IHF Data Privacy Statement

The Irish Hotels Federation (IHF) is a membership organisation representing the interests of hotels and guesthouses in Ireland. We are committed to protecting and respecting your privacy and complying with our legal obligations in relation to the processing of personal data under the General Data Protection Regulation (GDPR) and Data Protection Acts 1988-2018.

Although our members are businesses, not individuals, we do collect and use personal information relating to individuals as part of our activities. This is generally in order to manage membership services and to carry out our wider work promoting and defending the interests of the Irish hotel and guesthouse sector.

This privacy statement sets out how the IHF collects and uses personal information about individuals. Please read the following carefully to ensure you understand what personal data we process, the purpose and lawful bases for processing this information, how long we retain this information, with whom this information is shared and a description of your rights in respect of the personal data we collect and process.

If you have any queries in relation to this privacy statement, please contact us by email at dataprivacy@ihf.ie or write to: Irish Hotels Federation, 13 Northbrook Road, Dublin 6, D06 PK18.

1. PERSONAL DATA WE MAY COLLECT AND PROCESS

Information we may collect about you
The IHF collects and uses personal data to identify you, contact you and deliver services and information to you. Personal information you or your employer provide us in this regard may include your name, job title, e-mail address and phone number.

We collect this personal data in the following circumstances:

• IHF Members and Associate Members: We may collect certain information about you in a business-to-business context in order to manage your business’ membership of the IHF, deliver membership services, meet contractual requirements, comply with our legal obligations and, where necessary, on the basis of our legitimate interest to represent the interests of businesses within the hotels sector.

• Non-member hotels and guesthouses: We may collect certain information about you in a business to business context based on your consent to receive communications and in order for us to meet contractual requirements, comply with legal obligations and, where necessary, on the basis of our legitimate interest to represent the interests of businesses within the hotels sector.

• Other businesses: We may collect the personal data of individuals employed by or representing suppliers and other businesses with which we have a commercial relationship. This information may be processed on a contractual basis, to comply with legal obligations and, where necessary, on the basis of our legitimate business interests.

Other industry stakeholders: We rely on our legitimate interest as a business representative organisation to represent our members and the wider hotels sector and to provide information on a range of lobbying and policy development issues and initiatives to officials (national, European and international), commentators, media, other representative bodies, industry partners and stakeholders. Personal data collected for these purposes may include your name, job title, e-mail address and phone number.

Employees and Job candidates: We use the personal data job candidates provide us as part of the recruitment process and will retain it for one year after the recruitment process ends unless otherwise obliged to retain it by law. We collect and process the personal data of our employees and a copy of our Employee Data Protection Policy is provided to all employees when they commence employment.

Purposes for which we hold and use your information
We may process any personal data you provide to us for the following purposes:

• to confirm your identity
• to contact, respond and communicate with you in the context of the business-to-business relationship that exists between the IHF and you, your employer and your business
• to provide your business with updates and information resources, including marketing information, newsletters and email alerts for which you have subscribed
• to process any orders from you such as membership application, event bookings, training and payments for services
• to review and update our membership and business contact details
• to notify you of changes and updates to our services and to our websites
• to carry out recruitment and manage the IHF’s contracts of employment
   

Events: The IHF regularly organises hotel sector-related events such as workshops, seminars, education and training sessions, conferences, information days and social and networking events. Participants attend in a business-to-business context and may include members, non-members, other businesses, other stakeholders and invited speakers. When you attend an IHF event, we may require your name, email address, phone number, and payment information in order to organise and administer the event. If you are a speaker at an IHF event, we may publicly promote your involvement via social media channels, communications to potential attendees, media interviews, emails and webinars. This data may continue to be processed by those platform providers after the event has ended.

Employment services: We process personal data as part of the delivery of our human resources and industrial relations advisory services to members, Quality Employer Programme and other employee-related initiatives. Only relevant IHF staff members have access to this data, which is kept to a minimum and processed only in so far as is necessary to advise and represent members. We ensure through our management, employment obligations, internal policies and controls that relevant data is kept in a secure and confidential manner. Our data retention procedures ensure that the information is kept for no longer than is necessary. The IHF engages with third-party contractors to assist with employer relations advice and representation, and in doing so we ensure that sufficient contractor guarantees are in place in relation to data privacy protection.

Information Resources, including marketing communications, newsletters and email alerts
As a business representative organisation, we operate primarily with businesses rather than individuals and do not generally seek your consent to send you industry-related communications.  We believe that such communications are in our legitimate interests to represent the hotels sector, raise awareness of key issues, our work and services provided in your interests.

In our newsletters and email alerts we may use invisible 1×1 pixel tags, known as 'clear pixels' to send our messages in an easy-to-read format and to tell us whether our email has been opened or not. We also use this information in aggregated form to give us an indication of the popularity of content and to help us make decisions about future content and formatting.

All communications sent by the IHF include an ‘unsubscribe’ facility allowing you to opt out of receiving further communications. You may also ask us to stop sending communications by contacting us directly by phone, in writing or by email (including dataprivacy@ihf.ie). Some personal data such as you email address may be retained however to ensure you no longer receive communications from which they have unsubscribed.

Collection of data through our website: We may process and collect personal data that you voluntarily provide us with through the ‘Contact Us’ form on our website. Our website is not intended for children and we do not knowingly collect data relating to children.

Cookies: We use cookies to enhance site navigation and analyse website performance. The information collected cannot be used to identify or contact you. A cookie message is displayed on our website outlining our cookie usage policy and seeking consent for their usage.  

Links to external websites: Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.

2. DISCLOSURE OF INFORMATION TO THIRD PARTIES
We will not disclose your personal data to third parties unless you have consented to our doing so. We will, however, disclose your personal data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court, workplace relations forum, regulatory order or other statutory requirement. We may occasionally transfer personal data outside the European Economic Area (EEA) but will not do so without your permission nor without appropriate assurances on the adequacy of data privacy protection commitments.

3. SECURITY
Any personal data held by us in physical form is minimised and stored using a secure manual filing system in accordance with our data retention schedule.

Personal data held in electronic form is stored on secure servers. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. Any transmission of data is therefore at your own risk. Once we receive your data, we use appropriate technical and physical security measures, including firewalls and anti-virus protection to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Our suppliers are also required to use appropriate data protection compliance measures. We will continue to revise policies and implement additional security features as new technologies become available.

Personal information relating to credit cards are processed online are via a secure on-line payment and the IHF does not have access to this information. Information relating to credit and debit card payments made by other means will only be retained until the payment transaction has been successfully completed.

4. RETENTION

Members and Associate Members: We keep updated personal data relating to Member and Associate Member contacts for as long as the business remains a member. We review contact lists on an ongoing basis, including annually. If you unsubscribe from IHF communications, we will promptly remove your contact details from our subscription list. We retain finance information for invoicing purposes for seven years as required by revenue.

Non-members, other businesses and industry stakeholders: We keep updated personal data relating to non-members hotels and guesthouses, other businesses and suppliers, industry stakeholders personal data for communication purposes. If you unsubscribe from IHF communications, we will promptly remove your contact details from our subscription list. We retain finance information for invoicing purposes for seven years as required by revenue.

5. YOUR RIGHTS UNDER DATA PROTECTION LAW
You have the following rights under data protection law, although your ability to exercise these rights may be subject to certain conditions:

• to be informed about processing of your data
• to access your personal data
• to object to personal data processing (to object to any direct marketing either use the ‘unsubscribe’ button on our emails or contact us directly by emailing dataprivacy@ihf.ie)
• to request that your personal data be provided to you in a portable format
• to have inaccurate information about you corrected 
• to have your personal data deleted (in some circumstances)
• to have your data restricted or blocked from automated decision making, including profiling

We will aim to respond to all data subject access requests within one month. We will not charge a fee for dealing with such requests. If you are dissatisfied with how we are using your personal information or how an access request is handled, please contact our Privacy Compliance Coordinator and we will try to resolve any issues you may have. You also have the right to complain to the Data Protection Commissioner (www.dataprotection.ie), which is the statutory regulator for data protection law in Ireland.

6. CHANGES TO THE PRIVACY STATEMENT
Any changes to this Privacy Statement will be posted on this website so that you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We therefore encourage you to periodically review this statement to be informed about how we are protecting your information. If at any time we decide to use personal data in a manner significantly different from that stated in this website Privacy Statement, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail or in writing, and you will have a choice as to whether or not we use your information in the new manner.

FURTHER INFORMATION 
If you have any queries in relation to this privacy statement, please contact us by email at dataprivacy@ihf.ie or write to: Irish Hotels Federation, 13 Northbrook Road, Dublin 6, D06 PK18.