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Privacy Policy for Threshold Training Network

Data protection and personal information background

Data Protection is concerned with the safeguarding of the privacy rights of individuals in relation to the processing of personal data. The Data Protection Acts 1988, 2003 and 2018 and related regulations confer rights on individuals as well as responsibilities on those persons processing personal data.

Personal data means data relating to a living individual who is or who can be identified either from the data in conjunction with other information that is in, or likely to come into, the possession of the person controlling the content and use of personal data (i.e. the data controller). An individual or organisation who collects, stores and processes any data about living people on any type of computer or in a structured filing system are defined as data controllers. TTN is such a data controller. The Chief Executive holds responsibility for the data collected and stored by TTN and may assign duties to collect and properly store necessary personal data from time to time to other members of staff. It shall be a duty of the CE to ensure that TTN’s record systems are kept up to date with any new relevant regulations or legislation.


Data controllers have certain key responsibilities for the information they process which must be adhered to. These are summarised in terms of the following 8 fundamental rules:


1) Obtain and process information fairly

2) Keep it only for specified, explicit and lawful purposes

3) Use and disclose it only in ways compatible with these purposes

4) Keep it safe and secure

5) Keep it accurate, complete and up to date

6) Ensure that it is adequate, relevant and not excessive

7) Retain it for no longer than is necessary for the purpose or purposes

8) Give a copy of his or her personal data to that individual on request.


This policy governs the use by Threshold Training Network of any data you share with us whether by using our website (the Threshold Training Network Website), or otherwise engaging with our services.


Threshold Training Network respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we use your personal data when you visit the Threshold Training Network Website (regardless of where you visit it from) or otherwise share data with us and tell you about your privacy rights and how the law protects you.


For the purpose of this document, any reference to ‘our website’ or ‘this website’ or ‘the website’ shall be deemed to be a reference to the Threshold Training Network Website accessed by you.


1. Important information and who we are

1.1. Purpose of this privacy notice

This privacy notice aims to give you information on how Threshold Training Network collects and processes your personal data through your use of this website, including any data you may provide through this website when apply to participate on any courses or programmes provided by us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.2. Controller

Threshold Training Network registered in Ireland with charity number CHY 12234 and with registered address at 17-19 Tallaght Enterprise Centre, Tallaght Village, Dublin 24 is the controller and processor responsible for your personal data.

You have the right to make a complaint at any time to the Data Protection Commissioner’s Office ( being the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner’s Office so please email us at in the first instance.

1.3. Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 12/08/2020.

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

1.4. Third-Party Links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


2. The data we collect about you

2.1. Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:

2.1.1. Identity Data includes first name, last name.

2.1.2. Contact Data includes email address and telephone numbers.

2.1.3. Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

2.1.4. Usage Data includes information about how you use our website and services.

2.1.5. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.2. Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

2.3. Further information

We may provide you with further specific information about the type of data and purpose of it at the point of data capture.


3. How is data about you collected

3.1. We use different methods to collect data from and about you including through:

3.1.1. Direct interactions. You may give us your

3.1.2. Identity, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when complete a contact form on our website; Submit a CV to us for consideration for a current and future job vacancies apply for jobs advertised by us via third party sites; enter into a service contract with us

3.1.3. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. Please see our cookie policy for further details.

3.1.4. Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below LinkedIn or other public forums; Former employers in the context of reference checking;


4. How we use your Personal Data

We have set out below 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 email us at 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.

The lawful basis of processing that we use are as follows:

4.1. Legitimate Interest means the interest of our organisation in conducting and managing our operations to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing us at

4.2. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

4.3. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

4.4. Consent means we will only process your data when you have consented to it for one or more specific purpose. You consent will be as easy to withdraw as it was to grant and processing your data will cease if your consent is withdrawn.


Type of data
Lawful basis for processing including basis of legitimate interest

To comply with legal and revenue requirements (a) Company Name
(b) Company address
© Email address
Statutory requirements

For recruitment purposes
(d) First Name
(e) Last Name
(f) Email address
(g) Any information contained in your Curriculum Vitae
Consent given at the point where your data is provided to us.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website and social media content to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical

Subject to our Cookie Policy

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact


4.5. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.6. Opting Out

You can ask us to stop sending you marketing messages at any time by contact us link at any time.

Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of another transaction.


5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

5.1. Internal Third Parties.

Other members of the Threshold Training Network company.

5.2. External Third Parties.

5.2.1. Service providers who provide IT and system administration services.

5.2.2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Ireland who provide consultancy, payroll, banking, legal, insurance and accounting services.

5.2.3. Revenue, governmental agencies, regulators, grant authorities and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances or to whom we are obliged to share information about our organisation and participation in it.

5.2.5 Third parties with whom we partner in order to fulfil our contractual obligations to deliver your requirements. This may include tutors.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


7. Data storage and retention – How long will you use my personal data for?

Our company securely stores your data at 17-19 Tallaght Enterprise Centre, Tallaght Village, Dublin 24, backups are securely stored on the cloud.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Details of retention periods for different aspects of your personal data are available in the table below:


Personal Information Collected


Reason for collection Retention Time Student Registration Form

Info to provide support to student while doing course and to assess readiness for course.

Registration shredded once the student finishes the course and has QQI certification


Doctor’s Medical report

To prove that student has diagnosis of MHD, copy of report sent to ETB, student give written consent

7 years as per ETB for audit purposes


Expression of Interest form

To advise DDLETB that TTN has a potential new recruit

Shredded by TTN once student gets QQI certification at the end of programme if it is kept on file


Learner Detail form

Student signing up for DDLETB funded programme. Information required by funder. It is not kept on file by TTN, it is sent to DDLETB.


Training allowance info, bank details, start form

To pay person their weekly training allowance.

7 years as per ETB for audit purposes


Sign in, weekly attendance, medical certs

To prove students attendance at course or authorised absence

7 years as per ETB for audit purposes


Exit form

To advise ETB student leaving and to reinstate their payment with SW

7 years as per ETB for audit purposes


Monthly 1-2-1 and learning plans

For student reflection/review & evidence of student’s ILPs.

1 month after certification is issued by QQI


QQI modules portfolios

To complete QQI assessment requirement

Hard copies of student portfolios kept until 1 month after QQI certification.


Disciplinary issues

Work experience evaluations

To provide support and boundaries to student while doing course

2 years after leaving-if issue arises such as personal injuries case


Modules achieved & outcomes, excel spreadsheet, on Public drive

To submit to ETB to show placements Threshold Training Network annual statistics to show outputs from training for forward planning

3 yrs after finishing programme


Certification Pack

For QQI certification and adherence to ETB training standards for secondary providers

7 years as per ETB for audit purposes


Group folder

ETB training standards requirement

1 month after students get certification from QQI


Café Sign in

Fire safety and record of attendance numbers

End of each month after record of attendances completed


Loyalty Cards

To assign owner to cards

Cards in raffle shredded last Friday each month


Visitors Book

In the interest of fire and safety if evacuation required

At the end of each month


Wellbeing Classes

To make contact with people signed up if changes in workshop or classes cancelled

At the end of each month, booking sheets shredded


Taking Messages

To make contact to pass on to staff member

Till message passed on. Post it shredded , email deleted


Meditation and auricular acupuncture consent

To have record of persons consent, explains process and contraindication. Each person asked to re do each September

1 year from September


Emailing contact list

Everyone advised that it is receive info on wellbeing calendar and courses

Each monthly email offers people the opportunity to email back if they wish their name to be removed from contact list.


WRAP Names

As record that they completed level 1 WRAP

2 years


Staff files-Hard copy and soft copy for holiday and sick leave

To give employment history with the organisation and record leave year to year

2 years after leaving org hard copy file shredded


Annual leave record-held until end of January of the following year

Sick leave record held for 3 years

Training records 10yrs for Health and safety in workplace legislation


Interview sheets

For feedback, review or audit purpose

1 year after interviews



to pay staff

7yrs for audit purposes


Email correspondence

to provide support for people while attending centre

as soon as not needed


Text messages

to provide support for people while attending centre

as soon as not needed


Server and back up tapes


HOP Participant

to match with volunteer and provide participants support while on the project


HOP Volunteer

to match with participant and provide support while on the project


Trainer file

CV, tax clearance certs and invoices

7 years for audit purposes


Training Panel Interview sheets

For feedback, review and audit

1 year after interviews


Student on Placement information

College requirement and to be covered by insurance

until placement is over



For contact info

2 years after finishing



For contact info

2 years after finishing


Fire Drills

As proof carried out

7 years



To safeguard students and maintain a safe learning environment

2 years after person has left the organisation


Manual Handling Training

To safeguard students and maintain a safe learning environment

2years after person has left the organisation


Work experience time sheets

To prove student was on the course

7 years for audit purposes


GDPR Policy review

Addendum 1 added and info storage times reviewed and updated

February 11th 2020


In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may;

8.1. Request access to your personal data.

This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. An access request form can be obtained from the CE at

8.2. Request correction of your personal data.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

8.3. Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

8.4. Object to processing of your personal data.

You may object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

8.5. Request restriction of processing your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

8.6. Request transfer of your personal data to a third party.

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

8.7. Right to withdraw consent.

Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email


Addendum 1

As per email from Karen Mahon ETB 26th of September 2019, TTN is a data controller in respect to the client records we keep for our purposes and a data processor in relation to the personal information we keep in relation to students for DDLETB purposes
The proof of identification is required for sighting for DDLETB, threre is no need tor TTN to keep a copy on our records (as per email rmrn E-8 September 26th 2019) -the proof of ID can be social welfare card, passport, or birth cert