1) Who we are:
When we talk about ‘Cooley Healthcare’, or ‘we’ or ‘us’, we are talking about Cooley Healthcare Ltd with registered offices at 7a Culmore Park, Palmerstown, Dublin 20 and its subsidiaries and affiliates. Cooley Healthcare Ltd is a provider of Disability Bathrooms, Stairlifts, Ramps & Home Adaptations. For more information, visit www.cooleyhealthcare.ie
2) What is Personal Data:
When we talk about personal data we are talking about any information that relates to you.
Personal data covers items such as your name, address, email address, mobile number, date of birth and Personal Public Service Number (‘PPSN’). Personal data includes special categories of data concerning your health.
3) How we collect your personal data:
We ask you directly for the personal data that we require to deliver our products and services to you.
In addition, we gather your personal data through:
Our interactions with you, for example via email or postal correspondence and telephone calls.
Your use of our products and services, including through the transactions you make and the technology you use, such as our website.
In addition, we receive personal data from third parties such as Occupational Therapists, local councils, or government agencies.
Please note that if you provide us with another person’s personal data (e.g. when applying for a home adaptation for a relative) you need to obtain their agreement to do so and provide them with this data protection notice.
We may sometimes process your personal data even if you are not our customer, for example if you are the main contact for a job or assisting another person to avail of our services. In such cases, we will process your personal data in accordance with this notice.
4) How we use your personal data:
We collect and use (or “process”) your personal data for a number of different reasons. Any time we process your personal data, we must have a legal basis to do so. The various ways we process your personal data and the legal bases we rely on are outlined below:
4.1) For the performance of our contract with you.We process your personal data in order to provide the products or services that we have agreed with you. This includes processing to:
• Set up initial assessments and follow up appointments.
• Help us provide you with quotations.
• Assist you with grant applications to your relevant local authority.
• Contact you regarding the status of your application.
• Assist you with VAT reclaims from Revenue.
• Provide services and home adaptations as agreed with you.
• Manage your details for invoicing and payment purposes.
• We may use your personal data for marketing purposes.
4.2) Where you provide your consent.
We may, at times, request your consent to process your personal data for specific reasons, such as:
• Where you have appointed a third party to represent you and deal with us on your behalf (for example in a relative or friend) and we need to share your personal data with them.
• Where we need to process special categories of data (for example, health related data)
Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time (see sections 11 and 12 below for more details).
4.3) For compliance with our legal obligations.
We will use your personal data to the extent necessary to comply with applicable legal and regulatory obligations. We will process your personal data on this basis, including in the circumstances described below:
To fulfil our tax and regulatory reporting obligations, for example:
• To fulfil our tax and VAT obligations to Revenue.
• To comply with legal requirements of the Energy (Miscellaneous Provision) Act 2006.
4.4) Where necessary, in our legitimate interests.
We process your personal data where it is in our legitimate interests as a business. When we process your personal data in our own interests, we will seek to maintain a balance between our interests and your rights and freedoms. We will process your personal data on this basis:
For day to day operational and business purposes to ensure we conduct our business in a responsible and commercially prudent manner including for:
• Management, financial and regulatory reporting.
• Internal administration and planning, including statistical analysis and research, strategic planning and audit purposes.
• Management of Cooley Healthcare Ltd legal and compliance affairs.
• Management of network and information security including testing our websites and other systems.
• Maintenance of business continuity, disaster recovery and back up arrangements.
• Ensuring the safety of our staff, customers and premises.
• To help us improve our services and systems, and our customers’ experience with us through analysis of personal data generated from your use of our services.
• Quality assurance of our sales and services including the review of our application processes, calls, online, email and face to face interactions to identify training and process improvements.
• Analysis of complaints, errors and feedback.
• To understand and assess our customers’ requirements, and to help us continually develop, improve or identify products and offerings for our customers (including to identify products which might be relevant and personalised to you).
• market research at individual, group or industry level.
• Analysis of customer demographics such as gender, age and occupation.
• Combining your personal data with third party data such as economic or research data.
When we process your personal data in connection with the above activities, we do this using grouped customer information. We do not share information that can identify you as a customer, such as your name, or account details. We will however use your personal data when contacting you for customer or market research.
5) Implications of not providing personal data:
Please note that, in some cases, if you do not provide the personal data we need, or help us keep your data up-to-date, we may not be able to continue to operate your account and/or provide certain products and services to you.
6) Who we share your personal data with:
We will share your data, when necessary, within Cooley Healthcare Ltd. In addition, we will share your personal data with third parties in the course of providing our services to you, and where required for business, legal and regulatory purposes, including in the following circumstances:
• Where such third parties provide a service to us, for example: suppliers and manufacturers of goods necessary to complete our housing adaptations, stairlifts etc.
• Couriers and transport companies for delivery of goods.
• Legal advisors.
• As required by law, to statutory, regulatory and enforcement authorities, which includes Irish Government or statutory bodies, such as Revenue and local authorities.
• In any case where we share your personal data with a third party data controller, the use by that third party of your personal data will be subject to that third party’s own data protection policies.
7) How long we keep your personal data:
We will retain your personal data for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes, including, if relevant, to deal with any claim or dispute that might arise in connection with the services you receive from us.
In general, the period for which we retain your personal data will be determined having regard to any statutory obligations imposed on us by law. For example, we are required under the Consumer Protection Code to retain certain information for 5 years after the end of our relationship with you.
We will retain contact information such as name, address, contact details etc for a period of 5 years. We keep copies of your Occupational Therapist Report, PPS Number & Images of the property for a period of 2 years from the completion date of job.
We may, in certain cases, retain your information for longer periods, particularly where required by order of a court, or in the context of an investigation by regulatory or law enforcement agencies. This is to ensure that we will be able to produce records as evidence, if required.
8) Keeping your personal data safe and secure:
We have implemented technical and organisational security measures to protect your personal data when it is being processed and stored. These include:
• Controlling access to help prevent unauthorised viewing or alteration of your personal data.
• Minimising the data sets that we use to protect our customers when we process your personal data for the various activities outlined above.
• Using encryption mechanisms, where appropriate.
• Ensuring the proper disposal and shredding of personal information in an efficient and timely manner once there is no longer a need for retention.
• Ensuring that all personal data is securely stored.
9) Your Rights in relation to your personal data:
Under data protection law, you have a number of rights in relation to your personal data. You have the right to:
Access: to know if we process your personal data, access your personal data and receive a copy of your personal data that we process in paper or (if you request) electronic form.
Rectification: to have your data rectified where it is shown to be inaccurate or out of date.
Erasure: to have your data erased in certain circumstances (for example if you withdraw your consent to the processing of such data, provided that there is no legal requirement for us to retain it).
Restriction: to request a restriction on our processing of your personal data, for example, where you believe that:
• the processing is based on inaccurate data, or
• we are not processing your personal data in a lawful manner
Objection: to object to processing activities in our legitimate interests, including the right to object to profiling on this basis (such as the activities described in section 4.4 above) where such activities impact on your rights and freedoms as an individual and we have no compelling interests outweighing your rights and freedoms.
Portability: to receive a copy of your personal data in a portable format in circumstances where you have provided your data on the basis of your consent, or for the provision of our services and which is generated through the use of that service. You can also request that a copy of this data-set is sent to another company or other service provider. Please note however that where you have asked us to send your personal data to a third party, we are not responsible for their use of your personal data. We would recommend that you read any data protection notice that such third party provides to you.
Withdraw your consent: to withdraw any consent that you have provided for specific processing activities. Please note that if you withdraw your consent to our processing of your personal data for any specific activity, this will not affect the validity of any processing carried out on the basis of your consent prior to such withdrawal.
PLEASE NOTE: The above rights are subject to exemptions and may not apply in all circumstances. If you object to, or ask us to restrict, our processing of your personal data, or ask us to delete your data, we may have to suspend the provision of our products and services to you.
10) How to exercise your rights:
In Cooley Healthcare Ltd we are dedicated to helping you to exercise your rights under data protection law.
You can contact us directly:
By post: Data Subject Rights, Cooley Healthcare Ltd, 7A culmore Park, Palmerstown, Dublin 20.
By telephone: 01-5470611
By Email: email@example.com please note we do not recommend sending large amounts of personal data through email.
In exercising your rights we will need to verify your identity to help ensure that no one else seeks to use your rights to access or interfere with your personal data.
If you wish to exercise your data protection rights, please contact our office using the contact details set out in 10 above.
If you have a complaint, please provide as much detail as you can regarding your issue so that it can be effectively addressed. We would however caution you against including large amounts of personal data in an email, as email is an inherently insecure communication and may be viewed in transit by third parties.
You also have the right to make a complaint to the Data Protection Commission where you feel that your rights have not been appropriately served by us (www.dataprotection.ie). You can contact the Data Protection Commission by calling +353 (0)761 104 800 or LoCall 1890 25 22 31, emailing info@ dataprotection.ie or writing to Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23.
12) Changes to this Data Protection Notice:
We will make changes to this notice from time to time, particularly when we change how we use your personal data and change our technology and products. To request an up-to-date version, you can have it emailed or posted to you, call us on 01-5470611 or write to: Cooley Healthcare Ltd, 7a Culmore Park, Palmerstown, Dublin 20.