Privacy and cookies

We at Garda Síochána Ombudsman Commission (“GSOC”, “we”, “our”, “us”) respect your right to privacy. We will comply with our obligations under the EU Regulation 2016/679 (General Data Protection Regulation or “GDPR”) and the Data Protection Act, 2018 and all applicable data protection

The purpose of this Website Privacy Policy is to outline how we deal with any personal data that you provide to us while visiting this website. GSOC is a Data Controller for personal information provided by you on our website. If you have any queries in relation our use of your data you may contact our Data Protection Officer at dataprotection@gsoc.ie. If you are not happy with this Website Privacy Policy, you should not use this website.

By visiting this website, you are accepting the terms of this Website Privacy Policy.

Any external links to other websites are clearly identifiable as such and GSOC is not responsible for the content (or the privacy policies) of those other websites.

We retain two types of information:

“Personal Data”

This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, user IP addresses (in circumstances where they have not been deleted, clipped or anonymised), telephone number, date of birth and any other such data which has been provided by you on this website’s Online Complaint Form. Such information is only collected (via the website) from you if you voluntarily submit it to us.

“Non-Personal Data”

Like most organisations, GSOC gathers statistical and other analytical information collected on an aggregate basis of all visitors to our website. 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 our website.

Cookies are small files that are created and saved on your phone, tablet or computer when you visit a website. Cookies store information about how you use the website, such as the pages you visit on our website and how you interact with the content on some of those pages. If you use the social media buttons on our website and allow the cookies from the companies that own these platforms then they will collect information about you. More information is available below.

GSOC uses cookies for the following purposes:

• To enable core functionality such as page navigation, security and logged-in status (functional cookies)
• To understand how visitors interact with the content (analytics)
• To improve the Website by ensuring the Website is performing properly (non-essential cookies)
• To allow YouTube videos to play for users. These cookies are used to enable embedded YouTube video to be played on our website. They can also collect anonymous data about your web browser to display targeted advertising to you across the Web – these are called “YouTube cookies”

3.1 General Information

3.2 Non Essential Cookies

The Non-Essential Cookies described above are provided by Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by these cookies about your use of the website (including your IP address) will be transmitted to, and stored by, Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You do not have to consent to the use of these cookies which are switched off by default on our website, unless you have chosen to accept them. When you click on “Accept All Cookies”., you consent to the processing of data about you by Google in the manner, and for the purposes, set out above.

List of Non-Essential Cookies

Type (How do we categorise the cookies)

Expiration (How long cookies last)

3.3 Social Media

• We have included a social media buttons on the Website. This provides a link to our Twitter account and YouTube channel. We do not place any cookies or other trackers when you use these links from the Website.
• GSOC has a policy on its Social Media Engagement Programme. That policy sets out the purpose, and the parameters for the day to day operation, of that Programme. That policy is available here
• GSOC does not process personal data from social media platforms. You may come across GSOC on Twitter and YouTube through your own networks or by linking to them from the GSOC We use these platforms to inform, educate and engage people about the rights of children and our work. If you are logged into your own account for any of the social media channels then these parties may use their own scripts and trackers to record that you have visited our social media account.
• We use a social media platform because it is a valuable tool for us to raise awareness of the work we do with different audiences. The companies who own these social media platforms are commercial entities. We want to remind you that information shared by you on our timelines, on pages or in private messages on our social media may be used or sold by these companies for commercial purposes.

For more information about how these Third Parties process your information please read the links provided below.

Twitter: Privacy Policy – Cookies – GDPR Compliance  Opt-out option.

YouTube: Privacy Policy – Cookies – GDPR Compliance Opt-out option.

3.4 Where can I get more information about Cookies?

You can find more information about cookies by visiting the following information websites:

www.aboutcookies.org
www.allaboutcookies.org

Personal Data

We will process any Personal Data you provide to us for the purposes of fulfilling our statutory functions under the Garda Síochána Act, 2005 (as amended). These are:

• Deal with complaints from members of the public about garda conduct
• Conduct independent investigations into circumstances where it appears that the conduct of a garda or gardaí may have resulted in death or serious harm to a person;
• Investigate matters in relation to the conduct of gardaí where it is in the public interest to do so even if no complaint has been made or no referral has been received;
• To examine practices, policies and procedures of the Garda Síochána.

Non-Personal Data

We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our website visitors come from and to help us design and organise our website better.

4.1 Website Contact Form Users

If you get in touch with us through the contact form on our GSOC website, we save the details you share with us on our database. GSOC uses the data that you give to work out how we can answer the query or concern that you have raised with us. We also use the data to send our response to you by email. This way, if we get in touch with you in future, we can refer to our previous conversations. We will not contact you or share your details without asking for your consent. We keep the personal information obtained in this way for a maximum of seven years, after which we keep an anonymised version.

4.2 Website visitors

The cookies contain an ID number, which is used to uniquely identify your browser and track each site you visit that has GA enabled.

We use this data to find out the number of people using our sites and to better understand how they find and use our web pages. With this information, we can continually improve the information that we provide on our sites and the processes for actions such as contacting us. We can also use it to increase the number of new people finding our sites.

Google analytics stores the following data:

• Time of visit, pages visited, and time spent on each page of the webpages
• Interactions with site-specific widgets
• Referring site details (such as the URL a user came through to arrive at our sites)
• Type of web browser
• Type of operating system (OS)
• Flash version, JavaScript support, screen resolution, and screen color processing ability
• Network location and IP address
• Document downloads
• Clicks on links leading to external websites
• Clicks on videos
• Scroll depth

Personal Data

We will not disclose your Personal Data to third parties except:

• to the extent that we are required to do so by law, and/or
• in compliance with the Garda Síochána Act, 2005 (as amended) and/or
• to the extent that you have consented to this disclosure.

The third parties to whom we may provide this information may include parties to the investigation, the Garda Commissioner, the Office of the Director of Public Prosecutions and the Garda Síochána Inspectorate. This list is not exhaustive.

Information Shared with the Garda Commissioner

We may share information with the Garda Commissioner in accordance with section 81 of the Garda Síochána Act, 2005 (as amended) and having regard to the Memorandum of Understanding, Protocols and Agreement on Operational Matters. In particular, your attention is drawn to Part 4 (“Sharing of information, including evidence”) and Appendix 3 (“Information Sharing Protocol”) of that Memorandum.

Non-Personal Data

We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of community users of our website or the activities that visitors to our website engage in while on our website.

Your Personal Data is held on secure servers. 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.

Under the Data Protection Act 2018 you are entitled to apply to have your personal data updated and you may inform us at any time of any changes in your personal data. As an individual whose personal data is processed by GSOC, you have the following rights:

• the right to be informed, which is what this privacy statement is for
• the right to access the personal data we hold about you, subject to lawful restrictions
• the right to object to direct marketing, (either use the ‘unsubscribe’ button on our emails or contact us directly)
• the right to object to processing carried out on the basis of legitimate interests
• the right to erasure (in some circumstances)
• the right of data portability
• the right to have your personal data rectified if it is inaccurate
• the right to have your personal data restricted or blocked from processing

To request information on what personal data we hold on you or to request to have your personal data updated, amended or removed from our database, please email dataprotection@gsoc.ie or write to:

Data Protection Officer
Garda Síochána Ombudsman Commission
150 Abbey Street Upper
Dublin 1.

Following receipt, your application will be considered and a response will issue to you in this regard within the applicable statutory timeframe.

If you are not happy with the way we have handled cookies or your personal data, and are unable to resolve the issue with us personally, you can complain to the Data Protection Commission here.

GSOC does not engage in any direct marketing activity. However, from time to time (including on our Complaint Form), we offer individuals the option of providing us with certain voluntary additional information so as to assist us in assessing statistically important information. However, where we seek this information we make it clear as to the purposes behind the request and the voluntary nature of any response to it. Complainants who do not wish to provide this level of information need not do so and their decision in this regard will in no way have any effect on the way their complaint is treated.

We do not process or retain personal information in an identifiable format for longer than is necessary.

GSOC retains your data for as long as it is necessary to serve the purpose for which it was collected. For example, we will retain data relating to a complaint for the duration of the investigation of the complaint and in certain circumstances, where we have a legal or statutory obligation to do so, we may retain it for longer. This might occur if further legal action is taken following the completion of an investigation.

The personal data that we collect from you is not generally transferred outside of the European Economic Area (“EEA”).  In the case that GSOC needs to transfer such data outside the EEA it will ensure that an adequate level of data protection in that country exists that is no less protective than that which is provided in Ireland.

This Website Privacy Policy replaces all previous versions of this Policy.

This Policy may be updated from time to time in the light of operational experience and changes in legislation or technology.

GSOC will ensure that the most up to date version of its Website Privacy Policy will be posted on this website so you are always aware of what information 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 Website Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you and you will have a choice as to whether or not we may use your information in the new manner.