Mid West Simon Privacy Policy

Who we are
Mid West Simon supports people experiencing homelessness in a meaningful way that is
non-judgemental. By providing emergency accommodation, permanent housing, access to
food and support services, we build a sense of independence, hope and community. We
operate in Limerick, Clare, and North Tipperary.

This Privacy Policy describes how Mid West Simon Community, the data controller, collects,
uses, and discloses information associated with an identified or identifiable individual
(referred to in this Privacy Policy as ‘Personal Data’) and what choices you have around this
activity. If you have any questions, please do not hesitate to contact us.

Mid West Simon Community
Turnpike Road
Co Clare
V95 EE68

Telephone: 061 608 980
Email: reception@mwsimon.ie

Reg. Charity No: 20063450 CHY 17187

Contact email for Data Protection Queries: dataprotection@mwsimon.ie

What we collect, why and how we use your personal data:

The personal information we collect when you make contact with us includes your name,
email address, postal address, and telephone number.

If you volunteer with us, we will collect your name, email, postal address, next of kin details,
referee details, employment history and your driving licence details if applicable. We will also
ask you to confirm that you are over 18 years of age.

If you are a financial supporter and send us a donation by post or online or make regular
contributions to Mid West Simon via your bank account or credit card, we will collect
information that allows us to effectively administer your donation. This will include your
name, address, email or telephone number, payment details and whether you would like Mid
West Simon to claim tax paid on your donation. We also ensure that, if you are setting up a
regular donation to Mid West Simon either through your bank account or by credit card, that
you are 18 years or older by asking for, and keeping a record of, your year of birth.

We will ask for some or all of this personal information when you contact Mid West Simon
about our work or services, if you are involved with one of our campaigns, become a
volunteer, make a donation or if you attend one of our events.

We use this information to keep you informed about our work, to ensure you receive the help
you need, to keep you informed of other events or campaigns that may interest you, for
volunteering purposes, to help improve our services and to keep records of our
communication with you.

Our legal bases for processing your personal data

We will only use your personal information where:
• Consent: We have asked you and have your consent for us to contact you. You can
contact us at any time if you wish to withdraw this consent.
• Contractual obligation: We have a contract with you, for example when you attend
an event or become a volunteer with us.
• Legal obligation: We have a legal obligation to obtain information about you. For
example, we are legally required to keep records of donations that we receive for 7
years according to Revenue.
• Vital interest: When you agree to volunteer with us, and if in the unlikely event that
you need immediate medical attention, or in an emergency, we would need to contact
your next of kin.
• Legitimate interest: We have a ‘Legitimate Interest’ that supports our charitable
purposes. We will ensure this is fair and balanced and never unduly have an impact
on your rights. We will only use personal information for a purpose that you would
reasonably expect.

Marketing Purposes
We collect information such as name, email address, location, and browsing behavior from
our users for marketing purposes on social media platforms. The data collected is used to
personalize marketing campaigns, target specific audiences, and analyze the effectiveness
of our marketing strategies on social media. We prioritize the protection of user data and
ensure compliance with data protection laws such as the General Data Protection
Regulation (GDPR).

We do not sell or share user data with third parties for their marketing purposes. Data is only
shared with social media platforms for targeted advertising based on user preferences.
Users have the option to opt-out of targeted marketing on social media platforms by
adjusting their privacy settings or contacting our customer support team. User data is
retained for as long as necessary for marketing purposes or as required by law. Once data is
no longer needed, it is securely deleted from our systems. Any updates to our data privacy
policy related to marketing on social media will be communicated to users through our
website or via email to ensure transparency and compliance.

We value your privacy and understand the importance of keeping your information safe and
secure. Your address is stored securely within our CRM system to ensure confidentiality and
data protection. We take the necessary measures to safeguard your personal information
and prevent any unauthorized access. If, at any point, you wish to stop receiving emails from
us, you have the option to unsubscribe from our mailing list. We respect your preferences
and will promptly process your request to unsubscribe from future communications.
To unsubscribe, simply reach out to us by sending an email to dataprotection@mwsimon.ie
requesting to be removed from our mailing list.

Some emails that we send have no tracking information, for example invoices for services
that we have received. When specific consent for tracking has been provided by the data
subject, for marketing, fundraising and event emails, we can track, at an individual level,
whether the user has opened and clicked on the email. We do this to learn more about the
kind of information that our supporters like to hear from us. We use this information to
understand open and click rates on our emails to improve them.

If you want to unsubscribe from our emails there is an unsubscribe option at the bottom of
emails we send. You can also email dataprotection@mwsimon.ie to unsubscribe at any

Sharing your data
In order to make sure we are communicating, fundraising and campaigning in the most
effective way possible, we work with fully vetted service providers which may include
fundraising agencies and marketing agencies, researchers and direct mailing providers.

In some circumstances, it is necessary for Mid West Simon to give relevant staff at our
service providers access to your personal information. This access is only granted to the
extent necessary for them to perform their services for us. We require all service providers to
comply with strict rules to protect the information you have given us.

Mid West Simon does not, and will never, share, sell or swap your information with other
organisation for their own marketing purposes or commercial gain.

Legal disclosure
We comply with requests for the disclosure of personal information in line with data
protection legislation and best practice. This could include requests from law enforcement,
Revenue or tax agencies. In these circumstances, the request must be submitted in writing
and in accordance with the relevant legal requirements.

In certain circumstances, we may need to share personal data in our control with our
insurers for insurance claims or with our legal counsel as per our legitimate interests and
where processing is necessary for the establishment, exercise or defence of legal claims.

Data sharing for Mid West Simon customer services
We ensure all data gathering and processing activities are carried out in compliance with
legal requirements and with our organisational values and principles. Mid West Simon
complies with the GDPR while also upholding our ongoing responsibilities in property
management and service provision in line with relevant legislation as follows:

• As part of work in the areas of property management or service provision, Mid
West Simon as data controller may process and share data on a legal basis with
the local authorities (county or city councils), An Garda Síochána, Health Service
Executive, TUSLA, government departments (Department of Social Protection) as
per the Housing (Miscellaneous Provisions) Act 2014 or other relevant legislation.
• At properties we manage or at services we run Mid west Simon may process
CCTV data on a legitimate interest basis, namely for security, health and safety –
protection of staff and customers, protection of property or child protection. CCTV
is strictly managed at Mid West Simon with only designated personnel being
permitted to view material and solely accessed for the purposes defined. CCTV
notices will be present at all premises where CCTV is in use detailing operator,
purpose of system, access request information and privacy statement. CCTV may
be shared on request with An Garda Síochána as per Part V, sections 70 and 41
of the Data Protection Act 2018 Requests for access to CCTV data by the Gardaí
must be made in writing. In addition, Mid West Simon will comply with requests for
CCTV data by the Irish Court Service in the course of legal proceedings as

How long we retain your personal data

Financial donations
Where you have given a financial gift, we retain this for 7 years after the date you stop
providing financial support. We store this as required by Revenue for audit purposes. If a
donor has requested to have their contact details removed before this date, this financial
information is anonymised where feasible

We collect Personal Data including Basic Information, Contact Information, Financial
Information, and Profile Information for event registration. This data is retained only as long
as necessary.

For anyone who has applied to be a volunteer, we retain your data for the duration of your
volunteering and six months afterwards.

For individuals who have expressed interest in our work through inquiries or requests for
information regarding our services or projects, we retain your information for the required
duration and will delete it upon request.

Protecting your personal data
We have implemented appropriate physical, technical and organisational measures to
protect the personal information we control both on and off-line to prevent improper access,
use alteration, destruction and loss. Your information is encrypted and stored securely on our
servers in Ireland, and are maintained and updated by our IT service provider. If this
information needs to go to an external supplier, for example, to process a donation through
our website, this information is encrypted, transmitted securely and stored within the
EU/EEA. We have strict agreements/contracts in place with all external service providers to
ensure the highest levels of security and safety.

Sensitive Personal Information
We take extra precautions to ensure your sensitive personal information that we process or
store on your behalf is properly safeguarded. We treat it with the highest level of
confidentiality and ensure we have appropriate technical and organisational measures to
keep it extra secure. Data Protection legislation recognises that some categories of personal
information are more sensitive. Sensitive personal information can include information on
people’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious

Transfer outside of the EU/EEA
In the course of our legitimate business activities Mid West Simon will from time to time
transfer data outside of the EU/EEA (including to the United Kingdom). In such cases, we
will have the appropriate transfer mechanisms in place as well as additional safeguards to
protect that data as appropriate.

We use google analytics to track the performance of this website and your IP address may
be used to gather broad demographic information. We do not use any information which
when used either alone or in conjunction with other information, could personally identify

We utilize the most recent WordPress version, which offers features facilitating GDPR
compliance. These include comments consent, data erase and export settings, and a privacy
policy generator. Nevertheless, relying solely on these features is not sufficient for complete
GDPR compliance. Other aspects of your website, such as cookies, also require attention.

Web Forms
Mid West Simon are committed to respecting and protecting your online privacy. This
includes the personal information that you share with us via web forms on our website or our
owned social media channels and online ads, e.g. if you respond to an ad on one of our
social media channels, we will use the contact data you provide only to contact you about
your specific area of interest or the particular event advertised.

Your Rights
You have rights over your personal data, and how your information is used. These rights are
not absolute as some qualifications and restrictions may apply. To summarise your rights

• The Right to withdraw consent;
• Right of access;
• Right to rectification;
• Right to be forgotten / erasure;
• Right to restrict processing;
• Right to object;
• Right to refuse automated decision-making and/or profiling;
• Right to portability.

If you believe your privacy rights have been violated or you would like to make a data access
request, you can contact the Data Protection Administrator at dataprotection@mwsimon.ie.

You can also file a complaint with the Data Protection Commission at