Data Protection Policy

The ICHRPI (‘the Commission’) collects personal information relating to a variety of data subjects from members of the Commission through to attendees at events, awards applicants, and venue clients throughout the course of its activities. This document delineates the types of personal information that the ICHRPI is likely to collect, the ways in which we collect and process personal information and the rights of data subjects as outlined by General Data Protection Regulation (GDPR, 2018).

What types of personal information is the ICHRPI likely to collect?

The ICHRPI may collect a number of different personal details which are about a person and which, (either on their own or in combination with other information already held about that person) will allow us to identify that person as an individual. Depending on the nature of your relationship with the ICHRPI, these details may include but are not limited to the following:

  • title;
  • first name;
  • surname;
  • telephone number (including home and mobile telephone numbers);
  • email address;
  • social media account ID (including Facebook usernames and Twitter handles);
  • photographs;
  • device information (such as MAC address, IP address, operation system and browser type);
  • location information (such as GPS signal emitted by your mobile device);
  • age;
  • date of birth;
  • gender;
  • information necessary for legal compliance (including details of ethnicity or disability access requirements);
  • educational institute details (such as your school, university or college);
  • marketing preferences (for example where you have opted in to receive our newsletter(s));
  • reason(s) for contacting us (such as requests or enquiries);
  • opinions, preferences, feedback, complaints, comments and /or suggestions (including comments made on our social media pages);
  • online browsing habits, activities and behaviour (i.e. which ICHRPI web pages you have visited and when);
  • visit history, habits, activities and behaviour (i.e when you have attended an event or participated as a committee member);
  • preferences, access needs and dietary requirements;
  • employment related information;

In accordance with GDPR, the ICHRPI endeavours to collect personal information directly from the data subject and will use all such information solely for the predefined purpose(s) for which that information has been provided.

The ICHRPI may collect information from and/or combine any personal information which has been provided by a data subject with other sources when it is lawful to do so and when so doing is likely to enhance the efficiency and relevance of the services that we provide to others. Such sources may include:

  • Google or other internet search engine results or publicly available data from Facebook, Twitter and similar social medial, or other information in the public domain;
  • individuals and/or organisations whom you have confirmed may provide us with personal information;
  • government, tax or law enforcement agencies;
  • other sources (such as when personal information about you is volunteered by a third party, e.g. in a complaint or as part of a group booking).

The ICHRPI may also on occasion collect and use sensitive personal information such as dietary or access and assistance requirements which may indicate a health condition. In all such instances, however, we will ask you to provide the necessary details only. For example, we may need to collect sensitive personal information in order to assist with any access requirements that you may have and to comply with our legal obligations under equality legislation. In other cases, we will collect this type of information only with your clear consent. Should you provide us with any sensitive personal information in any other instance, you will be deemed to have consented to our collection and use of that information.

How does the ICHRPI collect personal information?

The Commission collects personal information through one or more of the following data collection media:

  • websites and micro sites as may be updated and/or extended from time to time, including our main website at www.ichrpi.info and our publisher’s website at www.ichrpi.com;
  • other online/mobile interactive features;
  • official social media pages (which may be provided in partnership with a third party social media platform such as Facebook or Twitter where other privacy policies and practices will apply);
  • communication channels (i.e. telephone, SMS/text message, email and fax).

The personal information collected may be stored in electronic and/or hard copy formats.

How does the ICHRPI use personal information?

The ICHRPI may use personal information for one or more of the following purposes:

  • to enable the data subject to participate in our activities;
  • to respond to, action and/or deal with the data subject’s feedback, requests and enquiries;
  • to ensure that our services are provided in the most effective manner for the data subject and the device that he/she is using;
  • to manage and improve services;
  • to send the data subject communications (including e-mail marketing and fundraising communications) with his/her consent where required;
  • to invite the data subject to provide feedback, assist with surveys and input into consultation exercises;
  • to provide the data subject with administrative information and/or service announcements and updates (including changes to our policies and terms);
  • to ensure our records are accurate and up to date;
  • to comply with our legal obligations and to perform our statutory and public functions and duties;
  • to establish, defend or exercise our legal rights;
  • to comply with orders, requests received from public, regulatory, governmental and judicial bodies;
  • to comply with our legal, regulatory and internal governance obligations (e.g. record retention policies).

Personal information will, however, be processed if and only if one or more of the following conditions has been satisfied:

  • The data subject has provided informed, unambiguous consent for his/her information to be used for a specified purpose(s);
  • It is necessary for the purposes of the ICHRPI’s legitimate interests;
  • The ICHRPI is under a legal obligation to do so (e.g. for equality monitoring, employment or health and safety purposes);
  • It is in the public interest and required in the performance of our official duties.

Does the ICHRPI share personal information with third parties?

Personal information will be made available to Commission office holders who need to see it in order to perform their functions/roles/responsibilities. Information may be held in our membership database in order to consolidate details of a data subject’s dealings with the Commission and may be shared with service providers such as caterers, conference venues and universities hosting ICHRPI conferences. The Commission will, however, ensure that a confidentiality agreement has been put in place with all such parties prior to the disclosure of any personal data.

The ICHRPI shares membership contact details with our third party publisher Taylor & Francis Group, an Informa business, in accordance with our contracts and data processing agreements, in order to assist in providing products and services included in your membership. Taylor & Francis Group may, in turn, share limited data with their commissioned sub-contractors who similarly subject to contractual obligations to keep personal data secure.

How does the ICHRPI keep personal information safe?

The ICHRPI takes all possible steps to protect the security of personal information in accordance with our legal obligations with information being stored either in secure storage or electronically in a secure server and/or databases.

Please note, however, that the ICHRPI cannot guarantee the security of the transmission of personal information via the internet. All personal information should therefore be submitted online if and only if the data subject is accepting of the incumbent security risks.

For how long will the ICHRPI retain personal information?

The Commission will keep personal details on record until we have dealt completely with a data subject’s request, enquiry or contract and during the period of a subject’s membership of the Commission and then for a reasonable period thereafter in accordance with data protection and other legislation.

Should the ICHRPI decide that the retention of personal information is no longer necessary, all such information will be destroyed/deleted in a secure and confidential manner.

What rights do data subjects have in relation to personal information?

Data subjects are entitled to request:

  • If and how their personal data is being collected and processed;
  • A description of the nature of the personal data that is being collected and processed;
  • Copies of, and/or to access their own personal information (see How do I make a subject access request? below);
  • That their personal information be corrected and/or amended where inaccurate or incomplete;
  • That their personal data be deleted or that the ICHRPI stop using their personal data where there is no longer a need to do so;
  • That the ICHRPI stop sending direct marketing or membership information communications.

How do I make a subject access request?

A subject access request should be submitted in writing or email to the ICHRPI Secretary General Dr Mario Di Napoli, Camera dei Deputati, Palazzo Montecitorio, 00186, Rome, Italy, email dinapoli_m@camera.it

The ICHRPI may require an individual to verify his/her identity and/or to provide further details in order to locate the required information but will endeavour to respond to all such enquiries within one calendar month once the necessary information has been provided.

In instances where a subject access request is likely to result in the disclosure of personal information relating to a third party, the ICHRPI will require that third party to consent to the disclosure. If consent from that person cannot be obtained, the subject access request may be denied.

Who should I contact for further information?

For further information relating to the ICHRPI and data protection, please contact the ICHRPI Secretary General Dr Mario Di Napoli at dinapoli_m@camera.it or our Second Secretary and web manager Dr Coleman Dennehy at reviewsper@gmail.com