PRIVACY POLICY

McBreen Environmental Drains Services Limited (hereafter known as ‘McBreen’, ‘we’, ‘our’ or ‘us’) takes your privacy seriously. This Privacy Notice describes our privacy practices in relation to information that we collect through our website, phone, email and site surveys. This Privacy Notice outlines:

  1. Who we are.
  2. Explanation of terms.
  3. What information we collect about you.
  4. How we collect the information.
  5. How we use that information.
  6. How we share information that we collect.
  7. How we store and secure information that we collect.
  8. Your rights as a data subject.
  9. How you can access and control your information.
  10. Other important details.

This Privacy Notice does not apply to the practices of third parties that we do not own or control.

1.Who we are

McBreen Environmental Drains Services Limited (McBreen, we, our) provides a range of services including drain cleaning, CCTV drain surveys, sludge and grease disposal, hydro demolition, integrity testing and drain rehabilitation. McBreen Environmental Limited includes all entities under the McBreen umbrella, such as InDepth Water Management, Connaught Drains and Breffni Organics.

If you have a query in relation to how your data is handled, you can contact us by email or phone:

Email:  sales@mcbreen.ie

Phone: 0818 66 33 33 (Option 5)

Post:     McBreen Environmental Drain Services Ltd, Lismagratty, Cootehill Road, H12 FP44, Co. Cavan.

2. Explanation of terms

Personal information means information relating to a living individual who is or can be identified either from the data or from the data combined with other information.

Sensitive personal information relates to the processing of special categories of personal data revealing

racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Processing means performing any operation or set of operations on data including Obtaining, recording, or keeping data, collecting, organising, storing, altering, or adapting the data, retrieving, consulting, or using the data, disclosing the information or data by transmitting, disseminating, or otherwise making it available, aligning, combining, blocking, erasing, or destroying the data.

A Data Subject is a living individual who the personal information relates to.

A Data Controller is a person or entity who, either alone or jointly with others, determines the means and purposes for processing personal data.

A Data Processor is a person or entity who processes personal information on behalf of the Data Controller.

3. What information we collect about you

We collect the following information:

  • Personal Data. “Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include name, title, company name, job function, expertise, address, postcode, telephone number(s), email address, browser, and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
  • Special categories of Personal Data (sensitive data). While we do not, in general, collect or process many types of special categories of personal data, it may be necessary, for example, to process medical information for employment purposes.
  • Criminal convictions data. “Criminal convictions data” includes personal data relating to the alleged commission of offences. While we do not, in general, collect or process many types of criminal data, we do process driver’s licences and penalty point data for employment purposes.
  • Other Information. “Other Information” is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymised. We use this information for other purposes as described below.


4. How we collect the information

We collect Personal Data and Other Information in several ways:

 

Explanation

Offline:

We may collect information from you offline, such as during on-site visits, during phone calls with our employees/representatives, or when you contact us.

From you:

We collect information such as your contact details, address, postcode, or your preferred means of communication (including email) when you voluntarily provide it.

You can browse our website without disclosing any information about yourself. Where we do request information from you, it is only information which we need to be able to provide you with the service(s) you have requested. By entering your details in any fields requested, such as your name, email address, telephone, or mobile number you enable us to provide you with the service(s) you select and for market research, which allows us to understand how to provide a better service for all customers.

We will tell you if we would like to send you information about our services or products and give you the choice to opt-in. We will also give you the opportunity to easily opt-out at any time.

From time to time, we will take photos or videos of employees to promote the workings of the business and/or for employee safety audits on sites – these may be displayed on our website, within our internal client relationship systems, our intranet, on our social media sites, on brochures or other promotional material. Each employee will be asked, in advance, if they wish to participate. Partaking in the video or photo is therefore deemed as consent for this processing.

Via your browser or device:

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the site you are using. Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the website, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is carried out automatically by many websites, applications, and other services, such as Google Analytics. We may use IP Addresses to calculate usage levels of the web site, to administer the site and to diagnose problems.

Many devices will have their own privacy settings and notices under which they may collect your information, so you may wish to check your device settings to obtain details of such processing.

Via cookies and other similar technologies:

“Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the website. When you visit a website, it can send one or more cookies to your device. These cookies enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse and enhance the level of services and functions provided. Please review our Cookies Policy (which can be found on our website) for more information.

Via our social media sites

We may collect publicly available information from social media websites, applications, and online content.

Via recruitment and employment processes

We will process certain personal information about our employees, that we collect during the job interview process, at the start of employment and in the course of employment. We process this personal data to the extent permitted or required under applicable law, for purposes connected with employment, such as human resources, payroll management and administration. We may process special categories of personal data such as medical data. We may process criminal convictions data such as your driver’s licence and penalty point data, when required, during the course of your employment with us.

We will process information you provide to us via the recruitment process including references, results of pre-employment screening, employment history, relevant experience, achievements, skills and qualifications, the outcome and results of any interviews or tests (which are part of the recruitment process) and any other information you provide us in the context of the recruitment process. The information provided enables us to consider you for the recruitment process.

We, and the companies that process recruitment-related information on our behalf, will use your personal information for the purposes of recruitment, including to evaluate your application and assess your suitability for the role in question, make a decision about whether you should be selected for interview and appointment, conduct relevant pre-employment screening (e.g. verify your address, academic qualifications and work experience), review and audit the recruitment process and its outcomes and identify any future employment opportunities which may be of interest to you.

We may process your personal data as part of using the Fleetmatics and GeoPal applications, the purpose of which is to assist with scheduling jobs, to identify the location of vehicles, to monitor assets, to assist job management, to provide training and to assess time management as part of our quality control processes to ensure no overcharging, or undercharging, of customers is occurring.

From time to time, we will use personal data of employees to promote the workings of the business, for example, an employee’s bio included within a tender document.

Your information will only be accessed and processed by authorised personnel, including recruiting line managers, HR professionals and occupational health professionals, who are directly involved in the management and administration of your personal data and have a legitimate need to access your personal information.

Via cameras

Front and rear-facing cameras may capture personal data of third parties. These cameras are installed for the purpose of reviewing accidents and will not be driver-facing.

5. How we use that information – purpose and lawful basis for processing

We use Personal Data:

  • To send information and materials regarding our products and services. To send administrative information such as changes to our terms, conditions, and policies.
  • To send you marketing communications, if you have consented to receive these communications, including via email in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
  • To verify the accuracy of the information we receive.
  • For our business purposes, such as data analysis, audits, developing new products, enhancing, improving, or modifying our website and services, identifying usage trends, determining the effectiveness of our operations, and expanding our business activities.
  • For recruitment and employment purposes, such as staff management, performance review, training records, appointments, removals, personal development, and administration.
  • To make or receive payments.
  • To complete a site survey.
  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

Our legal basis for processing Personal Data in certain circumstances will be in the instances where we need the Personal Data to perform a contract with you or to enter a contract with you. In some cases, we may also have a legal obligation to collect Personal Data and Special Categories of Personal Data (e.g., assessment of capacity to work). If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

We will collect and use your Personal Data where the processing is in our legitimate business interests, such as for fraud prevention, to ensure network and information security or for administrative transfers within the McBreen Group.

We will respect your right to privacy and only contact you if we have your consent, and we will only use methods you have agreed to. This may be post, face to face, email, text message, telephone, or any other available messaging service. We do not contact children with details of our services. We will not sell your details to other organisations but we may use marketing agents to act on our behalf.

You can withdraw consent at any time, and we will stop sending you details of our marketing offers. If you change your mind at any time about the contact methods you have agreed to, or to withdraw your consent, just let us know:

Email:  marketing@mcbreen.ie

Phone: 0818 66 33 33 (option5)

Post:  McBreen Environmental Drain Services Ltd, Lismagratty, Cootehill Road, H12 FP44, Co. Cavan.

We will always respect your rights to privacy and will only process your personal information where a lawful purpose applies:

  • You have consented to the processing.
  • It is necessary for the performance of a contract you have or have requested to enter.
  • If we have a legal obligation to do so.
  • To protect the vital interests of an individual.
  • If we have a legitimate business interest where it does not have an unfair impact on you; or
  • Where it is in the public interest, or we have been given official authority to do so.

If any of the details we collect, use, store or share is sensitive personal (Special Category) information we will only do this where:

  • We have given you a clear explanation and obtained your explicit consent.
  • The processing is necessary for the purposes of carrying out the obligations in the field of employment and social security.
  • We believe you or another person may be at risk to protect yours or their vital interests.
  • You have made the information public.
  • It is necessary to establish, exercise or defend a legal claim.
  • The law determines there is a substantial public interest, but we will always consider and take appropriate measures to safeguard your rights and privacy before doing this; or
  • Processing is necessary for the purposes of preventative or occupational medicine, for assessment of the working capacity of an employee.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (using the contact details provided above) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose

(processing activity)

Type of data

Lawful basis for processing

To register you as a new customer or to provide a quote.

Name, address, site address, postcode, phone number, email address.

Site survey of premises (including images of before and after).

To enter into a contract with you.

Necessary for our legitimate interests (to ensure we are providing effective services to you or evidence for your compliance with environmental laws).

To manage our ongoing relationship with you which will include:

–       Sending administrative information such as changes to our terms, conditions, and policies.

–       Issuing services correspondence such as reminders of the last tank clean/drain service and and when next one is due or recommended.

–       To make or receive payments.

–       To complete a site survey.

–       Asking you to leave a review or take a survey.

Name, address, site address, postcode, phone number, email address.

Site survey of premises (including images of before and after).

For the performance of a contract with you.

Necessary for our legitimate interests (to ensure we are providing effective services to you).

For our business purposes e.g. data analysis.

Name, address, site address, postcode, phone number, email address,

site survey of premises (including images of before and after), website visits, cookie analytics and usage trends.

Necessary for our legitimate interests (such as audits, developing new products, enhancing, improving, or modifying our website, applications, and services, identifying usage trends, determining the effectiveness of our operations, and expanding our business activities).

To deliver relevant content and advertisements to you in relation to our services and measure or understand the effectiveness of the advertising we serve to you.

Name, address, site address, postcode, phone number, email address.

With your consent.

To make suggestions and recommendations to you about goods or services that may be of interest to you.

Name, address, site address, postcode, phone number, email address.

With your consent.

To administer a service to you – we may pass your personal data to associate companies, agents, and service providers (see section 6 for further information).

Name, address, site address, postcode, phone number, email address, bank account information.

For the performance of a contract with you.

For recruitment and employment purposes, such as staff management, performance review, training records, appointments, removals, personal development, scheduling jobs, identifying location of vehicles, assessing time management and administration.

Name, address, site address, postcode, phone number, email address, performance records, bank account information, training records, driver’s licence, penalty point data.

For the performance of a contract with you.

As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Name, address, site address, postcode, phone number, email address, banking information.

To meet our legal obligations.

6.How we share information that we collect

We may pass your personal data to associate companies, agents, and service providers (such as recruitment agencies, pension and insurance providers, laboratories (for testing of effluent), and marketing and social media organisations (when you have consented to receive marketing correspondence)) to administer the service provided such as assessing suitability, resources required, provide information on our services and to manage our relationship with you. Any third parties that we may share your data with are obliged to keep your details securely. When they no longer need your data to fulfil this service, they will dispose of the details in line with our secure disposal procedures.

If we offer you products or services from other organisations and you take these products you will be entering into a contract with the organisation concerned.

We may release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organisations for the reasons given under Section 5 above.

We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data. In some instances, we may combine Other Information with Personal Data (such as combining your email with the name of your organisation). If that combination permits you to be identified, we will treat the combined information as Personal Data for as long as it is combined.

7. How we store and secure information that we collect

We have implemented appropriate organisational, technical, and administrative measures to protect Personal Data within our organisation, including security controls to prevent unauthorised access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorised access, modification, and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Us section below.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

8.Your rights as a data subject

Data Protection laws exist to protect and safeguard your rights and to ensure your personal information is processed in a fair and transparent way.

We decides what personal information we need to collect about you, how we use it, who we share it with and how long we keep it. This makes us the Data Controller of your personal information for Data Protection purposes. We may use Data Processors to act on our behalf however, this will always be under contract and after we have assessed their suitability. They are obliged to process your information only according to our instructions, keep it safe and not use your details for any other purposes. We will not sell your details to any other companies for them to use for their own purposes.

Data Protection laws give you rights relating to your personal information and set out rules that organisations acting as Data Controllers or Data Processors, must abide by. Your rights, as outlined in this notice, enable you to ensure that your personal information is accurate, is only made available to those that should have it and is only used for the purposes you expect.

Any rights request you make will be met within one month. If there are exceptional circumstances where this timescale cannot be met, we will contact you and explain this to you.

  • Right to be informed – We must be transparent with you about the processing we do with your personal information, informing you in a concise, intelligible manner using clear and plain language.
  • Right of access – you have the right to request a copy of the information that we hold about you. You can request a copy by completing a subject access request form which can be found on our website or by contacting us using any of the methods in this notice. If we refuse your request under a right of access, we will provide you with a reason as to why. You have the right to complain as outlined in Section 10.8 below.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation. This right applies only where the processing is based on your consent, or where necessary for the contract you have with us, and the processing is carried out by automated means.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

How you can access and control your information

If you would like to access, correct, amend, remove, object or limit the use or disclosure of any Personal Data about you that has been collected and stored by us, or have it transferred to another organisation, please notify us at sales@mcbreen.ie so that we may consider and respond to your request in accordance with applicable law.

You can opt-out of receiving marketing messages from us, or our business partners, at any time by unsubscribing through the unsubscribe or opt-out link in an email or by sending an email to marketing@mcbreen.ie. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative or service messages.

For your protection, we only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We will action your request within one month.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion.

10. Other important details

10.1 How long we will retain your Personal Data

We will not keep your personal data for longer than is needed for the purpose the data was originally collected, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes, and enforce applicable agreements. We have a Records Retention Policy and Schedule in place which outlines all timelines for retaining data records.

If you would like further information about the periods for which your personal data will be stored, please contact us using the contact details in the “Contact Us” section of this Notice.

10.2 Third Party Sites

Some websites, social media and applications permit you to link to other websites on the Internet through direct links or through applications such as “share” or “like” buttons, and other websites likewise may contain links to our sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Notice. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information is collected and used by them.

Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organisations, such as Apple, Facebook, Google, LinkedIn, Microsoft, RIM, Twitter or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data you disclose to other organisations through or in connection with Social Media Pages.

10.3 Personal data of Children

We do not knowingly or specifically collect information about minors under the age of 16. If you believe that we have mistakenly or unintentionally collected such information, please notify us at marketing@mcbreen.ie so that we can delete the information from our servers.

10.4 Sensitive (i.e., Special Categories of Personal Data) Information

We ask that you not send us or disclose any sensitive Personal Data (e.g., PPS/social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership).

10.5 Changes to this Privacy Notice

We may amend this Privacy Notice from time to time. The “date amended” appears at the bottom of this privacy notice and this date indicates when the Privacy Notice was last revised.

10.6 Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

10.7 Contact Us

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and manage your information, please contact:

Email:  sales@mcbreen.ie

Phone: 0818 66 33 33 (option5)

Post:     McBreen Environmental Drain Services Ltd, Lismagratty, Cootehill Road, H12 FP44, Co. Cavan.

Because email communications are not always secure, please do not include bank account information or other sensitive (special categories of personal data) information in your emails to us.

10.8 Your right to make a complaint

We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

You also have the right to complain to a data protection authority about our collection and use of your Personal Data. Their contact details are as follows:

Data Protection Commission

21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland

+353 578 684 800
+353 761 104 800

Date last reviewed: 17 May 2024