Book of Condolence Privacy Notice
The purpose of this privacy notice is to describe, in clear terms, the personal data that the book of condolence process collects about individuals, why it is needed, the legal basis, how it is used, and how individuals may interact with the council in relation to their personal data and the book of condolences. It also outlines the rights of individuals under data protection legislation.
Clare County Council also has a privacy statement which is a general document about how we approach data protection as an organisation and available on the council's website or on request.
Purpose of the book of condolences
Personal data is gathered as part of the book of condolences process in order for Clare County Council to provide a facility for citizens to record condolences following the death of a respected Irish person, world figure, or following a major tragic event. Condolences can be expressed either in a hard copy book of condolences or online.
The council is obliged to protect such personal data in accordance with the Data Protection Act 2018 and the provisions contained in the General Data Protection Regulation (GDPR).
Legal basis for the processing of personal data in a book of condolences
The legal basis to process personal data in the case of a book of condolences is the following: Article 6(1)e of the GDPR - the processing is neccessary for the performance of a task carried out in the public interest or in the exercise of an official authority vested in Clare County Council, in this case Section 64(1), Local Government Act, 2001.
Whether or not to participate in a book of condolenece is entirely a voluntary decision.
The categories of personal data concerned
Personal data processed is: name, organisation, address. Address is not a requirement, and the provision of it is entirely voluntary.
Processing and recipients of the data
Access to the data is limited to personnel handling the book of condolence within Clare County Council. Online books may be accessed by limited personnel in the company whose online platform is being used. The data entered in the hardcopy book of condolence may be seen by any other members of the public/staff who sign the book.
The book of condolences is given to the following recipients: the next of kin or the organisation/authority to which the deceased was affiliated.
Third party access to personal data is not allowed, except in the very limited circumstances permitted by law. Access requests shall be processed in accordance with the Data Protection Act 2018, the GDPR and the council's data protection policies and procedures.
The retention period for the data
Records in relation to books of condolences are retained while active and available for public access. The records are then transferred to the relevant recipients.
Data subjects have a range of data rights
- Right of access by the data subject
- Right to rectification
- Right to erasure ('right to be forgotten')
- Right to restriction of processing
- Right to data portability
- Right to object and automated individual decision-making
The council's data access request policy and procedures are available on www.clarecoco.ie or please contact dpa@clarecoco.ie
The right to lodge a complaint with the supervisory authority
If you are not satisfied with a decision on your request for access to data or have concerns about personal data processing, you have the right to make a complaint to the Data Protection Commission, Canal House, Station Road, Portarlington, Co Laois, Ireland. Before doing so it is recommended that you contact Clare County Council (dpa@clarecoco.ie) to establish the circumstances. We may be in a position to resolve the problem in a timely manner.
The Data Protection Commission website www.dataprotection.ie has further details and the forms that are required to be completed if you wish to raise a concern or make a complaint.
Contact details for the data controller and data protection officer
The contact details for the data controller is:
Clare County Council,
New Road,
Ennis,
Co Clare
Email: corporate@clarecoco.ie
Website: www.clarecoco.ie
The contact details of the Data Protection Officer:
Data Protection Office
Telephone: (065) 6846405
Email: dpa@clarecoco.ie
Page last reviewed: 30/07/24
Content managed by: Corporate Services Department
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