Privacy Statement
Updated 3 June 2022
Acceptance of this Privacy Statement
Contact the Data Protection Office
When visiting an Independent News and Media (INM) site or using one of our services, you’re trusting us with your information. We know that this is a big responsibility and we work hard to protect your information and put you in control.
At INM we seek to maintain the privacy, accuracy, and confidentiality of all data (including your personal data) that we collect and use as part of our services.
We will use your personal data only for the purposes described below and in full compliance with the GDPR Data Protection Legislation.
The purpose of this privacy statement is to explain how INM, in our capacity as a data controller, collect and use your personal information.
As Ireland’s largest media company, INM reaches millions of people each week across print and online. INM is a group of companies that has a number of online sites and services including Independent.ie, Sunday World, our Regional Titles and BelfastTelegraph.co.uk.
List of our Regional Titles:
This Privacy Statement applies to https://www.independent.ie, Sunday World, and our Regional titles. Other sites in the INM Group, have their own privacy statement.
INM provides a range of services through this site. We describe these in detail in this statement but basically, we provide services under the following broad headings.
Content: We provide the content that you view on our sites, and often fund the creation of this content by allowing advertisers to present you with relevant ads. You may choose to opt out of these personalised advertising services by means which we describe in the Advertising section.
Registrations: Certain services are only available to registered users. For example, some of our newsletters, some of our competitions and access to certain selected articles. We make registering for these services as easy as possible, enabling you to use Social Login providers such as Facebook and Google.
Subscriptions: INM makes certain services available through subscriptions. For example, the Irish Independent is available as an ePaper subscription here. Other INM titles are available elsewhere on our sites through other subscriptions.
Site Function: We use analytics providers in order for us to understand our audience, the content that appeals to them and how well our site is working. We also provide tools from the major social networks (Twitter, Facebook etc.) to allow you to share content from our site.
Mobile Apps and other channels: We also provide our content through a variety of other channels including apps, Twitter, Facebook etc. The services and content that we offer through these channels may differ and we provide details of how best to manage them. Platforms such as Facebook have their own privacy controls and you should frequently review your privacy settings there.
By using this Site and by disclosing your Data to us, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement.
When you visit our sites or use our services in any way we may collect and process different types of information about you. We have set out below the different types of data that we process, why and how we process it.
Content
Our stories and our audience are the key to everything we do here at INM. We fund our online journalism in part through advertising.
Advertising
Third-party vendors, including Google, display advertising on our site and services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site and other sites. This type of behavioural advertising is targeted towards groups of users in an aggregated manner. Such online advertising helps support the content, products and services we provide.
Our cookie policy provides links to manage your settings with these ad providers.
Ad Blocking
N.B. We provide an ability for you to set your privacy preferences on all modern browsers. However some older browsers do not support the technology required to deliver this privacy service. We suggest that you should always update your browser to the latest recommended version to ensure that you benefit from all security and privacy benefits
Since advertising plays a key role in supporting our journalism, our websites use ad block detection technology to detect the use of ad blocking software in your browser. It does not collect, store or process any personal information but asks you to turn the blocking software off.
Processing for journalistic purposes
As a news publishing organisation, INM processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes. It is recognised that this is in the public interest.
It is important to understand that certain rights which you have in relation to your personal information, including the right to erasure, may not apply where that data is processed for journalistic purposes.
Certain services are only available to registered users. Examples of these are newsletters, competitions and access to certain selected articles. We make registering for these services as easy as possible, enabling you to use Social Login providers such as Facebook and Google.
Sign up
When you sign up or register with INM to avail of a service we collect only the information needed to provide that service.
What we process:
Why we process this data: The legal basis for processing this data is to enable us to deliver registration services that you have consented to.
The personal identifier allows us to recognise you when you come to our site or service. This enables us to provide you with the service that you signed up for. For example, access to special articles, viewing your newsletter preferences etc. Details of these specific services are provided elsewhere on this page.
Who has access: Customer registration identity information is only ever accessible to INM employees though sometimes aggregated statistics about usage may be made available to others. For example, we might state to the market that we have a certain number of registered users who access Independent.ie.
Access may be granted to our registration system provider in order to resolve problems but only under the strictest governance by INM. INM ensures that our registration provider, adheres to the highest standards of data protection and privacy.
Your data may also be shared with a 3rd party if you choose to avail of a service from that 3rd party but only with your consent.
Delete My Account and associated data: If you wish to delete your Independent.ie account and all associated personal data (as defined under GDPR, Article 4), please email [email protected] and request that your account is deleted.
Social Sign Up
We also provide the ability to sign up or sign in using social login services such as Google, Apple and Facebook. It's a faster way to log in and saves you the pressure of having to create and remember countless different usernames and passwords.
What we process:
Why we process this data: The legal basis for processing this data is to enable us to deliver services that you have consented to receive.
The personal identifier allows us to recognise you when you come to our site or service and provide you with the service that you signed up for. For example, access to special articles, viewing your mail preferences etc. Details of these specific services are provided elsewhere on this page.
Who has access: You are always in control of what data we can access, and you can change this through your Google, Apple or Facebook account preferences. We never have access to your Google or Facebook account or password.
Delete My Account: If you remove Independent.ie from your Google Settings, Apple or Facebook Settings we will no longer have access to the information you previously chose to share with us. Similarly, you can delete the Google, Apple or Facebook account that you used to sign in to the Independent.ie in my account page on the Independent.ie. If you wish to delete your Independent.ie account entirely please request same via our secure Privacy Portal.
What we process:
Why we process this data: The legal basis for processing this data is to enable us to deliver services that you have consented to receive.
This registration data allows us to provide you with access to various INM sites with as little hassle as possible. It also allows us to understand which of these services are of interest to you so that we can provide you with a better service.
Who has access: Customer registration identity information is only ever accessible to INM employees. Sometimes aggregated statistics about usage may be made available to others. For example, we might state that we have a certain number of registered users who access Indpendent.ie.
Access may be granted to our Registration system provider in order to resolve problems but only under the strictest governance by INM. INM ensures that our registration provider, adheres to the highest standards of data protection and privacy.
Newsletters
All readers who register, will also receive the Daily Digest/Irish Local News newsletters seven days a week. These newsletters are a selection of our latest stories delivered each morning. Readers can unsubscribe at any time, by clicking the unsubscribe link at the bottom of each newsletter or going to 'My Account'.
We also offer to our readers the ability to sign up to a variety of newsletters. When you sign up for newsletters, we collect information to enable us to deliver the newsletter and to tell us what content you are interested in.
What we process:
Why we process this data: The legal basis for processing this data is to enable us to deliver the newsletters that you have consented to receive.
This identity and interest data help us deliver the newsletters that you have requested. The interaction data allows us to understand which parts of the newsletter and which content interest you to enable us to improve the service that we deliver to you.
Who has access: Only INM employees will have access to this data through our email and customer identity systems. Access may be granted to third parties such as our email campaign provider in order to resolve problems sending emails etc. but only under the strictest governance by INM. INM ensures that our email campaign provider adheres to the highest standards of data protection and privacy.
Competitions
When you enter a competition on an INM site or through an INM publication such as the Independent.ie, we may collect data about you or your entry in order to manage the competition and enable us to deliver the prize to you if you are lucky enough to win.
Entering a competition
When you enter a competition, we need to process your entry.
What we process:
Why we process this data: The legal basis for processing this data is legitimate interest. In order to decide the competition winner, it is necessary for us to process your entry. This data is required to enable INM to contact winners and manage the competition.
Who has access: This data will only be processed by INM employees and systems, and sub contracted service providers for the sole purpose of managing the competition.
The only exception to this is where a 3rd party is sponsoring the competition and requests to get access to your information. Information will only be shared with this 3rd party with your consent and this will be made clear to you before submitting your competition entry to ensure that you have full control of who sees your data.
Delete my competition entries: If you wish to delete any competition entries that you have made please make your request via our secure privacy portal by clicking the following link: Data Subject Request Form.
and request that you wish to have your competition entries deleted.
Winning a competition
If you are lucky enough to win a competition, then we need to contact you to ensure delivery of your prize and know where to send it.
What we process:
Why we process this data: The legal basis for processing this data is our contract with the winner to deliver the prize to them.This data is required to enable INM to contact winners and deliver the prize to them
Who has access: This data will only be processed by INM employees and systems, and sub contracted service providers for the sole purpose of delivering the prize to the winner. When a 3rd party is sponsoring the competition and providing the prize it is necessary to provide them with the winner’s personal data in order to enable them to deliver the prize to the winner.
The only exception to this is where a 3rd party is sponsoring the competition and requests to get access to your information. Information will only be shared with this 3rd party with your consent and this will be made clear to you before submitting your competition entry to ensure that you have full control of who sees your data.
Delete my competition entries: If you wish to delete any competition that you have made, please do so via our secure privacy portal by clicking the following link: Data Subject Request Form.
Quizzes, Surveys and Polls
When you enter a quiz or answer a poll or survey on an INM site we collect data about you and your response.
What we process:
Why we process this data: The legal basis for processing this data is your consent for us to process your response to the poll or survey that you have entered.
This data is required to enable INM to display the results of the poll or survey. No poll data is ever associated with your email or other personal identifier.
We do record whether you have interacted with the poll or survey to ensure that duplicate entries are not counted but this is linked to your browser or device and never contains information on your poll response.
Who has access: This data will only be processed by both INM employees and systems, sub contracted service providers for the sole purpose of managing the quiz, survey or poll.
The only exception to this is where a 3rd party is running or sponsoring the quiz, survey or poll. This will be made clear to you, along with what happens to your data before submitting your entry to ensure that you have full control of who sees your data.
Delete my quiz, survey or poll entries: If you wish to delete any quiz, survey or poll entries that you have made on Indpendent.ie, please make your request via our secure privacy portal by clicking the following link: Data Subject Request Form.
Award Nominations
When you submit a nomination for one of our awards on an INM site we may collect data about you or your entry in order to facilitate judging, contact the shortlist, appoint a winner, showcase winning entries at the event and create follow-up media coverage of the event in print and online, and if the event is televised, on TV. Winners’ data will be stored for 12 months after the awards for purposes of publicising the following year’s event.
Entering an award
When you enter one of our awards, we need to process your entry.
What we process:
Why we process this data: The legal basis for processing this data is legitimate interest. In order to decide the award winner, it is necessary for us to process your entry. This data is required to enable INM to contact nominees and manage the awards.
Who has access: This data will only be processed by INM employees and systems, and sub contracted service providers for the sole purpose of managing the competition. Information provided to judging panels will be anonymised.
The only exception to this is where a 3rd party is sponsoring the awards and requests to get access to your information. Information will only be shared with this 3rd party with your consent and this will be made clear to you before submitting your entry to ensure that you have full control of who sees your data.
Delete my award entries: If you wish to delete any award entries that you have made please email [email protected] and request that you wish to have your entries deleted.
Being shortlisted or winning an award
If you are lucky enough to be shortlisted or win an award, then we need to contact you to ensure that you are available for the ceremony and promotional activities. We may ask for your consent to share your personal data with another media partner.
What we process:
Why we process this data: The legal basis for processing this data is our contract with the entrant to put forward their submission for consideration in our awards.This data is required to enable INM to contact shortlisted parties/winners and arrange for them to attend awards ceremonies and partake in associated promotional activity.
Who has access: This data will only be processed by INM employees and systems, and sub-contracted service providers for the sole purpose of arranging attendance at the awards and associated promotional activity.
We may ask for your consent to share your personal data with another media partner in order to facilitate interviews and video coverage. Information will only be shared with this 3rd party with your consent and this will be made clear to you before submitting your entry and when we contact you to let you know you have been shortlisted to ensure that you have full control of who sees your data.
Delete my award entries: If you wish to delete any award entries that you have made, please make your request via our secure privacy portal by clicking the following link: Data Subject Request Form.
INM makes certain services available through subscriptions. For example, the Irish Independent is available as an ePaper subscription here. Other INM titles are available elsewhere on our sites through other subscriptions.
ePaper Subscriptions
INM provides a service that allows you to sign up for the ePaper through the Independent.ie site. It is a co-branded service operated Reach Home Delivery. We collect personal information to allow us to deliver these services.Terms of use for the service are available here .
What Reach processes:
Why Reach processes this data: The legal basis for processing this data is to enable us to fulfil our contract to deliver and manage the ePaper subscription that you have signed up for.
The personal identifier allows Reach to recognise you when you come to our branded site or service and provide you with the correct benefits that you signed up for. The other data allows Reach and INM to manage that service and ensure that you get all the benefits that you have subscribed to receive.
Who has access: At no time is your information shared with other 3rd parties without your consent. We recognise that your payment details are particularly sensitive, and we use specialist companies to handle subscription processing.
Occasionally, our employees receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately.
Full details and terms and conditions are available for viewing when you subscribe to one of our services.
Our ePaper is provided by a 3rd Party. When you go to access the ePaper via their website you will be asked to login. Further detailed information will be made available from the subscription processor at the point when you subscribe for an ePaper.
Delete my subscription: If you wish to cancel your paid subscription, please follow the instructions here.
We use analytics providers in order for us to understand our audience, the content that appeals to them and how well our site is working. We also provide tools from the major social networks (Twitter, Facebook etc.) to allow you to share content from our site.
Analytics
Analytics tools allow us to understand how our audience interacts with our site and our content and enables us to provide a better service to our site visitors. We do not collect or process any personal information in our analytics platform.
What we process:
Why we process this data: The legal basis for processing this data is the legitimate interests of INM to manage and optimise the running of our site and its content.
This data helps us optimise the way the site is structured and how content is arranged on the site. It also allows us to show interested parties how many people access the different parts of our site and on average how often they visit. This allows understanding of how many people look at our content at different times of the day etc. These statistics are always calculated on an aggregated basis – never individually. We use the data for future marketing and personalisedAdvertisement
(https://support.google.com/analytics/answer/2700409?hl=en-GB&utm_id=ad).
Who has access: Anonymised versions of the data are hosted on Google Analytics and the Adobe Analytics platform. At no point do we have access to personally identifiable information through Google Analytics. Adobe Analytics does store your IP address in order to be able to tell users apart. Anonymous aggregated reports about the general behaviour of our audience may be made available to the public, or advertisers, or others.
Stop being tracked: These analytics tools run on most sites across the web. If you wish to opt out of analytics tracking you must do so on these 3rd party sites or by changing your browser settings. Click on a link below to see the privacy policy and manage your consent across the web for each cookie type:
Further information can be found in our cookie policy.
Social Sharing
Our website and mobile applications use interfaces with social media sites such as Facebook, LinkedIn, Twitter and others.
If you choose to like or share information from our sites through these services, you should review the privacy statement of that service. If you are a member of a social media site and logged in, the interfaces configured on our Services allow the social media site to connect your site visit and browsing behaviour to the personal data held on your social media site. INM can use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.
Where links are provided on the site to other websites, INM bears no responsibility for such sites. These sites are not under our control and we are not responsible in any way for any of their contents.
Where links are provided to websites that process your data. INM will not be privy to any processing that occurs and accepts no responsibility in relation to the processing of your data by these third parties.
The following sections refer exclusively to content on Mobile Apps.
Mobile App Analytics
We do not collect process or store any personal information on our apps. However, we do collect anonymous browsing and analytics data.
What we process:
Why we process this data: The legal basis for processing this data is the legitimate interests of INM namely to manage and optimise the running of our site and apps and their content.
IP addresses are used solely to distinguish between individuals visiting our site. IP addresses are never used to personally identify an individual and never combined with other registration data.
This analytics data helps us optimise the way our content is structured and how content is arranged on our sites and apps to provide a better service to you.
Who has access: Anonymised versions of your browsing data are hosted on Google Analytics and Adobe Analytics platform. Only INM employees or our analytics partners have access to this information.
We use push notifications to inform you about breaking news, live event coverage and other top stories on our apps. We do not process any personal information and cannot establish the identity of the users who have subscribed to receive these notifications. You may receive these notifications based on your location, operating device and/or interests that are derived from your use of our Services.
You can control your push notification and location settings directly on your mobile device. It should be noted that iOS devices operate on the basis of opting-in to push notifications whereas Android devices operate on the basis of opting out. If you wish to use this feature you will be asked to specifically consent to your data being used for this purpose. This is recorded in your phone’s notification settings. You can at any time turn off push notifications from us in your phone settings if you do not wish to receive further push notifications from us.
Your Rights Under Data Protection Law
You have several rights under data-protection law in relation to the personal information that INM holds about you. If you choose to exercise any of these rights, we will ask you to verify your identity. We will consider your request and provide a response within one month. These rights are described in detail on the Data Commissioner’s Website and summarised below:
You can complain directly to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois by telephone at +353 1890 25 2231 and/or by email to [email protected].
You can also make a complaint directly to the relevant data protection authorities in the country where you are ordinarily resident. For example, in the UK you can also complain directly to the ICO at https://ico.org.uk/make-a-complaint/ or call their helpline on 0303 123 1113.
How To Exercise Your Rights
Requests for information or to exercise these rights should be made to the INM Data Protection Office via our Data Subject Request Form housed on our secure privacy portal. Alternatively, you can also make your request:
If possible, you should specify the type of information you would like to see to ensure that we meet your expectations. We must be able to verify your identity in order to ensure the safety of your data. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other individuals and/or businesses.
Limitations To These Rights
These rights are in some circumstances limited by data-protection legislation. You may have various rights under Data Protection Legislation. However, in certain circumstances, these rights may be restricted (Article 23 of the General Data Protection Regulation, which is transposed into UK law by the Data Protection Act 2018 sets out the circumstances in which your rights may be restricted). Also the personal information that is processed as part of INM’s journalistic work may be exempt under Art 85 of the GDPR.
These rights are in some circumstances limited by Data Protection legislation. You may have various rights under Data Protection legislation. However, in certain circumstances these rights may be restricted by Data Protection legislation. Also the personal information that is processed as part of INM’s journalistic work may be exempt under Art. 85 of the GDPR and Section 43 of the Data Protection Act 2018.
In particular, your rights may be restricted where this is necessary:
The following sections describe how we manage, secure and control access to your data and under what circumstances we disclose data to others.
Retention Of Your Data
To make sure we meet our legal Data Protection and Privacy obligations, where yo are an account holder, we will retain your information for at least as long as your account is active, as needed to provide you services or as necessary to comply with our legal obligations, resolve disputes, protect our legal interests and enforce our agreements.
If you ask for your account to be closed we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with legal obligations protect our legal interests, prevent fraud, collect any fees owed or to resolve disputes.
As a matter of course, we will delete personal data associated with accounts that have been inactive for at least 6 years.
Where you are not an account holder, we will retain your information for so long as is necessary to fulfil the purpose for which it is processed or for such longer period as is required to comply with our legal obligations, resolve disputes, protect our legal interests and enforce our agreements.
Sharing Data With 3rd Parties
We use third party service providers who work for us in the provision of our services. Your data may be processed by a third party if required to deliver a service you have requested or as otherwise set out in this Privacy Statement.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your Data.
We will have written contracts with them which provide assurances regarding the protections that they will give to your Data and their compliance with our data security standards and international transfer restrictions.
We also share data with other INM entities within the group where they are providing you with services that you have requested or where they provide services to us that you have requested or as otherwise set out in this Privacy Statement.
How Is Your Data Secured
INM operate and use appropriate technical and physical security measures to protect your personal data.
We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. In addition, our service providers are also selected carefully and required to use appropriate protective measures.
Where Do We Store Your Data?
In most cases, INM stores your data securely within the European Economic Area (EEA) using GDPR compliant service providers.
In some cases, INM may have to transfer or store your data to countries outside the EEA, for example, when one of our 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. 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, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.
Disclosure Of Your Data
Your Data is private and confidential. Your Personal data may only be shared within INM, for any of the purposes set out in this Privacy Statement.
From time to time, we may access and/or disclose your Data as set out in this Privacy Statement or if we are required to do so by law or in good faith and belief that such action is necessary to:
Changes to this Information
This statement is effective from: 9 September 2020
We may decide to make changes to this Privacy Notice. If it’s a fundamental change in how we deal with you, then the updated Privacy Notice will be provided to you well in advance of the change actually taking effect.
We will post the changes on our website or send them to you via e-mail along with an explanation of what the likely impact of those changes will be to you, if any.
In order to ensure fairness of the processing, we encourage you to review the content of this Privacy Notice regularly.
If you are unhappy with how we use your personal data
By using this Site and by disclosing your Data to us, you understand that we may collect, store, process, use and disclose your Data as described in this Privacy Statement. If you are not comfortable with any aspect of this Privacy Statement, you can discontinue using our Site or not provide us with any further personal data. We reserve the right to modify this Privacy Statement at any time.
Contact the Data Protection Office
INM has a data protection function including a Data Protection Officer. If you wish to invoke your rights or have any questions please contact the INM Data Protection Office via our secure privacy portal by clicking the following link: Data Subject Request Form.
Alternatively you can contact us by post or by email:
INM Data Protection Office
Independent News and Media PLC
Independent House
27-32 Talbot Street
Dublin 1
Email: [email protected]