The General Data Protection Regulations (GDPR) (EU) 2016/679, which came into effect on 25th May 2018, governs the controlling and processing of personal data in the European Union. TPI will process personal data in accordance with the GDPR and the Data Protection Acts 1988 to 2018.
TPI respects your right to privacy and actively seeks to preserve the privacy rights of all individuals who share their personal data with the Institute. In particular, this includes the following categories of persons:
- TPI staff members, both employees and contractors (including applicants for employment with TPI);
- TPI students (including applicants for training with TPI);
- TPI business contacts and suppliers; and
- all users of the TPI website.
Personal Data is any information relating to a living individual that allows for the identification of that individual. Personal Data can include a name, address, contact details, an identification number, IP address, audio-visual or audio recordings of a person, details about an individual’s location or any other detail(s) specific to that individual.
In circumstances where TPI controls Personal Data by deciding why and how that Personal Data is processed, TPI will be a “Data Controller”. Any entity that processes Personal Data controlled by TPI and does so on behalf of TPI, is a “Data Processor”. Data Processors may include third party service providers engaged by TPI (for example, payroll and marketing or recruitment agencies). As required by applicable data protection law, when TPI appoints a Data Processor, we will ensure that appropriate contractual protections are in place.
Under the GDPR ‘consent’ is no longer sufficient in itself as a legal basis to support the processing of personal data. Now, consent must be informed, for a specific purpose, freely given, unambiguous and capable of being withdrawn at any time.
TPI collects personal data under the legal basis of ‘legitimate purposes’, this means that such processing is necessary for TPI to meet its obligations and to provide relevant services to its students, staff and service providers. We will only use your personal data as the law allows us to do so, such as: where TPI has entered, or is about to enter, into a contract with you; to fulfil our statutory obligations; or where it is necessary for our legitimate purposes.
The purposes for how TPI uses this data include, but are not limited to: creating educational records of students training to become psychotherapists; monitoring the progression of students from year to year; the employment of staff to train and teach in the Institute; records of business transactions, payments etc.
TPI as a Data Controller will process the following categories of data that you provide to us:
Information you provide to TPI
This is personal data that you provide to TPI by post, email, telephone or online through the use of forms on our website www.turningpoint.ie This data can include any of the following types of information about you: your name, address, contact details, date of birth, country of birth, personal descriptions and photograph; medical details; financial data, such as your bank account; educational assessment and course progression data; professional or academic references; records of attendance and educational performance.
TPI will only use your personal data for the purposes for which it has been collected. Should any change occur that requires your data to be used for another purpose then TPI is obliged to seek agreement from you for that changed purpose.
Note that TPI does not collect any data about you from our website, such as technical information, cookies, usage data etc.
Data Storage, Retention / Destruction
TPI will only keep your data for as long as it is necessary in order to fulfil the purposes for which it was collected, including any purposes arising from contractual necessity and legal obligations. The period of time for which your data will be stored by TPI will vary according to the type of data concerned. For example, all student records are retained for a period of ten years. This is in accordance with the data protection policies of University College Cork, which validates the TPI MSc in Integrative Counselling and Psychotherapy, see:
TPI will manage, store and retain your personal data using security measures, including both physical and technical security. Any payment transactions are protected through the use of encryption, such as Secure Socket Layer (SSL) protocol and SSL technology.
Note that specific data protection procedures are related to academic research conducted by students of TPI: these procedures are available in the material provided to the MSc students, overseen by the TPI Research Ethics Committee.
Your personal data and your rights
The GDPR also introduces very detailed obligations on TPI to act transparently in relation to its data processing activities and what choices it is required to offer individuals in relation to their data.
In addition, individuals now have enhanced choices in relation to how their data is used, for example, data access rights, “right to be forgotten”, rights to object, withdraw consent, data portability etc.
So you have the following rights with regard to how TPI processes your personal data:
- You can seek copies of all data held about you by TPI (a subject access request) and you can find out how TPI uses your personal data; TPI has 30 days in which to meet this request.
- You have the right to ensure that any incorrect or incomplete data about you is corrected and updated;
- In certain circumstances you can seek that data about you be deleted from TPI systems that are used to process your data, or have the use of your personal data restricted in certain ways;
- You can object to certain processing of your data by TPI;
- You can exercise your right to data portability, that is if we process your data by electronic instead of paper means, then you have the right to obtain a copy of that data in a commonly used electronic format;
- If TPI has relied upon consent as a lawful basis for processing your personal data, then you have the right to withdraw that consent at any time.
Note that these rights are personal and specific to the individual concerned.
If you have any queries or complaints in connection with the processing of your personal data by TPI, then please contact the TPI Programme Director, 23 Herbert Street, Dublin 2, or email via firstname.lastname@example.org