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Privacy Policy

This is the website of Positive2Work (‘we’, ‘us, ‘our’, ‘Positive2Work’, ‘Positive2Work Skillnet’).

This policy discloses our information gathering and dissemination practices relating to this website. In order to fully understand your rights, we encourage you to read this in full. We are not responsible for the content or privacy practices of other websites. We reserve the right to modify this Privacy policy at any time. Each time you use this website you shall be bound by the then current Privacy policy and accordingly you should review the Privacy policy each time you use this website.

This policy governs the online processing activities of this website. For offline processing of personal data and our role as Data Processor for Skillnet, please request a copy of our data protection policy from our Data Protection Manager (contact details below).

Who we are

Positive2Work is a member of the Skillnet learning network. We are a company specialising in training solutions and people development with the aim of creating a Postive2Work environment for all employees within the member companies of the Skillnet.

Data Controller

Positive2Work Skillnet is the controller of the personal data it processes on this website. Positive2Work is a company limited by Guarantee (CLG) registered in Ireland under company number 412975.

Data Protection

We take our responsibility to protect your data seriously and will not collect any personal information about you on this website without your clear knowledge and permission. Any personal information which you volunteer to us will be treated strictly in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Acts 1988-2018. Where data is submitted it will be used for the stated purpose and any reasonably incidental purposes only.

We do not sell or distribute your personal information to third parties for purposes of allowing them to market products and services to you.

Communicating via the internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third-parties.

The information we collect

  • For general web-browsing certain statistical information is available to us via our internet service provider. This information may include the IP and logical address of the server you are using, the top level domain name from which you access the internet (for example .ie, .com, etc.), the type of browser you are using, the date and time you access our site and the internet address linking to our site. We may also use temporary “session” cookies which enable a visitor’s web browser to remember which pages on this website have already been visited.
  • You have an opportunity to send us information via this website, such as through the “contact us” pages or by sending an e-mail to the address listed to request information or provide feedback. You may also choose to provide us with personal data (e.g. name, e-mail, postal address or other contact details) in an e-mail message. In these instances, we collect name, email, and message content. We use these details solely for the purpose for which you provided them.
  • You can register for a course. In this instance we will process name, email address, company name, phone number, username and password.

The purpose of collecting information

  • Responding to your query – you may provide us with personal data through our contact form or email address while seeking information about our services.
  • To register you on a course, contact you to update you on course time & location and/or invoice you for course payment
  • Website functionality – We analyse website users’ pattern of use to help us to improve, administer and diagnose problems with our server and website.
  • Complaint handling – we may use the data you provide to us via our contact form or email address.

Legal basis for processing

We process your personal data based on the following lawful basis:

(1) Consent: We will only process your data for marketing purposes with your consent. For processing activities for which we rely on consent as a basis for processing, you have the right to withdraw that consent at any time.

(2) Contract: We may process the data you provide while fulfilling our obligations under a contract e.g. during the provision of training services to you.

(3) Statutory: Some processing activities are required by law e.g. Revenue reporting.
For processing activities that are based on a statutory or contractual requirement, you may request your data not be processed for that purpose. However, this is not an absolute right and may be over-ridden by our statutory obligations. In other cases, requesting that data should not be processed for a particular purpose may prevent us from executing a contract or delivering a service to you.

Your rights

Under data protection law, data subjects have certain rights. Subject to certain restrictions, which are set out below, you can exercise these rights in relation to your personal data we process.

  1. The right to be informed about the processing of your personal data
  2. The right to access your personal data
  3. The right to rectification of your personal data
  4. The right to erasure of your personal data
  5. The right to data portability
  6. The right to object to processing of your personal data
  7. The right to restrict processing of your personal data
  8. Rights in relation to automated decision making, including profiling
  9. You have the right to complain to the Irish Data Protection Commission (www.dataprotection.ie) and to seek compensation through the courts

Restriction of data subject rights in certain circumstances

Article 23 of the GDPR allows for data subject rights to be restricted in certain circumstances. In addition, the 2018 Act contains certain provisions dealing with the restriction of rights of data subjects, in particular Sections 59, 60 and 61, which give further effect to the provisions of Article 23. Further information can be found here.

Who we share your information with

We do not share your information with third parties other than those set out in this policy. We may share your information in the following circumstances:

  • Service providers: We may need to share personal information with our service providers, such as where necessary to provide our services to you. If there has been a breach of our terms of use, we may also share personal information with our legal advisors. All of our service providers will be obliged to keep your personal information safe and secure.
  • Positive2Work is a data processor for Skillnet Ireland with whom it has a Data Processing Agreement which dictates how, when and where trainee data can be processed.
  • We will share your course bookings with our trainers (service providers) and Skillnet Ireland (our funder and data controller)
  • Business Transfer: Where some or all of our company and/or its assets may potentially be or have been acquired, we may need to transfer your personal information to the new or prospective owners.
  • Legal and safety: In certain instances, we may share information where we reasonably believe that it is necessary for legal reasons, to defend our legal rights, to enforce our terms of use or to protect our rights, property, users, customers or the safety of any person. For example, we may provide personal information where ordered by a court to do so.
  • Other: We will share your information with a third party other than a service provider where you have given your consent for us to do so.

Where we store personal information

We generally store personal information on servers located inside the European Economic Area. However, in certain cases it may be necessary for us to transfer certain information to servers located outside of the EU. It is important to be aware that the privacy protections in certain jurisdictions may not be equivalent to those in Europe but we will only transfer your information outside the EEA where permitted by law and ensuring that it is subject to appropriate protections.

Data Retention

Positive2Work Skillnet retains personal data for a range of periods as set out in our Data Protection Policy.