Data Protection Policy

• Data Protection Legislation (“the Legislation”) provides rules which apply to the collection, use and processing of information concerning individuals. The Legislation sets out the principles that the Coillte Group must follow when processing personal data about individuals. It also gives individuals certain rights in relation to personal data that is held about them. For the purposes of this Policy, Data Protection Legislation means the Data Protection Acts 1988 to 2018 and any other applicable law or regulation governing the processing of personal data, including the General Data Protection Regulation (Regulation (EU) 2016/679).
  
  • This Policy sets out the basis on which we will process any personal data we collect from candidates for employment, or that is provided to us by individuals or other sources.
  • This Policy does not form part of any contractual agreement and may be amended at any time
  • For the purposes of this Policy, the Coillte Group comprises the following entities;
    • Medite Europe DAC, with an address of Redmondstown, Clonmel, Co. Tipperary.
    • Smartply Europe DAC, with an address of Belview, Slieverue, Waterford; and
    • Coillte Panel Products (UK) Limited, with an address of Persimmon House, Anchor Boulevard, Crossways Business Park, Dartford, Kent DA2 6 QH, England;
    • Coillte CGA, with an address of Dublin Road, Newtownmountkennedy, Co. Wicklow (“Coillte”);
  • While your personal data is likely to be primarily collected by the Coillte Group entity with which you have applied for employment, the Coillte Group entities share centrally organised management and administrative functions with the result that your personal data may be processed jointly by one or more of the above listed Coillte Group entities. The entities comprising the Coillte Group have agreed that they are joint data controllers, for the purposes of this policy, and that Coillte will undertake responsibility for compliance with Data Protection Legislation, in the context of your personal data, on behalf of the Coillte Group.
  • Any questions about the operation of this Policy or any concerns that the Policy has not been followed by the Coillte Group entity with which you have applied for employment, should be referred in the first instance to MEDITE SMARTPLY’s Data Protection Champion, Mark Hearne by email at dpc@mdfosb.com.
  • Liam McKenna, Mazars is the Coillte Group Data Protection Officer and he is responsible for ensuring the Coillte Group’s compliance with the Legislation and with this Policy.

• The Coillte Group needs to process personal data relating to you for the purposes of enabling us
  
  • to consider your suitability for employment; without such processing, it would not be possible for us to consider your application for employment. Please see the Schedule to this Policy for information in relation to;
    • the categories of personal data that we will process about you;
    • the reasons for any such processing;
    • the legal basis for any such processing;
    • the recipients or categories of recipients of the personal data; and
    • the period of time for which the personal data will be stored.

• We may, from time to time, engage the services of third parties (“data processors”) to assist us to perform our functions or obligations, for example, we may engage an external service provider to assist us to carry out reference checks, or perform functions in connection with the application/interview process. Where this occurs, any processing of personal data by the data processor will be in compliance with the requirements of the Legislation. Any such processing will be regulated by a contract between the Coillte Group and the relevant data processor. That contract will govern the conditions under which any personal data may be processed, the security conditions attaching to the processing of the data and will require the data processor to delete or return the data to the Coillte Group upon completion or termination of the contract.
  
  • We may, from time to time, need to seek advice from professional advisers such as lawyers, accountants and doctors in relation to your/the Coillte Group’s rights and entitlements and/or matters arising in connection with the application/interview process. It may be necessary to share certain records with those professional advisers in that context. Where those records contain personal data relating to you, we will rely on the following legal basis when sharing personal data with such professional advisers;
    • In the context of personal data, we will only share personal data with our professional advisers where necessary for the purposes of compliance with a legal obligation to which the Coillte Group is subject; and
    • In the context of special category data, we will only share personal data with our professional advisers where necessary for the purposes of enabling the Coillte Group to carry out its obligations or exercise specific rights (or to enable you to carry out your obligations or exercise specific rights) in the field of employment, insofar as it is authorised by EU or Irish law.

• The Coillte Group has installed CCTV systems in various locations for the purposes of;
  • protecting the safety and security of staff, visitors and other members of the public who attend at our offices/other locations where we manufacture goods or provide services;
  • protecting our buildings and assets from damage, disruption, vandalism and other such crime;
  • deterring anti-social activity in and around our offices/other locations where we manufacture goods or provide services;
  • supporting the day-to-day management of our operations, including ensuring the health and safety of staff and others;
  • enabling the investigation of suspicious activity, both inside and outside of our offices/other locations where we manufacture goods or provide services, including any issues that give rise to, or arise during the course of investigations into criminal or potentially criminal matters by Law Enforcement Agencies i.e. Police Authorities; and
  • ensuring that the Coillte Group is in a position to support/defend any litigation taken by/against it, whether in connection with any investigation carried out pursuant to Clause 4.1(e) above or otherwise.
    • For the purposes of this Policy, “CCTV system” includes any system designed to monitor or record images of individuals or information relating to individuals by the use of cameras (such as the Automatic Number Plate Recognition system in operation at the premises of Smartply Europe DAC, Belview, Slieverue, Waterford). The provisions of this Policy apply equally to images captured/recorded on the Coillte Group’s CCTV system as to any other form of personal data. Information relating to the personal data that will be collected and processed by way of the CCTV system is detailed further in the Schedule.

• CCTV cameras have been placed inside and outside of our offices/other locations where we manufacture goods or provide services. The system uses both fixed and domed cameras designed to capture and record images of individuals and property. The cameras do not pick up or record sound.
  

• Signs are displayed on-site at each of the Coillte Group entity locations including at site entrances to alert individuals that their image may be recorded. The signs contain details of the organisation operating the system (where the system is not operated by the Coillte Group) together with information in relation to how individuals can contact that organisation or otherwise access further information in relation to how any captured images will be processed, accessed and stored. The camera locations have been chosen in such a way as to minimise the viewing of spaces not relevant to the purpose of the monitoring. Cameras have not been placed in areas in which individuals might have a reasonable expectation of privacy, e.g. locker areas, changing rooms and toilet facilities. CCTV monitoring operates 24 hours a day and data captured on cameras is continuously recorded.

Live feeds from CCTV cameras will only be monitored where this is reasonably necessary to achieve the purposes set out in Clause 4.1 above. Otherwise, recorded images may be spot checked or accessed where necessary to achieve the purposes set out in Clause 4.1.Live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. This may include HR staff or members of management involved with or supporting investigations into suspicious activity. Recorded images will only be viewed in designated, secure offices.

Images captured/recorded by the CCTV system will only be used for the purposes set out at Clause 4.1 above, or for any other purpose(s) specifically permitted by the Legislation. The periods of time for which any images or recordings will be processed by the Coillte Group are detailed in the Schedule.