This document outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.
Who we are and how to contact us
Data protection officer
1 Information we collect and how we use it
We collect and use your personal information for a variety of reasons including:
If you register, purchase or subscribe to one of our Services
- To create an account with us: To become a subscriber to The Irish Times or to purchase or subscribe to one of our other Services, you will need to create an account with us. We will use your personal information to carry out our obligations arising from any contract you as our customer have entered into with us, including sending important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service. We may notify you by phone, post, email, SMS text or through other digital media depending on the content of the notification and your preferred contact mechanism.
We will also use your personal information to provide you welcome emails to help you get the most out of your subscription, subscriber-only content (e.g. specially selected articles and subscriber-only newsletters) and subscriber rewards which may include competitions, events and offers that are available exclusively to our subscribers.
If you cancel your subscription with us, we may use your personal information for direct marketing. We will only do so with your consent. We will generally send you direct marketing by email. We will use your information for a reasonable period of time, not exceeding five months, after your relationship with us has ended. Specifically, we will send you a short series of emails to remind you of the benefits of a subscription with us. You have the right to unsubscribe from receiving such communications from us by following the unsubscribe instructions included at the end of each email communication.
- To pay for the Services you have requested from us: We will collect your payment information to pay for any Services you have requested from us. Credit and debit card information is processed directly by PCI-compliant payment providers who perform payment services on our behalf. Occasionally, our employees receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately.
- To facilitate live chat sessions: We provide “Live Chat” sessions on our website to help understand the subscriptions we offer. We use this information to respond to your enquiry. You can, if you wish, request that we send a copy of the transcript of the chat to the email address you have provided. Live-chat correspondence is maintained by us for verification purposes and is processed to take the necessary steps at your request prior to entering into a subscription contract with us.
- To facilitate registration through social networks: We may collect your publically available social media profile details including your name and email address when you sign up for one of our services through a social media account. We may use these details for the purposes of our registration process in order to enter into a contract with you. We may also automatically import your profile photo and membership status of Facebook, LinkedIn and Twitter if you choose to make these details public. Where we do, we do so in pursuit of our legitimate interest in understanding the demographics of our customers and readers.
- To place an advertisement: We may process your personal information if you opt to place an advertisement. We only process this information to deliver the advertising service you have requested as per the terms and conditions you accept.
To deliver marketing, promotions and to conduct research
- To receive marketing communications: We may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided – we will only do so with your consent. We have an interest in making sure our marketing is relevant to you, so we may process your information to send you marketing communications tailored to your interests. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication.
- For competition and promotional purposes: We regularly run competitions or similar promotions. If you choose to enter a competition or promotion, we will use your personal information to administer these promotions and as per the terms and conditions you accept when you enter. In some cases, your competition entry may be shared with the promoter and this will be specified when you enter. If you win a competition, your contact information will be used to notify you as the winner and to award the relevant prize. We will publish your name on our website and indicate the prize you have won.
- To participate in a survey or poll: We conduct surveys and polls that we use to produce original research from our readers. Your participation is entirely voluntary. You may consent to The Irish Times contacting you at the email address provided to participate in this research. We do not track individuals but look at the information in the aggregate. Any opinion you express, therefore, is anonymous. From time to time, upon completing a survey or poll, we may ask for your email address for competition, promotional or gifting purposes. Participation is entirely voluntary and this information is processed and stored separately from the information you provide us for the survey or poll. Where you provide this information to us, it will be processed only to administer the competition or promotion.
To deliver our content to you
- To provide you with an email newsletter: We offer a number of email newsletters to non-subscribers. We will only send you these newsletters with your explicit consent. We collect and use your information to send you the newsletter(s) you have requested and in some cases to personalise the email we send. You can opt-out at any time by unsubscribing at the bottom of each email newsletter communication.
- To join our ‘Irish Times Abroad Network’: You may voluntarily opt to join our Irish Times Abroad Network. This, is a home for Irish-connected people around the world, with first-person Generation Emigration stories, news, interviews, features and opinion by and about the Irish overseas. By joining the Abroad Network, you consent to receive a newsletter by email with the best stories from The Irish Times Abroad. This allows our overseas audience to keep in touch. You may at any time choose to no longer participate in the Abroad Network by following the unsubscribe instructions included at the end of each email communication.
- To join our ‘Student Hub’: The Irish Times provides digital subscriptions to all qualifying third-level students through our Student Hub network. We process the information you provide to deliver the requested subscription services to you. We also process your information in accordance with our legitimate interests which are to verify student credentials, to assess the eligibility for a free subscription and to understand the demographics of our customers and readers. As part of our ‘Student Hub’ network, you may further consent to receive a weekly newsletter with the latest student news & tips.
- To share our content: We provide tools that enable users of our services to share or forward our content to a nominated email address. If someone else shares our content with you, we may temporarily collect your email address for the purpose of sharing the requested content. We will only use this information to fulfil the sharing request and this contact information is not retained by us. By providing us with your email address, the third party that initiates the sharing request indicates they have your consent to share our content with you.
- To provide an alert service: The Irish Times offers a number of email alert services. With your consent, we will process your personal details for the purpose of sending you the alert service you have requested. If you prefer not to receive these alerts, you can opt out at any time by unsubscribing at the bottom of each email communication or logging into the relevant alert service and disabling the alert.
To understand how you use our services
- To track how you gain access to or read our content: We collect information relating to your use of our services to track how you gain access to or read our content. We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
When you sign up for or subscribe to one of our services, we will track and aggregate non-personal information previously collected about you through our services with the personal information provided when you register or subscribe.Where we use any cookies or similar technology to collect any data about you we will only collect this data with your consent, which you can withdraw at any time. If we link other data with your personal information we will treat that linked data as personal information for as long as it remains combined. We use this information to evaluate your personal preferences and interests, which under the GDPR may constitute as customer profiling. We do so in pursuit of our legitimate interests which are: To research and improve The Irish Times’ products, services, and customer communications To understand which content you find useful or interesting To develop and maintain relationships with our customers and readers To deliver relevant content to our readers To understand the demographics of our customers and readers
- We log technical information that your browser sends us including: the internet protocol (IP) address; browser type and version; time-zone setting; access time; browser plug-in types and versions; operating system; and platform and device type
- We log usage information about the use of our website and services, including: a history of the pages viewed and other actions taken, including the full Uniform Resource Locators (URL) clickstream to, through and from our site; articles, content and products viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and any phone number used to call our customer service number
- Technical information, including: the type of mobile device used; unique mobile identifies, such as the devices IMEI number; mobile network information; the mobile operating system; the type of mobile browser used; and the time-zone setting
- Details of our mobile applications used including but not limited to: traffic data; location data; weblogs; and other communication data and the resources accessed
- Some of our location-enabled services require your personal GPS location data for the feature to work. If you wish to use a particular feature, you will be asked to specifically consent to your data being used for this purpose. This consent can by withdrawn at any time.
- To measure the effectiveness of our email communications: We use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.
To support our advertising services
Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site or other sites. This type of behavioural advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide.
The third-party vendors (such as advertising networks) use third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. When you visit our Site, your browser redirects to the third-party vendor and information is transmitted from your browser to this third-party vendor.
To deliver recruitment services to you
- To use our recruitment services: We may invite you to submit your personal information by applying for a job or becoming a candidate on our “RecruitIreland.com” website. Your personal information is used by us to provide our recruitment services to you. Where you consent, we will provide information on job opportunities and match your profile with suitable job vacancies. If you apply for a job posting, or if you explicitly enable recruiters to see your profile and CV in your candidate account settings, the personal information you provide to us (including sensitive information) may be shared with third-party recruiters and clients. In this circumstance, these third parties may contact you for the purposes of processing your job application and use your personal information to assess your suitability as a candidate. By sending us your personal information or by making a job application on our site, you agree to our recruitment terms and conditions. You may delete your candidate profile entirely if you wish by logging into your account and selecting the delete account option.
- To apply for a job with us: If you apply for a job within The Irish Times Group, you may provide us with certain personal information about yourself. We will use this information for the purpose of processing and responding to your application, to assess your suitability as a potential candidate and for current and future career opportunities.
To attend one of our events
We host many events throughout the year. These include but are not limited to breakfast briefings, live content events, live lectures, podcast recordings, training, conferences and seminars.
If you register for one of our events, we will collect personal information from you. We will use your information to register for the event, process your payment and provide you with information and services associated with the event. In some cases, we make audio or video recordings of these events and we may record information about you as a consequence. We will always inform you in advance if the event is being recorded so that you can choose not to participate if wish. Registration for our events is voluntary. Once you register, however, we process your personal information as per the terms and conditions of that specific event and on the lawful processing ground of contract.
- To monitor our premises with CCTV camera surveillance: Our premises at 24-28 Tara Street, Dublin 2, are monitored by CCTV security cameras. We may record personal information about you if visit our offices or walk in close proximity to our business premises. CCTV notices are on display outside our building to inform you of our practices and to give you advance notice of any recording. We are processing CCTV video surveillance data generally without your consent in pursuit of our legitimate interests to protect the rights, property and safety of The Irish Times DAC and the rights, property and safety of our employees or others.
The CCTV surveillance information we collect may be shared with An Garda Síochána or other third parties where we are required to do so by law.
- To correspond with you: If you correspond with us, we will use your contact information to respond to your enquiry. We process this information in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.
- To manage our everyday business needs: We may use your personal information to manage our every business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention in our legitimate interest. Our legitimate interest is the effective management of our business.
- To verify your identity: To exercise your data rights, we may need to collect additional personal information from you to verify your identity and to process your request.
- When you provide professional services to us: You may provide us with your personal information if you provide professional services to us. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract.
2 Anonymous information we process
We use app push notifications to inform you about breaking news, live event coverage and other top stories. We do not process any personal information and cannot establish the identity of the users who have subscribed to receive these notifications. We may occasionally use push notifications to send you marketing material which may be of interest to you. You may receive these notifications based on your location, operating device and/or interests that are derived from your use of our Services. You can control your push notification and location settings directly on your mobile device. It should be noted that iOS devices operate on the basis of opting-in to push notifications whereas Android devices operate on the basis of opting out.
3 The legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
- To provide you with the subscription, services or products you have requested
- To process your payment information
- To authenticate and verify your account
- To provide customer and technical support
- To administer competitions or similar promotions
- To process live chat information at your request prior to entering into a subscription contract with us
- To provide our recruitment services to you when requested
- To pay for the services you may professional provide to us
- To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service
- To keep you informed of the benefits of your subscription
- To ensure you get the most out of your subscription
- To deliver exclusive content and benefits to our subscribers
With your consent, which can be withdrawn at any time
We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us. You can also contact us at email@example.com and we will be happy to facilitate your request.
To comply with our legal obligations
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including:
- Providing information to an Garda Síochána, the Revenue Commissioners or other Government bodies or agencies when required to do so by law
- If you have exercised one of your data rights, we will retain a copy of all correspondence to demonstrate our compliance with data-protection legislation
- If you have exercised one of your data rights and ask us not to contact you by email at a particular email address, we will need to retain a copy of that email address in order to comply with your no-contact request
- To carry out our statutory audit
Processing based on our legitimate interests
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests. If you wish to do so contact us at firstname.lastname@example.org. Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit.
Where you object to our use of your personal information for our legitimate interests, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so. We will always ensure there is a fair balance between our legitimate interests and your fundamental right and freedoms.
We process personal information for the following legitimate business purposes:
- To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention
- To provide you with a more personalised experience, such as making content recommendations
- To understand which content you find useful or interesting
- To support our advertising services
- To determine the effectiveness of promotional campaigns, email campaigns and advertising
- To research and improve The Irish Times’ products, services, and customer communications
- To ensure content from our site and mobile applications is presented in the most effective manner for you and for your device
- To develop and maintain relationships with our customers and readers
- To better understand and improve the usability, performance, and effectiveness of our Services
- To protect you against fraud and to detect, prevent, and investigate security or technical issues to ensure our Services are secure
- To protect the rights, property and safety of The Irish Times DAC or the rights, property or safety of our employees or others
- To verify student credentials and assess the eligibility for a free subscription
- To understand the demographics of our customers and readers
- To send direct marketing to our subscribers.
4 When and how your information is shared
Within our group
We may share your personal information with any member of our group if the service you have requested is fulfilled by them. For example, where subscriptions are offered as part of a bundle, if the digital access is provided by a member of our group, we will share your personal information to fulfil the services you have requested.
With third parties
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Third-party service providers
We may share your personal information with third-party service providers which perform services and functions at our direction and on our behalfs such as our accountants, IT service providers, printers, payment providers, lawyers, providers of security and administration services and other business advisers.
Third-party service partners
We provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them. These third parties have their own security and privacy policies. You are advised to review these separately.
Third-party data controllers
We may share your personal information with third parties that may receive and process your personal information as a data controller in their own right. In the context of delivering an order or product to your address, we will share your shipping information with our delivery partners who will use it for the purposes of picking up, delivering and tracking your shipment. Our delivery partners may further use this information to plan delivery routes, to optimise and improve transportation operations and to enhance route and network planning tools such as maps, etc. As such, these third parties act as a data controllers in their own right in respect of any shipping information that they hold. You can obtain more information about the delivery partners we use, how they process and treat your personal information and how to exercise your data rights by contacting us at email@example.com
We disclose non-personally identifiable anonymous information to third-party advertisers to help them reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served. These advertising parties may combine the information we send with other information that you’ve provided to them or that they’ve collected from your use of their services.
We may share your personal data with a third-party auditing organisation (ABC) in accordance with our legitimate interests to verify aggregated statistics about circulation and usage of our products or to review our policies, processes and procedures for compliance with relevant standards.
Third-party recruiters and clients
If you apply for a job posting on our “RecruitIreland.com” website, or if you explicitly enable recruiters to see your profile and CV in your candidate account settings, the personal information you provide to us (including sensitive information) may be shared with third-party recruiters and clients.
Social networking sites
Where we display social media plug ins on our site this may allow social media operators to set cookies and other technologies when you visit our site. We are not responsible for how social media operators use your data and you should review their privacy policies separately.
5 Data storage and retention
We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.
6 International transfers
We may transfer your personal data outside the European Economic Area (EEA). These countries do not always afford an equivalent level of privacy protection and in such circumstances, we take specific steps, in accordance with data protection law to protect your personal information. In particular, for transfers of personal data outside the EEA we rely either on an adequacy decision by the European Commission or on contractual protection approved by the European Commission.
7 Your data rights
You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to:
- Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format
- Rectify any inaccurate personal information we hold about you
- Withdraw your consent where we have relied upon your consent to process your information
- Erase the personal information we hold about you subject to certain exceptions
- If technically feasible, have your personal information transmitted to another data controller in a machine readable format at your request
- Restrict processing of your personal information in certain circumstances
- Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
- Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
- Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please contact us at firstname.lastname@example.org. We will take measures to verify your identify which we will do by reference to copies of acceptable identification documentation supplied by you.
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
8 Consequences of not providing information
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
9 Processing for journalistic purposes
As a news publishing organisation, The Irish Times processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes.
This processing is exempt from compliance with certain obligations of the GDPR.
- We may process your personal information for journalist purposes where you submit content to be published online and in our printed publications
- Where you have voluntarily contributed your experience to us and we publish this information
- If we publish a letter you have written to the Editor
- If you participate in one of our discussion forums
It is important to understand that certain rights which you have in relation to your personal information may not apply where that data is processed for journalistic purposes.