CONTACT DETAILS
If you have any questions about this Data Protection Statement or the way in which your Personal Data is being used by us please contact:
Data Protection Officer
3 Ballyknockan Road
Saintfield
County Down
BT24 7HG
Email: [email protected]
Telephone: 1890 886001
1. ABOUT MCLERNONS
This Data Protection Statement applies to the following companies in the McLernon group:
McLernon Computers (NI) Ltd
McLernon Computers Limited
References to “We”, “Us” the “Company” and “McLernons” shall apply to the company in the group that is processing your Personal Data.
McLernon Computers provides software systems and solutions to pharmacies all over Ireland and the UK. We were born from McLernon Packaging Company in 1982 when the grandsons of Sam McLernon identified a new opportunity to help pharmacies by improving their dispensing systems. We have grown to become the market leader in Ireland, both North and South, providing solutions to over 1,500 customers and employing more than 55 people in three different office locations.
We are registered in the UK (NI) and the Republic of Ireland as McLernon Computers Limited (NI: NI024667, ROI: 95709).
In order to provide our services and manage our business, we need to process Personal Data. We are committed to protecting the rights and personal data of individuals in accordance with data protection legislation including the General Data Protection Regulation in Europe (the “GDPR”). Our role in connection with any patient data processed using our software is generally as processors. The pharmacy is as controller of patient data.
2. THE PURPOSE OF OUR DATA PROTECTION STATEMENT
This Data Protection Statement describes our approach to data protection and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that personal data for the purposes of the GDPR. Please read this Data Protection Statement carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it.
The protection of your personal data is important to us and we are committed to protecting and safeguarding your rights.
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3. WHO THIS DATA PROTECTION STATEMENT APPLIES TO
This Data Protection Statement provides specific information relating to the following data subjects whose Personal Data we process:
- business contact details including those of our customers, suppliers, partners, shareholders and business prospects “Business Contacts”;
- users/visitors to our Website “Website Users”; and
- prospective employees /those applying for jobs at McLernons “Candidates”; and
- members of the public who pass by and/or visit McLernons offices and whose images are captured on CCTV “Visitors”;
Personal Data of employees is dealt with in a separate internal data protection notice.
4. CATEGORIES OF PERSONAL DATA
We process the following categories of Personal Data. For each category we have included an example of the type of Personal Data that maybe part of that category:
| Personal Data Category | Description |
| Identification Data | may include a person’s name, date of birth, driver’s license and passport information. |
| Contact Data | may include a person’s email address, phone number, postal address, other communication details (e.g. Skype) |
| Communication Data
|
may include phone calls, email correspondence and hard copy correspondence. This includes when you use forms on the website such as the “Call me back” and “Book a Demo” contact forms, and when you contact our customer support team. |
| Marketing Data | may include your Contact Data and any preferences in receiving marketing from us and your communication preferences. |
| Recruitment Data
|
may include recruitment related data such as Identification Data, Contact Data, Communication Data, CV and job application data.
This may include employment history, skills/ experience, languages, educational history, qualifications, membership of professional associations, contact details of employer references/character references, licenses held, interests and hobbies, languages, locations, nationality, passport, eligibility to work in certain jurisdictions, salary expectations, interview/screening answers and notes. |
| Financial Data | may include payment related information or bank account details and financial data received as part of the services that we provide.
|
| Special Category Recruitment Data | If we interact with you for the purposes of a job with the Company, we may collect Recruitment Data that is of a special category per the GDPR definition: this can include diversity data such as gender, religion, racial or ethnic origin, sexual orientation, trade union membership or data relating to health. We will only source this data with the explicit consent of Candidates. |
| CCTV Data | We operate CCTV cameras at some of our premises. If you pass by and/or visit some of McLernons’ premises, your image may be recorded on CCTV |
| Web Data | may include Personal Data provided on any forms on our website and, to the extent that it includes Personal Data, information on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. |
5. OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA
All processing of Personal Data must be lawful. Processing will only be lawful if we have a legal basis for processing. When the Company processes Personal Data it is generally on one of the following legal basis:
Contract
We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract
Consent
For certain processing activities we may rely on your consent. For example, a Candidate may give us their consent to process their Personal Data when they apply to a position advertised on our website.
Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.
You can withdraw consent provided by you at any time by contacting us at [email protected]
Legitimate Interest
At times we will need to process your Personal Data to pursue our legitimate business interests, for example for administrative purposes, to collect debts owing to us, to provide information to you, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights.
We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweigh our legitimate interests.
If do not want us to process your Personal Data on the basis of our legitimate interests, contact us at [email protected] and we will review our processing activities.
Legal Obligation
If we have a legal obligation to process personal data, such as the payment of taxes, we will process personal data on this legal ground.
6. OUR PROCESSING ACTIVITIES
We use Personal Data to provide you with our services and to assist us in the operation of the company. Under data protection law, we must ensure that the purpose of processing is clear.
We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing:
| Purpose of Processing | Categories of Personal Data | Lawful Basis |
| Relationship Management including:
· to manage/respond to a complaint/appeal · for requests for service or product information/demo · to provide support services, take remedial actions, and to update our products/services as provided · to send notifications about changes/updates to our products/services · to fulfil our legal and contractual obligations · to follow up on payments |
· Contact Data
· Communications Data · Identification Data · Financial Data
|
· Legitimate Interests
· Contract |
| Marketing and Sales activities:
· to send newsletters and other information that may be of interest · to contact you as part of our business relationship or for lead generation and general administration · to inform you of events, tradeshows or webinars that might be of interest · to respond to any requests from you
|
· Contact Data
· Communication Data · Marketing Data · Web Data |
· Legitimate Interests
· Consent |
| Recruiting staff including:
· to interview the Candidate · to manage our database of Candidates · to contact you in connection with any job position we may have open · to check your suitability for the role · to fulfil the recruitment needs of the business.
|
· Identification Data
· Contact Data · Communications Data · Recruitment Data · Web Data · Special Category Recruitment Data |
· Legitimate Interests
· Consent · Contract |
| Website delivery including:
· to manage and respond to web forms · to promote our products and services · to administer the Website · for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes · to ensure the safety and security of our website and our services.
|
· Web Data
· Contact Data |
· Legitimate Interests
· Consent |
| Ensuring security of the McLernons premises | · CCTV Data | · Legitimate Interests |
| Management of Corporate Affairs
· to take minutes at board meetings · to contact shareholders/investors · to enter into partnerships and other commercial relations · to undertake appropriate due diligence
|
· Identification Data
· Contact Data · Communication Data · Financial Data |
· Contract
· Legitimate Interest · Legal Obligation |
7. SOURCES OF PERSONAL DATA
BUSINESS CONTACT PERSONAL DATA
We collect Business Contact Personal Data from our business contacts including – customers, suppliers, partners, consultants shareholders and business prospects.
We source Business Contact Personal Data in order to serve the business relationship. We will only ever source Personal Data that is necessary and in a way that would be generally expected.
We receive Personal Data about Business Contacts from a variety of sources, as follows:
- the Personal Data is often provided by the Business Contact as part of the business relationship;
- the Personal Data may be collected from public sources;
- the Personal Data may be collected indirectly from another person within the company of the Business Contact;
- the Personal Data may be collected through our website;
- the Personal Data may be collected from another company in the group;
- the Personal Data may be collected indirectly from a website or from a third party.
CANDIDATE PERSONAL DATA
We will only ever source Personal Data in a way that would be generally expected.
We receive Personal Data relating to Candidates from a variety of sources. The primary source is from Candidates directly. Examples of the sources of Personal Data of Candidates are as follows:
- the Candidate may send their CV to us with the intention of registering with us to be informed of potential job vacancies;
- the Candidate may apply directly to a position advertised on our website;
- the Candidate may apply to a position advertised on a third-party jobs’ website;
- the Candidates details may be provided by a member of staff or third party by way of referral; and
- the Candidates details may be provided by an recruitment agency.
WEBSITE USERS PERSONAL DATA
We may collect Website User information from all visitors to our web site www.mclernons.ie in order to improve our services and develop the Website.
For more details please refer to our Cookie Statement.
CCTV PERSONAL DATA
We may collect CCTV video footage of visitors to our premises.
8. DISCLOSURE OF PERSONAL DATA
In certain circumstances, we may disclose Personal Data to third parties as follows:
- to business partners and subcontractors for the performance of any contract relating to our services, including email, payment processors, hosting service providers, external consultants, auditors, IT consultants and lawyers;
- to other companies that form part of McLernons, such as between McLernons Computers NI and McLernons Computers ROI;
- to analytics and search engine providers that assist us in the improvement and optimisation of the Website. This consists of aggregated anonymous information only and relates to the web pages visited on the Website and not the information included on those web pages;
- if we or substantially all of our company is merged with another company or acquired by a third party, in which case Personal Data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have;
- to protect our rights, property, or safety, or that of our customers or Business Contacts or others. This may include exchanging information with other companies and organisations for the purpose of fraud protection.
More specifically we may share:
- information about our Business Contacts, their employees and others for the purpose fulfilling a business relationship;
- Personal Data with third party payment service providers for the purpose of processing payments related to the services we offer.
When we engage another organisation to perform services for us, we may provide them with information including Personal Data, in connection with their performance of those functions. We do not allow third parties to use Personal Data except for the purpose of providing these services.
9. SECURITY MEASURES
In particular, we have put in place appropriate physical, technical, and organisational procedures to safeguard and secure the Personal Data we process.
We will also take reasonable steps to verify your identity before granting access to information to protect the privacy and security of the Personal Data we process.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone.
If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately.
10.TRANSFERS OUTSIDE THE EEA
In order to provide our products and services we may need to transfer Personal Data outside the European Economic Area (EEA). We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.
If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission or the Privacy Shield in the case of transfers to the USA. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.
11.COOKIES
Cookies are small text files placed on your computer or mobile device by websites that you visit, and they help us improve the products and services that we offer you. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may allow a website to remember your activity over a period of time. Cookies are optional and you do not have to accept them.
Further information on the cookies we use on the website and the purpose behind their respective uses are set out in our Cookie Statement.
12.THIRD PARTY WEBSITES
Our Website may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings, and these are not endorsed by us. We do not accept any responsibility or liability for these third-party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.
13.RETENTION
In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.
Our retention policy is as follows:
| Purpose of processing | Categories of Personal Data | Retention Period |
| Relationship Management | · Contact Data
· Communications Data · Identification Data · Financial Data |
24 months after completion of service delivery activities in the case where there is no further meaningful engagement.
Certain Personal Data may be retained for 7 years |
| Marketing & Sales
|
· Contact Data
· Communication Data · Marketing Data · Web Data |
12 months in the case where no meaningful engagement or earlier in the case you unsubscribe. |
| Recruitment | · Identification Data
· Contact Data · Communications Data · Recruitment Data · Web Data · Special Category Recruitment Data |
12 months for unsuccessful candidates |
| Website Delivery | · Web Data Contact Data | 12 months or less |
| Security | · CCTV Data | 7 days |
| Management of Corporate Affairs | · Identification Data
· Contact Data · Communication Data · Financial Data |
7 years unless required to retain indefinitely |
In certain cases, we may retain Personal Data for longer than specified here if required under relevant laws.
14.YOUR RIGHTS UNDER THE GDPR
You have rights under data protection law in relation to how McLernons uses your Personal Data. You may generally access your rights free of charge.
You can ask for access to the Personal Data we hold on you
You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to all Personal Data we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.
We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.
We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.
You can ask to change Personal Data you think is inaccurate
You should let us know if you disagree with something included in your Personal Data.
We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
You can ask to delete Personal Data (right to be forgotten)
In some circumstances you can ask for your Personal Data to be deleted, for example, where:
- your Personal Data is no longer needed for the reason that it was collected in the first place
- you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
- there is no lawful basis for the use of your Personal Data
- deleting the Personal Data is a legal requirement
Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.
Please note that we cannot delete your Personal Data where:
- we are required to have it by law
- it is used for freedom of expression
- it is used for public health purposes
- it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
- it is necessary for legal claims.
You can ask us to limit what we use your Personal Data for
You have the right to ask us to restrict what we use your Personal Data for where:
- you have identified inaccurate information, and have told us of it
- where we have no legal reason to use that Personal Data, but you want us to restrict what we use it for rather than erase it altogether
When Personal Data is restricted it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.
You can make a complaint
You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.
15.AMENDMENTS TO THIS DATA PROTECTION STATEMENT
We will post any changes on the Website and when doing so will change the effective date at the top of this Data Protection Statement. Please make sure to check the date when you use our services to see if there have been any changes since you last used those services.
In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.
Thank you for reading our Data Protection Statement. Please Contact Us if you have any questions.
16.SUPERVISORY AUTHORITY
The Data Protection Commission in Ireland may be contacted using the contact details below if you have any concerns or questions about the processing of your Personal Data.
IRELAND – CONTACT DETAILS
Online Form: https://forms.dataprotection.ie/contact
Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Tel: +353 578 684 800 or +353 761 104 800
The Information Commissioner’s Office in the UK may be contacted as follows: