Privacy Policy

Summary  

The Commision for Regulation of Utilities’ (CRU) Online Consultation Portal is a free service provided to enable participation in public consultations. The portal publishes consultations to which you can make submissions, receive messages about consultations, read and interact with published submissions.  
 

The CRU fully respects your right to privacy.  Any information, which you submit via the CRU’s websites will be treated with the highest possible standards of security and confidentiality, strictly in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. This privacy statement sets out how the CRU (Data Controller) and CiviQ (the Data Processor and the company that runs the online consultation portal service) processes your personal data, secures this personal data, and the various policies that adheres to General Data Protection Regulation.  
 

The CRU reserves the right to amend the scope of the privacy statement at any time which may include or exclude other sites or platforms.  


Identity and the contact details of the controller:  

The Data Controller is the Commission for Regulation of Utilities, The Exchange, Belgard Square North, Tallaght, Dublin 24 

Contact details of the data protection officer:   

Identity and the contact details of the processor: 

The Data Processor is CiviQ, Business Barn, Kellystown Lane, Leixlip, Co. Dublin.   

How we collect your information 

The Online Consultation Platform, known as the "platform", and the data processor, CiviQ, collects personal information from you on our behalf, to facilitate your responses to public consultations and engagement with other respondents. Your data is collected in the following ways:  

  • Directly from your written input to the platform via the registration form, submission forms, survey forms and comment boxes;  

  • Automatically through the platform’s technologies including tracking online, such as by web cookies (which are small text files created by websites that are stored on your computer)   

The information you provide  

We collect the following information about you from your use of the platform:   

  • Contact details, including your name, email address, postal address, website and telephone number;  

  • Organisational affiliation if you are registering an organisation or a company;  

  • Gender and age (optional);  

  • Usernames and passwords;  

  • Website security roles to allow you to securely perform some limited functions within the CiviQ platform;  

  • Tracking codes, such as cookies;  

  • Submissions, comments, emails, feedback about the platform, indicators of support to other users, and other content you provide via the platform;  

  • Consent to receive emails from subscriptions, notifications and messages including date and time of consent;  

  • Anonymised Internet Protocol (IP) addresses used to connect your computer to the Internet;  

  • Account creation and last log-in date and time;  

  • Logging confirmation that the privacy statement is read during registration;

  • Audit of moderation tasks on your submission   

   

If you make a submission to some types of consultation, there is or may be a requirement to provide your name and address. The platform therefore requests these details at log in to facilitate your participation in all types of consultation, in an efficient and effective manner.  
 

Some types of communications from the platform require your consent.  These include messages and notifications. You may choose to receive notifications about consultations; system messages and notifications or withdraw consent to the same.  

 

What we need and why we need it  

We may use information we hold about you in the following ways:  
 

Information you give us. We will use this information:  

  • to carry out our obligations to process your responses to public consultations;  

  • to provide you with information;  

  • to notify you of confirmation that we have received your response to a consultation;  

  • to notify you about changes to any of our services;  

  • to ensure that content from the platform is presented in the most effective manner for you and for your computer;  

Information collected about you by the platform. This information is used:  

  • to administer the platform and for internal operations, including troubleshooting and testing.  

  • to improve the platform to ensure that content is presented in the most effective manner for you and for your computer or mobile device;  

  • to keep the platform safe and secure; and  

  • to help improve the reach and inclusiveness of public consultations using third party services such as Matomo Analytics.  
     

 Our legal basis for using your information  

The main legal basis for processing your personal data is that such processing is:  

  • necessary for us to comply with our legal obligations and/or  

  • necessary for us to carry out our tasks in the public interest and/or in the exercise of official authority vested in us.   

We will ask for your consent with regard to certain types of communications and notifications.   

 

How long we hold your data  

We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. The length of time we hold your personal data depends on a number of factors such as:

  • The type of data we hold about you.
  • Whether there is a legal obligation to hold the data for a minimum specified period.
  • Whether there is a public interest basis to hold the data for a specified period.
  • Where there is a sound evidence-based reason to hold the data for a specified period.

As a general rule, we keep your information for a specified period after the date on which your interaction with us has completed. This may mean that some information is held for longer than other information.

  • Information relating to your portal user account will be held for 24 months from your last submission.
  • Consultation responses published on the CRU website will remain there indefinitely.
  • Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”), e.g. where you think that the information, we are processing is inaccurate, or the processing is unlawful.

 

Storage of your information, international data transfers and security  

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  
 

The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.  
 

Transfers of data will be within the European Union and therefore covered by GDPR.  

We may transfer or allow the transfer of information about you to our service providers and other organisations outside the European Economic Area (EEA), but only if they agree to act solely on our instructions and protect your information to the same standard that applies in the EEA.

For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Law. We will 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 will establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU Commission’s model clauses.

   

Disclosure of Your Information  

We will not share your information with third parties. However some third parties may occasionally have access to areas of the platform where your data is stored for the purposes of providing the platform service, development, testing and fixing of the platform. In these cases, the third parties will also be bound by data protection agreements that comply with the GDPR.  
 

Automated decision-making  

Your personal data is not used for any automated decision-making.  

 

Cookies  

For more information on how we use cookies, please see our Cookie Policy.  

 

Your rights  

You have certain rights in relation to your personal information that is processed by us. These rights are listed below. These rights are not absolute and apply subject to certain conditions. For example, your rights may include:  

  • the right to access personal data held by us about you;  

  • the right to require us to rectify any inaccurate personal data held by us about you;  

  • in certain circumstances, the right to require us to erase personal data held by us about you;  

  • in certain circumstances, the right to restrict our processing of personal data held by us about you;  

  • in certain circumstances, a right to receive personal data which you have provided to us in a structured, commonly used and machine readable format. You may also have the right to require us to transfer this personal data to another organisation where feasible, at your request;  

  • the right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you); and  

  • the right to withdraw your consent, where we are relying on it to use your personal data  

 
To exercise these rights please contact dataprotection@cru.ie For further information please visit the Data Protection section of the CRU’s website: https://www.cru.ie/privacy-notice/ 

 

Some rights you can exercise directly on the platform via your Personal Account page; My Submissions Page; Manage Consent page; and by checking certain boxes on the consent forms we use when collecting your personal information. These facilitate you keeping your personal details up to date and prevent certain types of processing.   

 

With regard to communications, if at any point you wish to review or change your preferences, you can use the ‘opt-out’ or 'unsubscribe' mechanism or other means provided within the communications that you receive from us. Note that you may still receive transactional communications regarding your submissions.  

 

To inquire about or exercise other rights please email the data controller. CiviQ will action any instructions from the data controller with respect to your request.  

 

Obligation to provide personal data  

In order to provide certain services to you, the CRU requires your personal data, and cannot provide the services without this data. Where the CRU requires this data it will be made clear to you on application for these services, what personal data will be required to be held and processed by the CRU.  

 

Changes to this policy  

We reserve the right to modify the Privacy Policy at any stage. If and when we make changes to our privacy policy, we'll share details of these changes on this page. Please continue to check this page to ensure that you are always aware of any changes.  

 

Concerns or complaints  

If you have any concerns or complaints about the processing of your personal data or the CRU’s responses to regarding your personal data, you have the right to lodge a complaint to the Data Protection Commission, info@dataprotection.ie. For further information please visit the Data Protection section of the CRU’s website  https://www.cru.ie/privacy-notice/ 

 

For further assistance on Data Protection contact: 
The Data Protection Officer of the Commission for Regulation of Utilities, The Exchange, Belgard Square North, Tallaght, Dublin 24 

 

Last updated on 22/03/2024