Privacy Policy

 

1. What does this Privacy Policy cover?

 

This is our main Privacy Policy and it explains how Leaflet Marketing Ireland (“we”, “us ” or “Leaflet Marketing Ireland ”) use

Personal Data which we collect about individuals. “Personal Data” is information about living

individuals.

 

We use the words Personal Data to describe any information we hold that is about you or other

individuals, and from which you or they are identifiable. Our aim is responsible handling of Personal

Data and this Privacy Policy describes how we use Personal Data that we collect as part of our functions.

This includes Personal Data obtained from a variety of sources listed in paragraph 3 below.

 

This Privacy Policy may be supplemented by other privacy notices tailored to specific activities. This is

to make sure you have a full picture of how we collect and use your Personal Data.

 

We accept from you personal data about another individual only if you (a) inform the individual about

the content of this Privacy Policy and any other applicable privacy notices provided to you; (b) obtain

their permission to share their Personal Data with us in accordance with this Privacy Policy and other

applicable privacy notices; and (c) obtain any legally required consent, where applicable.

 

2. Personal Data we hold

 

The Personal Data we hold about you and other individuals differs depending on our relationship,

including the type of communications between us and the services we provide. Personal Data we may

hold and process includes:

 

• Contact information
• Marketing preferences, marketing activities and customer feedback
• Lifestyle data, age category, place of residence, family composition, household, income, car ownership and/or hobbies / interests
• Profiling

 

3. Sources of Personal Data

 

• We may obtain Personal Data from the following sources:

 

(a) our website at www.leafletmarketing.ie (the“Website ”); and

(b) email;

(c) telephone surveys and calls, directly or through third parties working on our behalf to

update our databases;

(d) from businesses in respect of individual contact details within such businesses; and

(e) data brokers who have obtained your consent to use your personal data for third party

marketing purposes.

 

4. How we use Personal Data

 

We use Personal Data to carry out our business activities, further details of which are available on our

Websites. The purposes for which we use your Personal Data may differ based on the services we

provide.

 

The main purposes include using Personal Data to:

 

4.1            enable us and our clients to undertake advertising, marketing, direct marketing and public

relation exercises;

4.2            provide a full range of database management services to our clients, including supplying

consumer and business data, data profiling, data hygiene, data capture and address validation

and correction;

4.3            perform accounting and other record-keeping functions;

4.4            provide personnel, payroll and pension administration services; and

4.5            supply identity verification for use in anti-fraud and anti-money laundering processes.

 

5. Responsibility for Personal Data

 

Leaflet Marketing Ireland is responsible for looking after your Personal Data in accordance with this Privacy Policy, our internal standards and procedures, and the requirements of data protection law.

 

When we provide Personal Data to third parties providing services to us or engage a third party to collect

Personal Data on our behalf, the third party service providers (data processors) will be selected carefully

and required to use appropriate measures to protect the confidentiality and security of the Personal

Data. Those third parties will assume certain responsibilities under data protection law for looking after

the Personal Data that they receive from us.

 

6. Sharing of Personal Data

 

In connection with the purposes described above, we may need to share your Personal Data with third

parties (this may involve third parties disclosing Personal Data to us and us disclosing Personal Data to

them). These third parties may include:

 

Clients

 

Businesses or individuals who wish to use our data for the purpose of sending direct marketing (subject to your preferences) or otherwise contacting you. These may include small and medium enterprises (“SMEs ”); manufacturers, financial services providers; government and semi-state bodies; utility companies and retail

companies. We also supply other data suppliers and marketing agencies who broker our data to their customers, and these parties are required to comply with data protection and e-privacy laws in the use of the data including observing any marketing preferences expressed.

 

Our Service Providers

 

External third party service providers, such as security professionals, accountants, auditors, experts, lawyers and other professional advisors; travel assistance providers; call centre service providers; IT systems, support and hosting service providers; advertising, marketing and market research, and data analysis service providers; banks and financial institutions that service our accounts; document and records management providers; printing service providers; and other third party vendors and outsourced service providers that assist us in carrying out business activities.

 

Database providers or publications

 

For the purpose of providing verification or ‘data hygiene’ services to our clients as set out in sections 4.2 and 4.5 above, we obtain (or have obtained) information from publications (e.g. Stubbs Gazette for verifying company directors) or other public registers and providers of databases and registers such as Demographics Ireland, Full Circle Data and Experian Ireland.

 

7. Processing of Personal Data

 

For the purposes set out above we may transfer Personal Data to clients and service providers located in

other countries

 

In the event that we transfer Personal Data to countries outside the EEA that have data protection regimes

which are different to those in the EU, we take steps to ensure that your Personal Data is adequately

protected and transferred in accordance with the requirements of applicable data protection law.

 

This may involve the use of data transfer agreements in the form approved by the European Commission

or another mechanism recognized by data protection law as ensuring an adequate level of protection for

Personal Data transferred outside the EEA (for example, the standard contractual clauses approved by

the European Commission).

 

For further information about these transfers and to request details of the safeguards in place, please

contact us using the details below.

 

8. Security of Personal Data

 

Leaflet Marketing Ireland uses appropriate technical, physical, legal and organizational measures that comply with data protection laws to keep Personal Data secure.

 

As most of the Personal Data we hold is stored electronically we have implemented appropriate IT

security measures to ensure this Personal Data is kept secure. For example, we use anti-virus protection

systems, firewalls, and data encryption technologies. We have procedures in place at our premises to

keep any hard copy records physically secure. We use electronic access cards with secret PIN to manage

access to all areas in our premises. We also train our staff regularly on data protection and information

security.

 

Unfortunately, no data transmission over the Internet or electronic data storage system can be guaranteed

to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for

example, if you feel that the security of any Personal Data you might have sent to us has been

compromised), please immediately notify us.

 

• Legal justification for our use of Personal Data

 

To comply with the law, we need to tell you the legal justification we rely on for using your Personal

Data for our purposes.

 

While the law provides several legal justifications, the section describes the main legal justifications that

apply to our purposes for using Personal Data:

 

• Justification for processing Personal Data:

 

(a)             Where necessary for performing a contract to which you are a party or to take steps at

your request prior to entering into this contract;

(b)            Your consent (where you voluntarily give consent to provide us or a third party with

your Personal Data ); and

(c)             Where necessary for the purpose of our legitimate interests or those of a relevant

third party.

 

8.2            Where we rely on our legitimate business interests or the legitimate interests of a third party to

justify the purposes for using your Personal Data, our legitimate interests will usually be:

 

(a)             pursuit of our commercial activities and objectives, or those of a third party (for

example, by carrying out direct marketing or conducting market research);

(b)             compliance with applicable legal and regulatory obligations;

(c)             development of any guidelines, improvement and development of business operations

and service offerings;

(d)            conducting analytical and statistical research and profiling.

 

9. Monitoring communication

 

We monitor electronic communications between us (for example, emails) to protect you, our business

and IT infrastructure, and third parties including by:

 

(a)             identifying and dealing with inappropriate communications; and

(b)             looking for and removing any viruses, or other malware, and resolving any other

information security issues.

 

10. Retention of Personal Data

 

We will keep Personal Data for as long as is necessary for the purposes for which we collect it.

 

Where we hold Personal Data to comply with a legal or regulatory obligation, we will keep the

information for at least as long as is required to comply with that obligation.

 

Where we hold Personal Data in order to provide a product or service to you as a client, we will keep the

information for at least as long as we provide the product or service, and for 7 years thereafter.

 

In relation to consumer names and addresses these are periodically deleted where they have not been

used in a marketing campaign in over 12 months . If you opt out of receiving direct marketing, we will

keep a record of this indefinitely in order to ensure that your marketing preferences continue to be

observed.

 

In relation to business contact data, we deactivate the Personal Data after 24 months from the date of its

last verification. It is only reactivated following fresh verification and subject to this Policy.

 

For further information about the period of time for which we retain your Personal Data, please contact

us using the details below.

 

11. Personal Data Rights

 

The following is a summary of the data protection rights available to individuals in the EEA in connection

with their Personal Data. These rights may only apply in certain circumstances and are subject to certain

legal exemptions.

 

• Right of access to a copy of your Personal Data;
• Right to withdraw consent to processing of Personal Data (where we process on the basis of
• consent);
• Right to rectify any Personal Data we hold about you if it is inaccurate or incomplete;
• Right to have your Personal Data erased from our systems in certain circumstances e.g.

 

• if your Personal Data has been processed unlawfully;
• if you object to our processing of Personal Data on grounds relating to your particular
• situation and we have no overriding grounds to continue to use it (see below); or
• where you have provided consent to processing and you wish to withdraw the consent.

 

• Right to restrict (i.e. suspend) our processing of Personal Data (This may be requested while
• the accuracy of your Personal Data is being established by us in the event we receive a
• rectification request or while we assess an objection received by you (see below);
• Right to data portability where your Personal Data, which you have provided to Data Ireland
• with your consent, is processed by automated means;
• Right to object to our processing of your Personal Data on the basis of our legitimate interests
• (see paragraph 9.2 above) on grounds relating to your particular situation. However, we may
• continue to use your Personal Data, despite your objection, where there are compelling
• legitimate grounds to do so or if we need to use your Personal Data in connection with any legal
• claims or where we have one or more other legal basis to process your Personal Data (see
• paragraph 9 above);
• Rights relating to automated decision making and profiling having legal or similarly significant
• effects on you – Leaflet Marketing Ireland does not engage in such decision making or profiling on this basis
• and therefore these rights do not apply.

 

If you wish to exercise your rights, please contact us using the details below.

 

You also have a right to complain to the Irish Data Protection Commission if you think that we have

processed your Personal Data in a manner that is not in accordance with data protection law. If you are

based in another EU Member State, you may complain to your local data protection regulator.

 

12. Who to contact about your Personal Data

 

If you have any questions or concerns about the way your Personal Data is used by us, you can contact

us by e-mail at: dataofficer@leafletmarketing.ie  or by writing to the Data Officer, Leaflet Marketing Ireland, 56 Western Parkway business Park, Ballymount, Dublin 12.

 

This Privacy Policy was last updated in May 2018.

 

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of

changes in our business, legal requirements, and the manner in which we process Personal Data.

 

GDPR and Leaflet Marketing Ireland:

 

As the nation’s leading provider of Leaflet Distribution, Unaddressed Mailing, Mapping and Customer segmentation for distribution purposes, we are committed to our responsibilities under data protection legislation, including the General Data Protection Regulation which comes into force on 25th May 2018.

What is GDPR

The General Data Protection Regulation (“GDPR”) is a new European privacy regulation which will replace the current EU Data Protection Directive (“Directive 95/46/EC”). The GDPR aims to enhance the current Directive to strengthen the security and protection of personal data in the EU and harmonize data protection legislation throughout the EU.

How does the GDPR apply to Data Ireland’s products?

We use consumer and business names and addresses which is defined as personal data and data protection legislation, including the GDPR, therefore applies to our products.

How has Leaflet Marketing Ireland been preparing for the GDPR?

We have prepared the following overview for potential clients and data subjects describing our products and outlining the measures we have taken to achieve compliance with existing legislation and the GDPR.

What personal data do you hold?

• Contact information
• Marketing preferences
• Marketing activities
• Lifestyle data
• Age Category
• Place of Residence
• Family Composition
• Household Income

We may obtain Personal Data from the following sources:

• our website at www.leafletmarketing.ie (the “Website”); and
• email;
• telephone surveys and calls, directly or through third parties working on our behalf to update our databases;
• from businesses in respect of individual contact details within such businesses; and
• data brokers who have obtained consent to use personal data for third party marketing purposes.

What legal basis do you have for processing this data?

Justification for processing Personal Data:

• Where necessary for performing a contract for which personal data is required to fulfil the requested services;;
• The data subject’s consent (where he/she voluntarily gives consent to provide us or a third party with his/her Personal Data ); and
• Where necessary for the purpose of our legitimate interests or those of a relevant third party.

Where we rely on our legitimate business interests or the legitimate interests of a third party to justify the purposes for using Personal Data, our legitimate interests will usually be:

• pursuit of our commercial activities and objectives, or those of a third party (for example, by carrying out direct marketing or conducting market research);
• compliance with applicable legal and regulatory obligations;
• development of any guidelines, improvement and development of business operations and service offerings;
• conducting analytical and statistical research and profiling.

How do you monitor compliance?

As most of the Personal Data we hold is stored electronically we have implemented appropriate IT security measures to ensure this Personal Data is kept secure. For example, we use anti-virus protection systems, firewalls, and data encryption technologies. We have procedures in place at our premises to keep any hard copy records physically secure. We use electronic access cards with secret PIN to manage access to all areas in our premises. We also train our staff regularly on data protection and information security.

For all other queries on data protection, please contact our Data Officer at:

dataofficer@leafletmarketing.ie

Data Protection Policy for Leaflet Marketing Ireland

Introduction

At Leaflet Marketing Ireland privacy and data protection rights are very important to us.

Data Protection is the safeguarding of the privacy rights of individuals in relation to the processing of personal data, in both paper and electronic format. The Data Protection Acts 1988 and 2003 (the “Data Protection Acts”) lay down strict rules about the way in which personal data and sensitive personal data are collected, accessed, used and disclosed. The Data Protection Acts also permit individuals to access their personal data on request, and confer on individuals the right to have their personal data amended if found to be incorrect.

This document outlines Leaflet Marketing Ireland’s policy to help ensure that we comply with the Data Protection Acts.

Inquiries about this Data Protection Policy should be made to: Data Officer, Leaflet Marketing Ireland, 56 Western Parkway Business Park, Ballymount, Dublin 12.

 

Data Protection Policy

 

Purpose of this policy

This policy is a statement of Leaflet Marketing Ireland’s commitment to protect the rights and privacy of individuals in accordance with the Data Protection Acts.

Collecting information.

We collect and use information to provide the following services:

• To undertake advertising, marketing, direct marketing and public relation exercises.
• To provide a full range of database management services, including supplying consumer and business data, data profiling, data hygiene, data capture and address validation and correction.
• To perform accounting and other record-keeping functions.
• To provide personnel, payroll and pension administration services
• Use of name and address data for identity verification, anti-fraud and anti-money laundering services.

Data Protection Principles

We shall perform our responsibilities under the Data Protection Acts in accordance with the following eight Data Protection principles:

• Obtain and process information fairly

We shall obtain and process personal data fairly and in accordance with statutory and other legal obligations.

• Keep it only for one or more specified, explicit and lawful purposes

We shall keep personal data for purposes that are specific, lawful and clearly stated. Personal data will only be processed in a manner compatible with these purposes as defined in the company personal data usage matrix.

• Use and disclose only in ways compatible with these purposes

We shall use and disclose personal data only in circumstances that are necessary for the purposes for which we collected the data.

• Keep it safe and secure

We shall take appropriate security measures against unauthorised access to, or alteration, disclosure or destruction of personal data and against its accidental loss or destruction.

• Keep it accurate, complete and up-to-date

We adopt procedures that ensure high levels of data accuracy, completeness and that data is up-to-date.

• Ensure it is adequate, relevant and not excessive

We shall only hold personal data to the extent that it is adequate, relevant and not excessive.

• Retain for no longer than is necessary

We have a retention policy for personal data.

• Give a copy of his/ her personal data to that individual, on request

We adopt procedures to ensure that data subjects can exercise their rights under the Data Protection legislation to access their data.

Responsibility

Overall responsibility for ensuring compliance with Data Protection Acts rests with Leaflet Marketing Ireland. However, our responsibility varies depending upon whether we are acting as either a data controller or a data processor. All employees and contractors of Leaflet Marketing Ireland who separately collect, control or process the content and use of personal data are individually responsible for compliance with the Data Protection Acts. The Data Officer is Leaflet Marketing Ireland’s Data Officer, and co-ordinates the provision of support, assistance, advice, and training within Leaflet Marketing Ireland to ensure that the company is in a position to comply with the legislation.

Procedures and Guidelines

Leaflet Marketing Ireland is firmly committed to ensuring personal privacy and compliance with the Data Protection Acts, including the provision of best practice guidelines and procedures in relation to all aspects of Data Protection.

Access Requests Policy & Procedure can be located on our website.

Access Request Form

Review

This Data Protection Policy will be reviewed regularly in light of any legislative or other relevant developments.

This Data Protection policy is available on the Leaflet Marketing Ireland’s Website.

Data Privacy Statement:

 

This is the privacy statement of Leaflet Marketing Ireland and it relates to our privacy practices in connection with our website. We are not responsible for the content or privacy practices of other websites. Any external links to other websites are clearly identifiable as such.

General statement

Leaflet Marketing Ireland respects the rights of users of our website and is committed to protecting your privacy in accordance with the Data Protection Acts of 1988 and 2003 (the “Data Protection Acts”) at all times. We will not collect any personal information (also referred to as personal data) about you on our website without your permission or otherwise in accordance with the Data Protection Acts.

(Please see below for a Glossary of technical terms used in this document).

Collection and use of personal data

Except in relation to certain specific features of our website, you do not have to provide us with any personal information (or personal data) to use our website. However, where you elect to give us your personal data through our website via online feedback forms or web email then we will treat your personal information in accordance with this paragraph.

Web browsing

By simply visiting our website you do not disclose, nor do we collect, personal data on you. All that we may know about your visit may be limited to technical data such as:

• The logical address (or IP address) of the server you used to access this website
• The top level domain name from which you access the internet (for example .ie, .com, .org, .net)
• The previous website address from which you reached us
• The type of web-browser you used
• Web traffic data.

The technical data may be used for administrative and statistical purposes and may be shared with our internet service provider. We may use this information to help us to improve our website. This technical data does not provide us with the personal data of visitors to our website.

Cookies

We do not use cookies. Should we decide to use cookies in the future, we will not do so to collect or store personal information without notifying you. [Note: You can change the settings on your browser to refuse all cookies. However, you should note that disabling cookies may result in some parts of the site not working efficiently or in slower downloads].

Giving us your personal information

Please note that where you provide us with your personal information (e.g. name, e-mail address, work address, phone and facsimile numbers and/or other contact information), through a facility provided on our website or directly to us by e-mail, you consent to us:

• Processing and administering your personal data to perform all necessary actions to give effect to your request or instruction; and
• Retaining a record of incoming and outgoing communications (e.g. email).

Information in the email we receive and send will not be disclosed to any third party without the permission of the sender unless otherwise in accordance with the Data Protection Acts.

Please note that by using Leaflet Marketing Ireland’s website you are giving us your consent to process your personal data as outlined in this Privacy Statement. Your consent is also provided to any successor or assignee of Leaflet Marketing Ireland and/or any of its businesses. We inform all persons who submit their personal data to us of these conditions by this Privacy Statement.

Security of data

Leaflet Marketing Ireland takes seriously its security obligations in respect of your personal data under the Data Protection Acts to prevent unauthorised access to, or alteration or destruction of personal data in our possession.

Right of Access

You have a right to be given a copy of any of your personal data held by us, in accordance with section 4 of the Data Protection Acts subject to certain exceptions. To request a copy of your personal data please email our Data Officer at dataofficer@leafletmarketing.ie where you can also download our Access Request Form for completion before sending it to us at Data Officer, Leaflet Marketing Ireland, 56 Western Parkway Business Park, Ballymount, Dublin 12 together with the prescribed fee of €6.35.

Please note the following important requirements:

• We ask that you use our Access Request Form to make an access request. However, use of our preferred format is not mandatory.
• We shall not process an access request unless the prescribed fee of €6.35 is received by cheque or postal money order made payable to Leaflet Marketing Ireland; and
• We do not accept access requests via telephone, email or text message.

Right of rectification or erasure

If we hold incorrect information about you which was originally submitted by you through this website, you have the right to have the data amended. Further, you have the right to have any information you have sent to us via this website erased. To request your right to rectification and/or erasure please send your request to us in writing to:  Data Officer, Leaflet Marketing Ireland, 56 Western Parkway Business Park, Ballymount, Dublin 12 together with:

• Your name and address.
• A description of the specific personal data you wish rectified.
• If you request an erasure of your personal data all your data will be erased subject to the following important notice.

We are not required to rectify or erase your data where to do so would prevent you from meeting your contractual obligations to us or where we are required to process (including retaining) your personal data for a lawful purpose in accordance with the Data Protection Acts.

Glossary of technical terms used

Cookies: Small pieces of information, stored in simple text files, placed on your computer by a web site. Cookies can be read by the website on your subsequent visits so that you can access information in a faster and more efficient way. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the web site can “remember” you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have separately furnished such information to the website.

IP address: The identifying details for your computer (or your internet company’s computer), expressed in “internet protocol” code (for example 192.168.72.34). Every computer connected to the web has a unique IP address, although the address may not be the same every time a connection is made.

Personal data: means information about you which can identify you and which is within the possession of Leaflet Marketing Ireland (e.g. your name and address).

Web browser: The piece of software you use to read web pages. Examples are Microsoft Internet Explorer, Netscape Navigator, Firefox and Opera.

Code of Conduct for Leaflet Marketing Ireland Directors:

 

1. Introduction

This Code of Conduct (“the Code”) applies to all the directors of Bascatti Limited (trading as Leaflet Marketing Ireland), hereafter Leaflet Marketing Ireland. Reference in the Code to “a connected party” (or “connected persons”) means the following:-

• spouse, parent, brother, sister, child or step-child
• a body corporate with which the director is associated
• a person acting as the Trustee of any trust, the beneficiaries of which include the director or persons at (a) above or the body corporate at (b) above
• a person acting as a partner or any person who by virtue of (a) – © above is connected with the director.

The Code outlines the responsibilities of each director to the Company and amongst other things establishes procedures for dealing with any potential conflict of interest which may arise between the responsibilities of a director and any other outside interest which he/she or a connected party may have. The Code is not a full statement of the obligations of a director arising from his/her relationship with the Company.

This Code of Conduct:

• establishes an agreed set of ethical principles to guide Directors in their business conduct;
• is designed to promote and maintain confidence and trust in the Board of generally; and
• seeks to prevent the development or acceptance of unethical practices.

2. General Responsibilities

At all times it is the responsibility of each director to ensure that he/she acts within the law in general and in particular in fulfilling his/her duties as a director. It is the responsibility of each director to satisfy himself/herself as to what is lawful or otherwise. It is also the responsibility of each director to ensure that all of these activities, whether covered specifically or otherwise in this document, are governed by the ethical considerations implicit in these procedures. Good example from directors helps ensure that proper ethical values are observed and accepted at all levels in the Group.

3. Confidentiality

The directors of the Company in the course of their duties have access to confidential information and are required to preserve the confidentiality of such information. In this regard attention is drawn to Article 93 of An Post’s Memorandum and Articles of Association which states:

“Every Chairman, Chief Officer, Auditor, Trustee, member of a committee, officer, servant, agent, accountant, or other person engaged in the business of the Company, shall keep strictly secret and confidential, and shall not disclose to any person save as may be authorised by the Board, or by some person duly authorised by the Board, or use otherwise than solely for the benefit of the Company in the course of his duties, or as may be required by law, any confidential information or any books, documents or records relating to the business, affairs and accounts of the Company and its dealings with customers, suppliers and others; and shall if required by either the Minister or the Board execute an undertaking, in such form as the Board may determine, to perform all of the obligations contained herein, and to indemnify the Company against any loss occasioned as a result of his failure to do so. For the purpose of this Article “Company” shall include all subsidiary and associated companies of the Company and “confidential information” shall mean that which is expressed to be confidential either as regards particular information or as regards information of a particular class or description”

4. Conflict of Interest

The duty of each director is to act at all times solely in the interests of the Company to the exclusion of all other considerations.

A conflict of interest exists in any situation where the personal or other interest of a director or a connected party might in any way affect the discharge by a director of his/her duties or his/her deliberations in a situation where a director or a connected party could benefit. It makes no difference that the Company does not suffer by the conflict of interest. A director or his/her relatives, friends or associates must not under any circumstances obtain any such benefit.

Directors are expected to act as follows in the event of a conflict of interest.:-

Where at a meeting of the directors any of the following matters arise, namely

• an arrangement to which the Company is a party or a proposed such arrangement, or
• a contract or other agreement with the Company or a proposed such contract or other agreement, then any director of the Company present at the meeting who, otherwise than in his capacity as a director, is in any way, whether directly or indirectly, interested in the matter shall at the meeting disclose to the Company the fact of such interest and the nature thereof and shall not vote on a decision relating to the matter and, where an interest is disclosed pursuant to this Article, the disclosure shall be recorded in the minutes of the meeting concerned, and for so long as the matter to which the disclosure relates is being dealt with by the meeting, the director by whom the disclosure is made shall not be counted in the quorum for the meeting.
• Where at a meeting of the directors a question arises as to whether or not a course of conduct, if pursued by a director, would be a failure by him to comply with the foregoing requirements of this Article, the question may be determined by the Chairman of the meeting whose decision shall be final and where such a question is so determined particulars of the determination shall be recorded in the minutes of the meeting.

Declaration of Director’s Interest

On appointment to a Board each director should furnish to the Secretary details of his employment and of all other business interests including shareholdings and professional relationships. Disclosures over and above those required by the Companies Acts will be treated as confidential. The interests of any connected party which could involve a continuing conflict of interest should be disclosed as far as they are known to the director.

Notes:-

Disclosure of minor shareholdings is at the discretion of the Board. A holding valued at more than €13,000 in the shares of a company is not considered minor. Shareholdings valued in excess of €13,000 should be disclosed although the value need not be disclosed except where the shareholding is 5% or more of the issued share capital of the particular company.

Each director should consult the Chairman if in doubt regarding disclosure of an interest of his/her own or a connected person (as defined above).

Register of Directors’ Interests

The Secretary will maintain a confidential Register of the interests of each director. The Register will be updated on a half yearly basis. Changes in interests should be notified to the Secretary in the interim as soon as possible. Only the Chairman, Chief Executive and Secretary will have access to the register. Use of the register will be strictly limited to the requirements of this Code.

Attendance at Board meetings where a conflict of interest may arise

Board or Company documents on any case which relates to Company dealings with the interests declared by a director will not be made available to the director. (Such documents are taken to include those relating to cases involving competitors to the declared interests).

As it is recognised that the interests of a director and persons connected with him/her can change at short notice, a director should, in cases where he/she receives documents relating to his/her interests or of those connected with him/her, return the documents to the Secretary.

A director should absent himself/herself when the Board is deliberating or deciding on matters in which he/she (other than in his/her capacity as a member of the board) or a person or body connected with him/her has an interest.

In such cases a separate record (to which the director will not have access) will be maintained.

Where a question arises as to whether or not a case related to the interests of a director or a person or body connected with him/her, the Chairman shall determine the question and his/her decision shall be final.

5. Gifts and Benefits

A director must not obtain personal advantage from any person dealing with the Company.

In particular a director must not accept any gifts, or inducements where the value of such could make it appear that the person giving the gift is attempting to influence the director to gain advantage. Any such gifts or inducements received should be returned tactfully with the request that no gifts be forwarded in future.

The detailed provisions on giving and receiving gifts, sponsorship and entertainment set out in the Leaflet Marketing Ireland Staff Code of Conduct should be observed by directors.

6. Staff Code of Business Conduct

Directors are required to comply with the Leaflet Marketing Ireland Staff Code of Conduct, and that Code is an integral part of this code.

7. Raising Matters of Concern

Leaflet Marketing Ireland has a Policy and Procedures for Raising Matters of Concern which refers to the disclosure of malpractice, illegal acts or omissions within Leaflet Marketing Ireland. Directors are expected to use the procedures set out in that policy to report any instances of illegal or unethical behaviour by any of the Company’s directors, managers, employees, agents or contractors. Malpractice is taken very seriously and Leaflet Marketing Ireland is committed to the highest possible standards of openness, probity and accountability.

8. Obligations

Directors are required, to the extent it is within their power, to meet the following obligations which help ensure the director and An Post comply with all applicable Government Guidelines and Codes of Practice and Irish and EU law.

• Use their reasonable endeavours to attend all Board and Committee of the Board meetings.
• Fulfil all statutory and regulatory obligations imposed on Leaflet Marketing Ireland.
• Co-operate with relevant regulatory and supervisory bodies.
• Ensure that taxation and welfare legislation is complied with. Ensure that the company does not engage in “offensive” tax avoidance strategies or transactions.
• Do not engage in unethical, illegal or criminal activities.
• Keep their tax affairs, both personal and business, in order and up to date.
• Ensure the company competes fairly in accordance with EU and Irish Competition Law.
• Adhere to the Code of Practice for the Governance of State Bodies.
• Comply with Leaflet Company Ireland’s policies on Dignity at Work, Equality and Disability.
• Ensure Leaflet Company Ireland’s Purchasing Procedures and Capital Expenditure Approval Procedures are adhered to.
• Ensure that there are adequate controls in place to prevent material fraud, irregularities or misreporting including compliance with expense reimbursement procedures.
• Directors must not accept positions or consultancy or similar work after their retirement/resignation as a director which could give rise to conflicts of interest or concerns as to confidentiality.

9. Integrity and Fairness

Directors should be (and be seen to be) selfless and objective. They are required to adhere to the highest standards of personal and professional integrity. In particular directors:

• Take decisions solely in terms of public interest. Directors will not act for personal gain or for the benefit of family and friends.
• Decide issues objectively on their merits.
• Participate in Board activities vigorously but also ethically and honestly at all times.
• Ensure the company conducts its business fairly.
• Comply with employment and equal status legislation within Leaflet Marketing Ireland.
• Value customers and treat all customers equally and encourage all staff to do likewise.

10. Loyalty

Directors take account of the interests of the shareholders when performing their duties. Directors are required to be loyal to the Company and be fully committed to all of Leaflet Marketing Ireland’s business activities. Directors acknowledge their duty to act ethically in accordance with this Code.

11. Work/Environment

Directors ensure systems, equipment and procedures are implemented to promote and preserve the health and safety of the Company’s staff. Community concerns are considered by directors when taking decisions. Leaflet Company Ireland seeks to minimise its impact on the environment.

12. Circulation of Code

This Code will be circulated to all directors for their retention. Directors will be required to acknowledge their receipt and understanding of same.

13. Failure to comply with the Code

Failure by a director to comply with this code of conduct may result in his/her actions being referred to Leaflet Marketing Ireland by the Chairman and will make a director liable to such action (including removal from the Board) as is considered necessary.

14. Review

This Code will be reviewed at least every two years.

Access Request Policy Leaflet Marketing Ireland:

 

Introduction

At Leaflet Marketing Ireland your privacy and data protection rights are very important to us.

Data Protection is the safeguarding of the privacy rights of individuals in relation to the processing of personal data, in both paper and electronic format. The Data Protection Acts 1988 and 2003 (the “Data Protection Acts”) lay down strict rules about the way in which personal data and sensitive personal data are collected, accessed, used and disclosed. The Data Protection Acts also permit individuals to access their personal data on request, and confer on individuals the right to have their personal data amended if found to be incorrect.

Inquiries about this access request policy (“Access Request Policy”) should be made to: Data Officer, Leaflet Marketing Ireland, 56 Western Parkway Business Park, Ballymount, Dublin 12.

Access Request Policy and Procedures

Purpose of this policy

This document outlines Leaflet Marketing Ireland’s Access Request Policy to help ensure that we comply with requests made under the provisions of the Data Protection Acts.

Procedures

Individuals may make a request from Leaflet Marketing Ireland as follows:

• Right to establish existence of personal data (section 3 Data Protection Acts).

Under section 3 of the Data Protection Acts an individual may write to us asking whether we keep any personal data on him or her. Where we hold such personal data on you, we shall respond within 21 days of receipt of the request, giving you a description of the data we hold on you and the purposes for which it is kept.

You do not have to pay a fee for making a request of this type under section 3 of the Data Protection Acts. Please make your request in writing to us at: Data Officer, Leaflet Marketing Ireland,  56 Western Parkway Business Park, Ballymount, Dublin 12 stating that you are making your request under section 3 of the Data Protection Acts. Please note that before we respond to your request we may require that you provide us with satisfactory evidence of your identity and address.

We do not accept section 3 requests via telephone, email or text message.

• Making an Access Request (section 4 of the Data Protection Acts).

Under section 4 of the Data Protection Acts, you may receive a copy of your personal data held by Leaflet Marketing Ireland upon written request, subject to payment of a fee of €6.35.

In order to respond to your section 4 request we ask you to:

• Download the Access Request Form
• Please complete, sign and date the form and be specific as possible about the information you wish to access.
• Attach a photocopy of your proof of identity and address to the Access Request Form.
• Enclose a cheque or postal money order payable to Data Ireland in the amount of €6.35 and:
• Post the Access Request Form to: Data Officer, Leaflet Marketing Ireland, 56 Western Parkway Business Park, Ballymount, Dublin 12
• If you cannot download the Access Request Form from the internet please write to us requesting a form from: Data Officer, Leaflet Marketing Ireland, 56 Western Parkway Business Park, Ballymount, Dublin 12and we shall send you a copy by return post. Use of the Access Request Form is not mandatory. Completing the Access Request Form should enable us to process your section 4 request more efficiently. However, please note that we may not provide you with the data requested if you do not meet the requirements at points 3)-5) above.

Please note that we reserve the right not to process and release data requested where you have not complied with the requirements of section 4 of the Data Protection Acts including where:

• You have not paid the prescribed fee of €6.35. All payments should be made by cheque or postal money order made payable to Leaflet Company Ireland’;
• Your request is not made in writing. We do not accept access requests via telephone, email or text message.

Responding to your Access Request under section 4

Once we have received your fully completed Access Request Form, your proof of identity and address and the prescribed fee, we shall respond to you within the statutory period of forty (40) days.

If you are not satisfied with the outcome of your access request you are entitled to make a complaint to the Data Protection Commissioner who may investigate the matter for you.

Responsibility

Overall responsibility for ensuring compliance with the requests made under the Data Protection Acts rests with Leaflet Marketing Ireland. However, our responsibility varies depending upon whether we are acting as either a Data Controller or a Data Processor.

All employees and contractors of Leaflet Marketing Ireland who separately collect, control or process the content and use of personal data are individually responsible for compliance with the Data Protection Acts. The Data Officer is Leaflet Marketing Ireland’s Data Protection Officer, and co-ordinates the provision of support, assistance, advice, and training throughout the company to ensure we are in a position to comply with the legislation.

Review

This Access Request Policy will be reviewed regularly in light of any legislative or other relevant developments.