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PRIVACY POLICY

Introduction

Ireland Consultancy Services Ltd (‘we’, ‘our’, ‘us’) values your privacy and is committed to protecting the way in which your personal data is handled. We respect and value the privacy of all our customers and others with whom we interact and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

References to “UK GDPR” are to Regulation (EU) 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

This policy explains how we use your personal data; how it is collected, how it is held, and how it is processed through your use of this website or when you otherwise interact or communicate with us. Please read the policy carefully to understand your rights under the law relating to your personal data.

Ireland Consultancy Services Ltd (registered number 13393783) is the data controller in respect of your personal data.  Ireland Consultancy Services Ltd’s registered office is 1 The Sanctuary, Westminster, London, SW1P 3JT.

If you have any questions about this privacy policy, or how we handle your personal data, please contact our Data Protection Contact by emailing dataprotection@ireland-consultancy.com.

Personal Data Defined

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified.  Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out below.

What personal data do we collect?

We may collect, hold, and process the personal and non-personal data set out below. We do not collect any ‘special category’ or ‘sensitive’ personal data.

We collect:

  • Identity Information – including identity information including name, title, position, company or organisation from our clients, potential clients, suppliers, potential partners or their representatives.

  • Contact Information – including name, postal addresses, email addresses, telephone numbers and any personal data provided in the course of communications from our clients, potential clients, suppliers, potential partners, correspondents, complaints or their representatives.

  • Business Information – including business name, job title, profession, and business contact information from our clients, potential clients, suppliers, or potential partners or their representatives.

  • 3rd Party Information – including contact information, and profile information from 3rd
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Why do we collect that personal data, and what is our lawful basis for processing it?

Our purpose and legal basis for collecting and processing each of the types of personal data outlined above are set out below

  • Business Contact Information including identity, contact and business information – we collect business contact information as a legitimate interest within UK GDPR Article 6(1)(f) of managing our relationships and contacts with clients, potential clients, suppliers, or potential partners and meeting our contractual obligations.

  • Contact Information – we collect contact information and any other personal data you provide in the course of your correspondence or other communications with us, for example when you fill in an online form on this website or when you correspond with us by post, phone, email or otherwise, as a legitimate interest within UK GDPR Article 6(1)(f) of managing our business, responding to enquiries and dealing with any legal claims that we wish to establish, exercise or defend against.

  • Other Information – we collect contact information, and profile information directly from you and from 3rd Parties where and to the extent necessary within UK GDPR Article 6(1)(b) for the performance of our contract with you or to enable us to take steps at your request prior to entering into a contract.

How do we use personal data that we have collected?

Under the Data Protection Legislation, we only use your personal data when we have a lawful basis to do so as detailed below:

  • Where you have given your consent to the processing of your personal data for a particular purpose.

  • Where it is necessary to meet our obligations under (or to enter into) a contract with you.

  • Where we need to comply with a legal or regulatory obligation.

  • Where it is necessary for our legitimate interests, or those of a third party, and your rights do not override these interests. When we rely upon legitimate interests as our legal basis for processing, you have the right to object on grounds relating to your particular circumstances to that processing (including any profiling). If we receive an objection from you then we will carry out, and share with you the results of, a balancing exercise to determine whether we are able to demonstrate compelling legitimate grounds for the processing which either (i) override your interests, rights and freedoms, or (ii) are necessary for the establishment, exercise or defence of legal claims.

 

If you fail to provide certain information to us when requested, we may not be able to enter into a contract with you or perform the contract we have entered into with you or we may be prevented from complying with our legal obligations.

With your consent and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003. To the extent required by law, we will obtain your express opt-in before using your personal data for marketing purposes, and you will always have the opportunity to opt-out.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us by emailing dataprotection@ireland-consultancy.com.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How long do we keep personal data?

  • We will retain your personal data for as long as you continue to be a client and it is necessary to meet our obligations under contract with you or to respond to any claims that might be made under or in respect of that contract during the applicable limitation period.

  • We will retain your personal data for as long as you continue to be a referral partner, or supplier and it is necessary to meet our obligations under any agreement with you.

  • We will retain your personal data where it is necessary for our legitimate business interests until such time as you ask us to stop. Where we can demonstrate a legitimate business interest and continuing purpose for storing your personal data, we will continue to do so until the purpose has been fulfilled. You have the right to object on grounds relating to your particular circumstances to that processing (including any profiling). If we receive an objection from you then we will carry out, and share with you the results of, a balancing exercise to determine whether we are able to demonstrate compelling legitimate grounds for the processing which either (i) override your interests, rights and freedoms, or (ii) are necessary for the establishment, exercise or defence of legal claims.

  • We will retain your personal data where we have a legal obligation to do so and until such time as we have met that legal obligation.

  • We will retain your personal data where you have provided your consent until such time as you ask us to stop or otherwise withdraw your consent.

Where do we store personal data?

We may transfer your personal data outside the UK and European Economic Area (“EEA”) from time to time for the purposes outlined in this policy. For example, we may transfer it to, or it may be accessed by service providers in locations outside of the UK and EEA. The laws of some of these countries may not offer the same standard of protection for personal data as the UK.To the extent required by applicable data protection laws, we take steps to ensure that appropriate safeguards are in place to protect your data when it is transferred internationally. For example:

  • where the transfer is to a country that has been deemed to provide an adequate level of protection for personal data by the UK Secretary of State;

  • by relying on an approved framework such as the EU-US Data Privacy Framework (and the UK Extension to the EU-US Data Privacy Framework); or

  • by entering into appropriate contractual agreements, such as the European Commission’s Standard Contractual Clauses and the Information Commissioner’s Office (ICO)’s UK Addendum, with the recipient of the data.

For further information, please contact us by emailing dataprotection@ireland-consultancy.com.

Data security

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.

  • Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

  • Security measures implemented to secure both the storage and accessibility of data using all reasonable levels of encryption and identity management.

The transmission of information via the internet is not completely secure and while we use all reasonable measures to secure transmission, we cannot guarantee the security of your data.

How will we share your personal data?

We may share your personal data with third parties for the purposes set out above, where is it necessary for us to administer our relationship with you, where we have a legitimate interest in doing so or where otherwise permitted or required by applicable law. This may include sharing your personal data with:

  • Service providers including suppliers of IT infrastructure, software providers and cloud hosting providers.

  • Government bodies, dispute resolution and law enforcement organisations and other regulators, including HMRC, other regulators, the police, the courts and third parties involved in legal proceedings or on the instructions of a court order, legal obligation or government authority.

  • Our advisors, including accountants, auditors, lawyers and other external professional advisors.

  • Third parties in the instance that we sell, transfer, or merge parts of our business or assets. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

We may also share your personal data with a third party where we have your explicit consent to do so. If any of your personal data is shared with a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law. If any personal data is transferred outside of the UK, we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.

Your data protection rights

Under the Data Protection Legislation, you may have certain rights in relation to your personal data. We have set out a list of rights that you may be entitled to below, although please note that they may not always apply in every case and may be subject to certain qualifications or otherwise only apply under certain conditions.

  • Your right of access – you have the right to access the personal data we hold about you.

  • Your right of rectification – you have the right to ask us to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.

  • Your right to be forgotten – you have the right to ask us to have your personal data deleted or otherwise disposed of. Please note that your right to erasure might not apply if we have a continuing purpose and lawful basis for processing your personal data.

  • Your right to restrict processing – you have the right to restrict (i.e. prevent) the processing of your personal data in certain circumstances.

  • Your right to object to processing – you have the right to object to the processing or use of your personal data in certain circumstances.

  • Your right to withdraw consent – you have that the right to withdraw consent at any time if we are relying on your consent as the legal basis for using your personal data however this will not affect the lawfulness of any processing carried out before you withdraw your consent.

  • Your right to be informed on the collection and use of personal data – you have the right to be informed about the collection and use of your personal data. This policy should tell you everything you need to know.

  • Your right to data portability – you have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

We will usually respond to requests within one month. If your request is complex the timescale for a response may be extended by up to two months. Where this is the case, we will advise you of this within one month of receiving your request and explain why we need more time.

You will not have to pay a fee to exercise any of the rights described above. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

If you would like to exercise any of these rights, please contact us in writing at dataprotection@ireland-consultancy.com.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, by emailing dataprotection@ireland-consultancy.com.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

This Privacy Notice was last updated on 18 February 2025.

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ICSL Advisory is the trading name of Ireland Consultancy Services Ltd which is a company incorporated in England and Wales with registered number 13393783 whose registered office is at 1 The Sanctuary, Westminster, London SW1P 3JT.