).

SUPPLIER DATA: We collect your personal data during the course of our work with you on our own behalf or occasionally on behalf of our Client.

PROJECT PARTNER DATA: There are two main ways in which we collect your personal data:

1.       Directly from you; and

2.       From third parties (e.g. Clients and Project Partners) and other limited sources (e.g. online and offline media).

PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS: We collect your contact details only where a member of our Staff puts you down as their emergency contact.

WEBSITE USERS: Our website does not currently use cookies but our website is hosted through Squarespace. Their privacy policy can be viewed here:  https://www.squarespace.com/privacy/

How do we use your personal data?

CLIENT DATA: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly and to comply with legal requirements. The more information we have, the more bespoke we can make our service.

We use Client information for:

·       Consulting Engineering Services Activities;

o   Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to consulting engineering activities;

o   Keeping records of our conversations and meetings;

o   Undertaking customer satisfaction surveys;

·       Marketing Activities;

o   Sending Christmas cards, corporate gifts and invitations to events;

·       To help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."

If you are not happy about this, in certain circumstances you have the right to object.

SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us (or between you and our Client) can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.

We will only use your information:

·       To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;

·       To offer services to you;

·       To obtain support and services from you for us or on behalf of our Client;

·       To perform certain legal obligations;

·       To help us to target appropriate marketing campaigns; and

·       In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.

If you are not happy about this, in certain circumstances you have the right to object.

PROJECT PARTNER DATA: The main reason for using information about Project Partners is to ensure that the contractual arrangements between us and our mutual Clients can properly be implemented so that the relationship can run smoothly and to comply with legal requirements.

We use Project Partner information for:

·       Consulting Engineering Services Activities;

o   Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to consulting engineering activities;

o   Keeping records of our conversations and meetings;

o   Undertaking customer satisfaction surveys;

·       Marketing Activities;

o   Sending Christmas cards, corporate gifts and invitations to events;

·       To help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."

If you are not happy about this, in certain circumstances you have the right to object.

PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS: We use the personal details of a Staff member's emergency contacts in the case of an accident or emergency affecting that member of Staff .

WEBSITE USERS: We use your anonymous data to help us to improve your experience of using our website.

Please note that communications to and from CS Consulting Staff including emails may be reviewed as part of internal or external investigations or litigation.

Who do we share your personal data with?

CLIENT DATA: We will share your data only as required so that the contractual arrangements between us can properly be implemented.

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

·       Any of our group companies;

·       Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);

·       Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);

·       Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;

·       Third party Project Partners working with us on behalf of the Client;

·       Third party Suppliers engaged by us on behalf of the Client;

·       Third parties required over the course of a project such as Local Authorities, Irish Water, ESB, Survey Contractors, Building Contractors, Other Building Specialists, etc.

·       If CS Consulting merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

SUPPLIER DATA: We will share your data only as required so that the contractual arrangements between us (or our Client) can properly be implemented.

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

·       Any of our group companies;

·       Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);

·       Banking provider in order to process payments;

·       Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);

·       Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;

·       Third party Project Partners working with us on behalf of the Client;

·       Where we engage a Supplier on behalf of our Client for a project, we will share your information with the Client for direct payment;

·       Third parties required over the course of a project such as Local Authorities, Irish Water, ESB, Survey Contractors, Building Contractors, Other Building Specialists, etc.

·       If CS Consulting merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

PROJECT PARTNER DATA: We will share your data only as required so that the contractual arrangements between us can properly be implemented.

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

·       Any of our group companies;

·       Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);

·       Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);

·       Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;

·       Third party Project Partners working with us on behalf of the Client;

·       Third parties required over the course of a project such as Local Authorities, Irish Water, ESB, Survey Contractors, Building Contractors, Other Building Specialists, etc.

·       If CS Consulting merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS:  

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

·       Any of our group companies;

·       Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);

·       Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);

·       Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;

·       Third party Project Partners working with us on behalf of the Client;

·       Third parties required over the course of a project such as Local Authorities, Irish Water, ESB, Survey Contractors, Building Contractors, Other Building Specialists, etc.

·       If CS Consulting merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

WEBSITE USERS: We receive only anonymous analytics regarding our Website Users which we may share with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

How long do we keep your personal data for?

If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).

When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our services. We will also consider it meaningful contact if you communicate with us about potential contracts, either by verbal or written communication or click through from any of our marketing communications.

How can you access, amend or take back the personal data that you have given to us?

One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us.

To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.

Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:

·       we may ask you to verify your identity, or ask for more information about your request; and

·       where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.

If your interests or requirements change, you can unsubscribe from part or all of our marketing content by clicking the unsubscribe link in the email.

How do we store and transfer your data internationally?

CS Consulting is an international Company and we may have a need to transfer or store your data internationally.

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

Who is responsible for processing your personal data on the CS Consulting website?

CS Consulting Group website is hosted by Squarespace. Details of Squarespace’s Privacy Policy can be found here:  https://www.squarespace.com/privacy/

CONSENT

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:

·       you have to give us your consent freely, without us putting you under any type of pressure;

·       you have to know what you are consenting to – so we'll make sure we give you enough information;

·       you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and

·       you need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way.

We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the consulting engineering services we provide as long as you do not actively opt-out from these communications.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials.

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

HOW TO CONTACT US

How you can get in touch with us:

to access, amend or take back the personal data that you have given to us;

if you suspect any misuse or loss of or unauthorised access to your personal information;

to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);

with any comments or suggestions concerning this Privacy Policy

You can write to us at the following address:

CS Consulting, 1st Floor, 19-22 Dame Street, Dublin 2.

Alternatively, you can send an email to: it@csconsulting.ie

How you can get in touch with us to update your marketing preferences:

Alternatively you can email us at: info@csconsulting.ie or by clicking the unsubscribe link in any marketing e-mail we send to you. 

HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

Details of your local supervisory authority in Ireland: The Office of the Data Protection Commissioner. You can contact them in the following ways:

Phone: (+353;) 57 8684800 or (+353) (0)761 104 80 or 1890 252 231 (Local)

Email: info@dataprotection.ie

Online feedback form: www.dataprotection.ie

Post:

·       Dublin Office: 21 Fitzwilliam Square, Dublin 2, D02 RD28, Ireland

·        Portarlington Office (Postal Address): Canal House, Station Road, Portarlington, R32 AP23, County Laois, Ireland.

Fax: (+353) 57 868 4757

GLOSSARY

Clients - while it speaks for itself, this category covers our customers, clients, and others to whom CS Consulting provides services in the course of its business.

Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.

General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

Project Partners – includes Design Team members, Contractors and other parties working mutually on a Clients project alongside CS Consulting.

Staff – includes employees and interns engaged directly in the business of CS Consulting (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to CS Consulting (even though they are not classed as employees). Likewise, independent contractors and consultants performing services for CS Consulting fall within the definition of a 'Supplier' for the purposes of this Privacy Policy.

Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to CS Consulting. In certain circumstances CS Consulting will sub-contract the services it provides to Clients to third party suppliers who perform services on CS Consultings behalf. We may also engage third party suppliers on behalf of our Client which are also covered under “Suppliers”.

Website Users - any individual who accesses any of the CS Consulting websites.