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Data Protection Policy

Introduction

The Muslim Sisters of Éire (MSOÉ) is a voluntary independent organisation of mainly Muslim women living in Ireland, providing a range of support services for the homeless, women and youth and promoting empowerment, social inclusion and diversity.

The purpose of this document is to provide a clear policy statement regarding the Data Protection obligations of MSOÉ. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the General Data protection Regulation (GDPR) 2018, the Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003).


Rationale

MSOÉ must comply with the data protection principles set out in the relevant legislation. This policy applies to all personal data collected, processed and stored by MSOÉ in the course of its activities. MSOÉ makes no distinction between the rights of data subjects, all are treated equally under this policy.


Scope

The policy covers both personal and sensitive personal data held in relation to data subjects by MSOÉ. The policy applies equally to personal data held in manual and automated form.

All personal and sensitive personal data will be treated with equal care by MSOÉ. Both categories will be equally referred-to as personal data in this policy, unless specifically stated otherwise.

This policy should be read in conjunction with the associated GDPR document that outlines the Subject Access Request procedure, Data Retention and Destruction, the Data Retention Periods List and the Data Loss Notification procedure.


The Muslim Sisters of Éire (MSOÉ) as a Data Controller

In the course of its daily organisational activities, MSOÉ acquires, processes and stores personal data in relation to:

  • Events seminars: Speakers and guests of MSOÉ
  • Third party service providers engaged by MSOÉ

In accordance with the Irish data protection legislation, this data must be acquired and managed fairly. Not all MSOÉ voluntary administrators will be expected to be experts in data protection legislation. However, MSOÉ is committed to ensuring that its voluntary administrators have sufficient awareness of the legislation in order to be able to anticipate and identify a data protection issue, should one arise. In such circumstances, administrators must ensure that the Data Protection Officer is informed, and in order that appropriate corrective action is taken.

Due to the nature of the services provided by MSOÉ, there is regular and active exchange of personal data between MSOÉ and its Data Subjects. In addition, MSOÉ exchanges personal data with Data Processors on the Data Subjects’ behalf.

This is consistent with MSOÉ’s obligations under the terms of its contract with its Data Processors.

This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a MSOÉ administrator is unsure whether such data can be disclosed.

In general terms, the administrator should consult with the Data Protection Officer to seek clarification.

Subject Access Requests

Any formal, written request by a data subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.

It is intended that by complying with these guidelines, MSOÉ will adhere to best practice regarding the applicable data protection legislation.

Third-Party Processors

In the course of its role as Data Controller, MSOÉ uses a number of data processors to process personal data on its behalf. These data processors include:

  • MailChimp for newsletters and event information.
  • PayPal for donations and events (where appropriate) payment
  • Eventbrite for event bookings
  • Google email and Google Drive for MSOÉ documentation and archive storage.
  • WhatsApp/Viber for committee communication
  • Skype/Zoom/Teams for committee meetings.

The Data Protection Principles

The following key principles are enshrined in the Irish legislation and are fundamental to the MSOÉ’s Data Protection Policy.

In its capacity as Data Controller, MSOÉ ensures that all data shall:

1. ....BE OBTAINED AND PROCESSED FAIRLY AND LAWFULLY.

For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:

  • The identity of the Data Controller (MSOÉ)
  • The purpose(s) for which the data is being collected
  • The person(s) to whom the data may be disclosed by the Data Controller
  • Any other information that is necessary so that the processing may be fair.

MSOÉ will meet this obligation in the following way.

  • Where possible, the informed consent of the data subject will be sought before their data is processed;
  • Where it is not possible to seek consent, MSOÉ will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
  • Where MSOÉ intends to record activity on video, a Fair Processing Notice will be posted in full view;
  • Processing of the personal data will be carried out only as part of MSOÉ’s lawful activities, and MSOÉ will safeguard the rights and freedoms of the data subject;
  • The data subject’s data will not be disclosed to a third party other than to a party contracted to MSOÉ and operating on its behalf.

2. .... BE OBTAINED ONLY FOR ONE OR MORE SPECIFIED, LEGITIMATE PURPOSES.

The MSOÉ will obtain data for purposes which are specific, lawful and clearly stated. A data subject will have the right to question the purpose(s) for which MSOÉ holds their data, and MSOÉ will be able to clearly state that purpose or purposes.

3. ..... NOT BE FURTHER PROCESSED IN A MANNER INCOMPATIBLE WITH THE SPECIFIED PURPOSE(S).

Any use of the data by MSOÉ will be compatible with the purposes for which the data was acquired.

4. .... BE KEPT SAFE AND SECURE.

MSOÉ will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by MSOÉ in its capacity as Data Controller.

Access to and management of members’ records is limited to those administrators / committee members who have appropriate authorisation and password access.

5. ... BE KEPT ACCURATE, COMPLETE AND UP-TO-DATE WHERE NECESSARY.

The MSOÉ will:

  • ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
  • conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. MSOÉ conducts a review of sample data every year to ensure accuracy.
  • conduct regular assessments in order to establish the need to keep certain personal data.

6. ... BE ADEQUATE, RELEVANT AND NOT EXCESSIVE IN RELATION TO THE PURPOSE(S) FOR WHICH THE DATA WERE COLLECTED AND PROCESSED.

MSOÉ will ensure that the data it processes in relation to data subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.

7. ... NOT BE KEPT FOR LONGER THAN IS NECESSARY TO SATISFY THE SPECIFIED PURPOSE(S).

MSOÉ has identified the data retention requirements for each type of data, in both a manual and automated format.

Once the respective retention period has elapsed, MSOÉ undertakes to destroy, erase or otherwise put this data beyond use.

8. ... BE MANAGED AND STORED IN SUCH A MANNER THAT, IN THE EVENT A DATA SUBJECT SUBMITS A VALID SUBJECT ACCESS REQUEST SEEKING A COPY OF THEIR PERSONAL DATA, THIS DATA CAN BE READILY RETRIEVED AND PROVIDED TO THEM.

MSOÉ has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.


Data Subject Access Requests

As part of the day-to-day operation of the organisation, MSOÉ’s administrators engage in active and regular exchanges of information with data subjects. Where a formal request is submitted by a data subject in relation to the data held by MSOÉ, such a request gives rise to access rights in favour of the Data Subject.

There are specific timelines within which MSOÉ must respond to the data subject, depending on the nature and extent of the request.

MSOÉ’s administrators will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request.


Implementation

As a data controller, MSOÉ ensures that any entity which processes personal data on its behalf (a data processor) does so in a manner compliant with the data protection legislation.

Failure of MSOÉ’s administrators to process personal data in compliance with this policy will result in changes to the administration of MSOÉ.

September 2022


DEFINITIONS

For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.

Data

This includes both automated and manual data.

Automated data means data held on computer, or stored with the intention that it is processed on a computer.

Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.

Personal Data

Information concerning or relating to a living person who is either identified or identifiable (such a person is referred to as a ‘data subject’), in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, MSOÉ refers to the definition issued by the Data Protection Commission and updated from time to time.)

Sensitive Personal Data

A particular category of Personal Data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s sexual orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.

MSOÉ does NOT collect or process sensitive personal data.

Data Controller

A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.

Data Subject

A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.

Data Processor

A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.

Data Protection Officer

A person appointed by MSOÉ to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to data protection queries from members, speakers and guests.

Relevant Filing System

Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.

Sources:

The information on this page was last updated on 30 June 2023.

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