1. Personal Data Collection

Why do we collect personal data?

We collect and use personal data to optimise your experience with CMD Group and, with your consent, to help us perform direct sales, marketing, and customer service excellence.

When do we collect personal data?

We collect personal data about you when you interact with us for our services. This may be in person, by phone or through physical letters and / or documents. It also includes interaction via online channels (our websites, email, or social media channels).

What personal data do we collect?

• We may collect name, phone number, title and email address, in addition to your company’s name and contact information.
• We may also collect feedback, comments and questions received from you during our service-related communication and activities. This can include emails, phone calls, documents and meetings.
• We will collect data from you in connection with our various services – this data is provided to us in order to work with you in the following areas and at your request:
  • CV preparation
  • Interview Skills Preparation
  • Career Options Service

The information gathered at this point could include, name, address, date of birth, phone number, email address, work history, education history, memberships, achievements, work preferences. As you have paid for these services, such information will be stored by our Managing Partner on a PC in a private, locked office and on a secure server in the event that you lose your documents e.g. CV, Career Reports etc.

We may collect IP-address and actions taken on our websites.

If you upload photos or videos, add posts or comments, etc. on our social media sites, the information can be read by anyone with access to the these sites and used for purposes over which CMD Training Institute/CMD Group or you have no control. Therefore, CMD Training Institute/CMD Group is not responsible for any information you submit to our social media sites.

Personal Data and QQI Certification

This section applies only to those intending to achieve IITD, ILM or ATI certification through our courses.

CMD Training Institute/CMD Group collects, stores and processes special categories of personal data, such as Public Personal Social Numbers (PPSN) and sensitive personal data in the form of dates of birth, gender and home addresses. This information is required to be collected by us for any persons being submitted by us for certification to IITD, ILM or ATI QQI is an authorised data collector by the Department of Social Protection and Family Affairs and QQI has delegated these powers to us as a QQI quality-assured training provider. We only submit this information to IITD, ILM or ATI on your behalf and all data is securely deleted by us once submitted. Internal access to this data is restricted to only those individuals involved in collecting, storing and submitting the information to IITD, ILM or ATI.

Other data we collect

We also collect data about suppliers, partners and persons seeking a job or working in our company.

How long do we keep your personal data?

We store personal data for as long as we find it necessary to fulfil the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, your data will be anonymous.

What is our legal basis for collecting personal data?

Collecting personal data based on consents

The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracts

We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.

Collecting personal data based on legitimate interest

We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between Professional Development and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.

COOKIES

Cookies are strings of information which we may from time to time transfer to the browser on your computer’s hard disk to enable us to remember who you are when you return to the website. In addition, we use cookies to provide us with access to anonymised, aggregated statistics and analytics of our visitors using the Google Analytics platform and other Google Analytics services including Google Analytics Demographics and Interest Reporting, Remarketing. We may use cookies to enhance your enjoyment of our website and to improve our service to you. If you wish you can usually adjust your browser so that your computer does not accept cookies. Please note you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings. Alternatively, you may install the Google Analytics Opt-out Browser Add-on. If you do this, you will still be able to access our website but this may limit some of the functionality available to you. How you adjust your web browser will depend on which internet browser programme your computer uses.

Cookies do not contain information such as your home address, telephone number or credit card details and we will not disclose the content of cookies to any third parties.

2. Personal Data Use

We may use your personal data for the following purposes:

• To reply to web forms you have completed on one of our website for example: Sending an inquiry, downloading a brochure, booking a place.
• To carry out direct sales activities in cases where legitimate and mutual interest has been established.
• To send you marketing communications. We will only send you marketing communications if you have opted in to this service, and will always enable you to opt out at any time. Marketing communications may include information about our products and services, upcoming promotions, articles, and whitepapers.
• To send you information about the products and services that you have purchased from us.
• To provide you with relevant information about a course or event you have booked with us.
• To follow up on requests we have received directly via emails or phone calls.
• To carry out contractual obligations relating to your booking. This may incorporate booking confirmation, invoicing and payment, venue details, reminders, and similar.
• To ask for feedback about your experience with our services and products.

3. Personal Data Sharing

Do we share your data with anyone?   

Aside from what is outlined below, we do not share, sell, rent, or trade your information with any third parties without your consent:

Third-party Service Providers working on our behalf:

We may pass your information on to our partners, sub-contractors and other associated organisations with the purpose of them providing services to you on our behalf.

Third-party Product Providers we work in association with:

We work closely with various third-party product/service providers to bring you a range of products and services designed to meet your learning and development requirements. When you enquire about or purchase one or more of these products, the relevant third-party product provider will use your details to provide you with information and carry out their obligations arising from any contracts we have entered into with them on your behalf. In some cases, our third-party product providers will be acting as data processors of your information and, therefore, we advise you to read their Privacy Policy and sign a Data Processing Agreement. These third-party product providers will share your information with us, which we will use in accordance with this Privacy Statement.

Other Disclosure Instances:

We may disclose information about you to the extent that we are required by law, in connection with any legal or prospective legal proceedings, or in order to establish, exercise or defend our legal rights. If any of the above circumstances occur, we will however, make every effort to continue to protect your privacy.

Transfers Abroad

We use the services of a third-party provider, Hubspot, based in the United States to collect email addresses for direct marketing purposes. The safeguard we have in place is a contract we have entered in to with Hubspot, which includes the model clauses for EU GDPR compliance.

4. Your Website Visits (Cookies and Beacons)

We use cookies and web beacons (‘Website Navigational Information’) to collect information during your visits to our websites.

Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol (“IP”) address; and the actions you take on the company’s websites, such as the web pages viewed and the links clicked.

This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.

5. Security

We take precautions to protect your information. When you submit sensitive information via our website, your information is protected both online and offline.

6. Links

Our website contain links to other sites. We strive to ensure that the sites we link to are relevant and uphold stringent privacy policies. We are not responsible for the content or privacy practices of such other sites.

We encourage you to be vigilant when leaving our site and to read the privacy statements of any other site that collects personally identifiable information.

7. Your Rights to Your Personal Data

You have the following rights with respect to your personal data:

• The right to request a copy of your personal data that CMD Training Institute/Group holds about you.
• The right to request that CMD Training Institute/Group corrects your personal data if inaccurate or out of date.
• The right to request that your personal data is deleted when it is no longer necessary for CMD Training Institute/Group to retain such data.
• The right to withdraw any consent to personal data processing at any time. For example, your consent to receive marketing communications: If you want to withdraw your consent to marketing, please make contact with us to inform us of same. Please note that you may still receive system messages and administrative communications from CMD Training Institute/Group such as order confirmations, system messages and notifications about upcoming courses on which you are registered.
• The right to request that CMD Training Institute/Group provides you with your personal data and, if possible, to pass on this information directly to another data controller when the processing is based on consent or contract.
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
• The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.

8. Contacting Us

Questions

If you have any questions about our privacy policy, your rights, or how we use your information, please don’t hesitate to get in touch with our Data Protection Officer by email at info@cmd.ie

Your right to complain with a supervisory authority

We make every effort to ensure your personal data is securely and respectfully handled.

If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact info@cmd.ie 

If you are still dissatisfied after our efforts to resolve your concerns, you also have the right to apply directly to the Data Protection Commissioner (the supervisory authority for Ireland). They can be contacted by email at info@dataprotection.ie

9. Privacy Policy Changes and Updates

Our privacy policy may be updated occasionally. This version is our most current policy. We encourage you to check this Privacy Policy occasionally to ensure that you are happy with any changes.