EDITORIAL CONTRIBUTOR PRIVACY NOTICE
CONTENT
1. INTRODUCTION ...... 2
2. IDENTITY OF THE DATA CONTROLLER ...... 2
3. CONTACT DETAILS OF THE DATA PROTECTION TEAM ...... 3
4. WHEN DOES THIS PRIVACY NOTICE APPLY ...... 3
5. PROCESSING OF YOUR PERSONAL DATA ...... 3
6. SHARING OF PERSONAL DATA ...... 4
7. TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA ...... 5
8. HOW IS MY PERSONAL DATA SECURED ...... 5
9. STORAGE OF PERSONAL DATA ...... 5
11. YOUR RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY ...... 6
12. CHANGES TO THIS INFORMATION ...... 6
13. CONTACT US ...... 6
1 5569832.4 1. INTRODUCTION
1.1 This Privacy Notice provides guidance and information to editorial contributors to Mediahuis Ireland (including, but not confined to, Mediahuis Ireland Limited and Mediahuis Sunday Newspapers Limited) (“Mediahuis”) regarding the processing of personal data by Mediahuis (hereinafter “Mediahuis”, “us”, “we”, or “our”).
1.2 For the purposes of this Privacy Notice "Mediahuis" shall mean Mediahuis Ireland Group Limited plus any subsidiaries thereof and "subsidiaries" has the meaning given to it by section 7 of the Companies Act 2014.
1.3 Mediahuis is committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which any personal data we collect from or about you or that you provide to us will be processed by us. Please read this Privacy Notice carefully to understand our treatment and use of your personal data.
1.4 In this Privacy Notice, references to “you” mean the person whose personal data we collect, use and process.
1.5 We will use your personal data only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of your personal data is in compliance with the Data Protection Act 2018.
1.6 Please note that all contributors to the Irish Independent, Sunday Independent, Sunday World and Herald should familiarise themselves with the Editorial Code of Practice (available when you log into the Online Contributor System) with regard to your data protection obligations, among other things.
1.7 We seek to maintain the privacy, accuracy, and confidentiality of data (including your personal data) that we collect and use concerning our contributors and contractors.
2. IDENTITY OF THE DATA CONTROLLER
2.1 For the purposes of Data Protection Legislation, the Data Controller is the relevant Mediahuis Group entity with whom you are engaging, which may include as appropriate:
Mediahuis Ireland Limited, a private company limited by shares and registered in Ireland (Registered Number 153066) and having its registered office address at Independent House, 27-32 Talbot Street, Dublin 1;
Mediahuis Sunday Newspapers Limited, a private company limited by shares and registered in Ireland (Registered Number 40265) and having its registered office address at Independent House, 27-32 Talbot Street, Dublin 1;
Mediahuis UK Ltd, a private company limited by shares and registered in the UK (Registered Number 1908967) and having its registered office address at 39 Welbeck Street, London, W1G 8DR;
Mediahuis Ireland Digital Limited, a private company limited by shares and registered in Ireland (Registered Number 247783) and having its registered office address at Independent House, 27-32 Talbot Street, Dublin 1;
Mediahuis Ireland Regionals Limited, a private company limited by shares and registered in Ireland (Registered Number 04329) and having its registered office address at Independent House, 27-32 Talbot Street, Dublin 1;
2.2 Mediahuis and its affiliated companies will be referred to collectively as the “Mediahuis Group”.
2 5569832.4 3. CONTACT DETAILS OF THE DATA PROTECTION TEAM
3.1 The contact details of the data protection team appointed in respect of Mediahuis are as
follows: Email Address: [email protected] Address: Mediahuis Data Protection Team, 27-32 Talbot St, Dublin 1, Ireland
4. WHEN DOES THIS PRIVACY NOTICE APPLY
4.1 This Privacy Notice applies to personal information that we collect, use and otherwise process about you in connection with your relationship with us as an editorial contributor or contractor.
5. PROCESSING OF YOUR PERSONAL DATA
5.1 How and why do we process your personal data?
The personal data we collect from or about you or through our systems helps us manage our contractual or editorial relationship with you, e.g. for payment of your contributors fee, but also to comply with our legal obligations or for the conduct of our business. The personal data we collect, the basis of processing and the purposes of processing are detailed below.
Sometimes, these activities are carried out by third parties, including other members of the Mediahuis Group (see “Sharing of Personal Data” section below).
Personal data Basis of processing Purpose of processing
Financial or other It is necessary for the This is required to enable administration data (name, performance of our contract Mediahuis to administer the login, photo, private contact or relationship with you, or contractual or financial details, address, emergency to take steps for entering relationship with you, contact data, gender, marital into our contract or including the set-up of the status, date of birth, data on relationship with you. online contributor payment education, professional system. In the case of experiences and photos, to enable publication qualifications (as provided for journalistic purposes or during the application for ‘picture bylines’. process), social security ID, contributor contract type, fee, performance review data, travel expenses, data)
Accounting data (contributor It is necessary for us to pay This is required to enable fee, bank details) you, or to comply with our Mediahuis to process legal obligations. your contributor fees.
Health data (sickness, It is necessary for the Sickness may need to be incapacity to work, data performance of our contract processed for administration related to work accidents) with you and/or to comply purposes; information with our legal obligations. related to incapacity to work or limitations to work needs to be processed to protect your health. Work accidents need to be reported to the competent authorities and social security bodies. Data on work incidents that may encompass health data is processed for compliance reasons and to make your workplace safer.
3 5569832.4 Personal data Basis of processing Purpose of processing
Security Data (access It is necessary for us to This is required for the control, video surveillance comply with a legal security of our premises, the data “CCTV”) obligation and to protect the protection of our Employees vital interests of you or other and contributors/contractors, individuals. as well as theft prevention and in general for compliance with legal, regulatory and other good governance obligations.
5.2 Where does Mediahuis obtain my personal data from?
Most of the personal data we process is obtained from you when you sign a contract with us or sign up to the Online Contributor Payment system but we also obtain personal data about you in the course of the performance of your work (for example, communications with commissioning editors).
In some circumstances, we may request your explicit consent to process (specific types of) personal data. In these circumstances, you are able to withdraw your consent at any time by following the instructions provided when you gave consent or at the contact details below.
6. SHARING OF PERSONAL DATA
6.1 Our Group Companies
Personal data will only be shared across the Mediahuis Group in certain circumstances and where lawful to do so, i.e. it may be necessary to share your personal data with other members of the Mediahuis Group, which includes our ultimate holding company and its subsidiaries for the purposes of our business management, including workforce management and administration, management information, forecasting and other related functions. Your personal data will in particular be shared with:
Mediahuis Ireland Limited Mediahuis Sunday Newspapers Mediahuis UK Ltd Mediahuis Ireland Digital Limited Mediahuis Ireland Regionals Limited
Access rights between members of the Mediahuis Group are limited and granted only on a need to know basis, depending on job functions and roles.
6.2 Service Providers
We use third party service providers who provide services including the Online Contributor Payment system, Editing services and IT services. In providing the services, your personal data will, where applicable, be processed by the service provider on our behalf.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal data. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal data and their compliance with our data security standards and international transfer restrictions.
6.3 Disclosures to Third Parties
In certain circumstances, we share and/or are obliged to share your personal data with third parties outside the Mediahuis Group, for the purposes described above and in accordance with Data Protection Legislation.
These third parties may include:
financial institutions and our financial advisers;
4 5569832.4 companies that process payments to you or claims by you on our behalf; external professional advisers; auditors - to comply with legal requirements; revenue - who may share information with the tax authorities of other countries; our legal advisers - for advice and interpretation of law and regulations in connection to your pension; government bodies and law enforcement organisations - for the purposes of crime prevention and compliance with regulatory requirements; relevant industry bodies and regulatory authorities; at your request, with an independent financial adviser - so that they can advise and provide their services to you; travel companies if required; and Others, which may include: landlords, embassies (where it is permitted by law, or where we have your consent), event companies, promotion companies.
7. TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA
7.1 Your personal data may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”), for example, when one of our third party service providers use employees or equipment based outside the EEA. For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation.
7.2 We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, for example we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU Commission’s model clauses.
7.3 If you would like to see a copy of any relevant provisions, please contact our data protection office (see “Contact Us” section below).
8. HOW IS MY PERSONAL DATA SECURED
8.1 Mediahuis operates and uses appropriate technical and physical security measures to protect your personal data.
8.2 We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with our relationship with you. Access is only granted on a need-to-know basis to those people whose roles require them to process your personal data. In addition, our service providers are also selected carefully and required to use appropriate protective measures.
9. STORAGE OF PERSONAL DATA
9.1 We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. This may mean that some personal data is held for longer than other personal data. The criteria we use to determine data retention periods for personal data includes the following:
9.1.1 Retention in case of queries; we will retain it for a reasonable period after the relationship between us has ceased;
9.1.2 Retention in case of claims; we will retain it for the period in which it may be enforced (this means we will retain it for 7 years in some instances); and
9.1.3 Retention in accordance with legal and regulatory requirements; we will consider whether we need to retain it after the period described in 9.1.2 because of a legal or regulatory requirement.
9.2 If you would like further information about our data retention practices, please contact our data protection office (see “Contact Us” section below).
10. YOUR RIGHTS
5 5569832.4 You may have various rights under Data Protection legislation. These may include (as relevant):
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive information about the data we hold about you.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
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 exercised your right to object to processing (in certain circumstances).
Object to processing of your personal data where we are relying on a legitimate interest for processing (or a legitimate interest of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Data Portability of your personal data. Subject to certain conditions you are entitled to receive the data which you have provided to us and which is processed by us by automated means, in a commonly used machine readable format.
10.1 If you would like to exercise any of the above rights, please contact our data protection office (see “Contact Us” section below). Requests should be made in writing and we will respond to you within 30 days in line with regulation.
11. YOUR RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
11.1 If you want help to understand our Privacy Notice, or if you have any questions or queries, please contact Data Protection Office at [email protected] or alternatively you can write to us at Mediahuis Data Protection Office, 27-32 Talbot St, Dublin 1 Ireland.
11.2 If you are unhappy about any aspect of the way we collect, share or use your personal data, please let us know using the contact details above.
11.3 You also have a right to complain to the Office of the Data Protection Commission at Canal House, Station Road, Portarlington, Co. Laois by telephone at 1890 25 2231 and/or by email to [email protected]. For complaints in Northern Ireland you can contact the Information Commissioners Office, 14 Cromac Place, Belfast, BT7 2JB by telephone at 028 9027 8757 and/or by email at [email protected]
12. CHANGES TO THIS INFORMATION
12.1 We may need to make changes to this Privacy Notice. If we make any material changes to how we collect your personal data, or how we use or share it, we will update the Privacy Notice and notify you of these changes.
13. CONTACT US
13.1 For further information or if you have any questions or queries about this Privacy Notice, please contact our Data Protection Office at [email protected] or alternatively you can write to us at Mediahuis Data Protection Office, 27-32 Talbot St, Dublin 1 Ireland.
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