MUNSTER CAR PARK SERVICES LIMITED DATA PROTECTION POLICY
INTRODUCTION
This policy applies to Munster Car Park Services Limited and the terms ‘MCPS’ and ‘we’ or ‘our’ or ‘us’ are used throughout to refer to that company.
In order to operate its business, MCPS needs to collect and use certain types of information about staff, clients and other individuals with whom it comes into contact.
The personal information must be gathered and dealt with properly no matter how it is collected, recorded and used – whether on paper, in a computer, or recorded on other material. We ensure that MCPS Data Protection Policy complies with the EU General Data Protection Regulation (GDPR) and in the Republic of Ireland (currently) the Data Protection Acts 1988 to 2018 and we will refer to these under the name of ‘Data Protection Legislation’.
We make sure that MCPS treats personal information lawfully and correctly as it is very important to the success of our operations.
Therefore, MCPS will:
- process personal information only where this is strictly necessary for legitimate organisational purposes
- collect only the minimum personal information required for these purposes and not process excessive amounts of personal information
- provide clear information to individuals about how their personal information will be used and who will be using the information they provide
- only process relevant and adequate personal information
- process personal information fairly and lawfully
- keep all personal information secure
- maintain an inventory of the categories of personal information that is processed
- ensure personal information is kept accurate and up to date
- retain personal information only for as long as is necessary for legal or regulatory reasons or, for legitimate organisational purposes
- respect individuals’ rights in relation to their personal information as defined in the Data Protection Legislation
- Not transferring personal information outside the EU Member States
- Only apply exemptions permitted by the Data Protection Legislation
In this notice, we provide you with the necessary information regarding your rights and our obligations, and we explain to you how, why and when we process your personal data.
INFORMATION THAT WE COLLECT
MCPS processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services and products. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from you includes;
- Name
- Address
- E-mail address
- Phone Number (Landline/Mobile)
- Vehicle Registration Number
- Vehicle’s make
- Bank Details/Payment Card Details
- Passport/ Driving License
- Proof of Address
- DOB (if supplied)
The ways we collect your personal data are;
- Web contact forms
- General Client/Customer Query Form
- Permit Application Form
- Parking Contract
- Phone call/e-mail to our Customer Support team
- Enforcement Receipt
- Appeals Application
- Employment CV and Records
- Supplier Set-up Forms
- Client Agreement
- Client/Customer Set-up Forms
PERSONAL DATA – HOW WE USE IT
MCPS takes your privacy very seriously and with responsibility, and will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
THE PURPOSES AND REASONS FOR PROCESSING YOUR PERSONAL DATA
- Parking Enforcement – The car parks, parking areas, and sites for which MCPS is contracted to manage them are random patrolled by our Parking Enforcement Officers or directly by our clients and their patrol personnel. All patrol personnel are trained to the highest standard. When the Parking Enforcement Officer undertake an enforcement action, as part of the process he will collect images of your vehicle, your vehicle registration number, make/model and colour of your vehicle. Each customer is provided with a Clamping Notice contains unique number in order to challenge and enforcement action online. Furthermore, our Parking Enforcement Officer might record the clamping procedure by Van CCTV and/or by Body Camera to avoid any disputes in the Appeal process
- Appeals – If you decide to appeal an enforcement action, you will be asked to fill out Appeals Form. Following an investigation, if your appeal is declined you can further contest this decision with an independent secondary adjudicator – the National Transport Authority. They will have access to your data relating to the enforcement action, and initial appeal decision
- Permits – We provide parking permits on behalf of our clients. In all instances, we will need to verify your address/license. We can also process permits at the request of the client, who in some instances will provide your details to us in order for us to process your permit
- Monthly Parking Contract – we provide monthly car parking renting in behave of our clients; you’ll be asked for your name, address, your vehicle registration number, your email address to arrange and sign an agreement
- Customer Service – General queries, which include business call back requests, can be made through our website contact form or by calling us directly to the office. This area also includes customer complaints/feedback provided to Car Park Attendants. Information provided is used for the specific purpose of reading, investigating, and answering your query
YOUR RIGHTS
You have the right to access any personal information that MCPS processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible, within one month and free or charge; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the Data Protection Legislation; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
With any request, you can contact us directly from our website or by email to info@mcps-ireland.com, giving in the title DATA PROTECTION
SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. MCPS uses third parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection legislations and any other appropriate confidentiality and security measures
Pay by phone car park: We use Parking Tag to process pay by phone/text parking payments in our sites. The information they process on our behalf is vehicle registration, name, address, contact number, bank card/payment details.
For more information about Parking Tag, please read their Privacy Policy at www.parkingtag.ie, choosing PRIVACY POLICY
ELAVON: We use Elavon to process with the online payment by Credit Cards for enforcement and appeal procedure. The information they process on our behalf is name, email, contact number, vehicle registration, bank card details, proof of identification (where applicable).
For more information about Elavon please visit www.elavon.ie and read their Privacy Pledge
SAFEGUARDING MEASURES
MCPS takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction and provide security measures in place, as restricted access to files, IT authentication, password, ant-virus, locked office cabinets, external hard disc.
TRANSFERS OUTSIDE THE EU
Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. MCPS does not transfer or store any personal data outside the EU.
CONSEQUENCES OF NOT PROVIDING YOUR DATA
You are not obligated to provide your personal information to MCPS, however, as this information is required for us to ensure parking compliance on the privately owned/managed car parks or sites we manage, we will not be able to offer our services without it.
LEGITIMATE INTERESTS
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis to pursue a motorist for unpaid parking charges relating to trespass and breach of contract, and to ensure safety and security and help deter/detect criminal activity.
HOW LONG WE KEEP YOUR DATA
MCPS only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under Irish tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
“Clamping Records” (for Enforcement) are retained for 3 years according to the National Transport Authority requirements and Regulation 18 of Vehicle Clamping and Signage Regulations 2017.
LODGING A COMPLAINT
MCPS only processes your personal information in compliance with this privacy policy and in accordance with the relevant data protection legislation. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Data Protection Commissioners
Website: https://dataprotection.ie
T: +353 57 8684800 / +353 (0)761 104 800 / 1890 252 231
E: info@dataprotection.ie
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