Gas Networks Ireland Privacy Notice
The site www.carbonmonoxide.ie (the "Site") is produced in the interest of safety by Gas Networks Ireland, on behalf of the Register of Gas Installers of Ireland (RGII), National Standards Authority of Ireland (NSAI), Irish LPG Association (ILPGA) (collectively the "Carbon Monoxide Working Group"). The Carbon Monoxide Working Group has been established as part of the Commission for Energy Regulation's safety framework.
Gas Networks Ireland ("we", "us", "our") is a "Controller" under the General Data Protection Regulation ((EU) 2016/679) ("GDPR") in respect of certain Personal Data you furnish to us. Gas Networks Ireland is part of Ervia. We own, operate, build and maintain the natural gas network in Ireland and connect all customers to the network. Gas Networks Ireland holds both Asset Owner and Asset Operator Licences for the Natural Gas Transmission and Distribution networks and is regulated by the Commission for Regulation of Utilities. Gas Networks Ireland has its registered office at Gas Networks Ireland Headquarters, Gasworks Road, Cork. Gas Networks Ireland has produced this Site and operates the Site on behalf of the Carbon Monoxide Working Group
This Privacy Notice is intended to help you understand what Personal Data Gas Networks Ireland collect about you, why we collect it, and what we do with it.
1. What is Personal Data?
"Personal Data" is any information relating to an identified or identifiable natural person ("Data Subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier such as a user IP addresses or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Special Categories of Personal Data;
"Special Categories of Personal Data" is any Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; genetic data or biometric data and data concerning health or sex life and sexual orientation.
2. Personal Data Collected and Processed
We collect and process Personal Data relating to you in connection with our relationship with you. This Personal Data includes:
your name and contact details, including your address, phone number and email address;
- customer service records, including surveys and complaints;
- details related to your connection, including service requests, work orders and details;
- your account record, including meter readings, billing, payments and collections;
- health and safety records in the event of a health and safety risk, an accident, an incident or a hazard;
- any Freedom of Information or Subject Access Request details;
- landowner records where relevant to a right exercised by Gas Networks Ireland, e.g. a right of way; and
- any other Personal Data relating to you that you provide to us or that we generate about you in connection with our relationship with you, including records of any consent you have given and your use of the Site.
3. Technical Data Collected
When you visit the Site, we gather statistical and other analytical information collected on an aggregate basis of all visitors to the Site. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of the Site.
4. Sources of Personal Data
We collect data from you and from other entities within the Ervia group.
5. Purposes for which we hold your Personal Data
The Personal Data that is referred to above will be processed for the purposes of:
- performing our functions as a public authority, including operating and maintaining the gas transmission and distribution systems;
- complying with our legal obligations;
- providing customer service to you and contacting you if required to respond to any communications you might send to us;
- establishing, exercising or defending legal claims;
- sending you promotional and marketing materials; and
- improving the services we provide to you.
Our legal basis for collecting and using this information in accordance with the provisions of this Data Privacy Notice is:
that it is necessary for the performance of a contract with you;
- that it is necessary for the performance of tasks that we carry out in the public interest or in the exercise of official authority vested in us by law (including the Energy Act 2016 and the Safety, Health and Welfare at Work Act 2005);
- that it is necessary for compliance with a legal obligation that applies to us; or
- that you have provided consent to us for the use of your Personal Data.
Where you have provided consent for the use of your Personal Data, you can withdraw it at any time by informing firstname.lastname@example.org, however, this will not affect the lawfulness of processing which was carried out based on your consent prior to its withdrawal.
6. Disclosure of your Personal Data to third parties
We disclose your Personal Data to various recipients in connection with the above purposes, including:
- to third parties who we engage to provide services to us, such as outsourced service providers, IT service providers, professional advisers and auditors;
- to any other members of the Ervia group of which Gas Networks Ireland is part, for any of the purposes set out in this Privacy Notice;
- to other public authorities and bodies where required or permitted by law, such as An Garda Síochána or other law enforcement authorities for the purposes of prevention, investigation or detection of crime; and
- to comply with any applicable law or regulation, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
7. Transfers of your Personal Data outside of the European Union
In order for the purposes outlined above and particularly for technical support, from time to time, we might have to transfer your Personal Data outside the European Economic Area (EEA) to a country that has not been confirmed by the European Commission to provide an adequate level of protection for Personal Data.
If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a data processing agreement in respect of the transfer which contains the 'standard contractual clauses' approved by the European Commission, or in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework (or any replacement framework). Further details of the measures that we have taken in this regard are available on request from email@example.com.
What this means is that, where we do not have the assurance of the destination for your data having been subject to a review by the European Commission, we will use other approved controls to ensure we can protect your data adequately and to ensure that those third parties who may process your personal data on our behalf meet the highest standards of privacy practices and comply with applicable data protection law.
8. How we secure your Personal Data
Where you communicate with us via the Site, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet. No data transmission over the internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
9. Your Rights
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your Personal Data:
- the right to access your Personal Data;
- the right to request the rectification and/or erasure of your Personal Data in certain circumstances;
- the right to restrict the use of your Personal Data in certain circumstances;
- the right to object to the processing of your Personal Data;
- the right to be forgotten in certain circumstances; and
- the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller, in certain circumstances.
10. How you can exercise your rights
In order to execute any of the rights set out above, please contact us at firstname.lastname@example.org.
11. How long we retain your Personal Data
We will not hold your Personal Data for longer than is necessary. We retain your Personal Data for as long as we need it for the purposes described in this Privacy Notice (including but not limited to section 3 (Disclosure of your Personal Data to third parties)), or to comply with any applicable statutory requirement.
12. Changes to this Privacy Notice and our Policies
We reserve the right to make changes to this Privacy Notice at any time without prior consultation. Any changes to this Privacy Notice will be posted on the Site so that you are always aware of what Personal Data we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail.
13. Questions and Complaints
If you have any questions regarding this Privacy Notice, you can contact us using the information below:
Data Protection Officer
Gas Networks Ireland
24-26 Talbot Street
You have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie/en/contact/how-contact-us).