Data Protection Notice For Customers
1 About this Data Protection Notice
This notice tells you how Focus Ireland uses your personal data when you are a customer. It explains what information we collect, why we collect it, how we use it and who we might share it with. It’s a way for us to be transparent about how we respect and protect your data and privacy.
2 Who we are
Focus Ireland is a registered charity that helps people get and keep a home, to end homelessness for good. We work with people all over Ireland and offer many different services to support people.
You can find out more information on who Focus Ireland is and what we do on our website – www.focusireland.ie .
3 Our contact details
If you have any queries or concerns in relation to our processing of personal data or the contents of this Data Protection Notice, we would be happy to help. You can contact us by writing to, emailing, or phoning our head office:
Focus Ireland
9-12 High Street info@focusireland.ie
Christchurch
Dublin 8 +353 (0) 1 881 5900
D08 E1W0
Contact details for Data Protection Officer (DPO):
You can also contact our Data Protection Officer (DPO) directly using the contact details below:
Data Protection Officer (DPO) dpo@focusireland.ie
9-12 High Street
Christchurch
Dublin 8 +353 (0) 1 881 5900
D08 E1W0
4 What data we process and why
Personal data is any information which identifies you or could identify you.
The below table summarises the type of data we process for different activities we do.
| Business Activity | What data we collect | Lawful Basis |
| Advice and Information (A&I) | When you contact us, we will collect some information to ensure we give you the best advice and help. This includes your name, date of birth, and contact details. We may also need to know other information that will help us understand your case and assist you. | Legitimate Interests of Focus Ireland to provide advice and information to the public in line with the charitable purpose. |
| Coffee Shop | We provide food and support at our Coffee Shop on Eustace Street, Dublin. We keep a record of customers’ names and any purchases they make. We will keep a record of any advice or help we provide, any food or drinks given on credit, and any incidents that need to be noted for health and safety. | Legitimate Interests of Focus Ireland to record information on the customers of its coffee shop for the purpose of supporting customers in line with the charities mission, offering customers credit. |
| Case Management | The aim of case management is to support people who need to find a home or are at risk of losing their home. It varies for each person but can include making support plans, assessing needs, advocating, keeping case notes, and helping with housing. This might mean finding suitable housing or keeping current housing. It can also involve support with training, education, and employment. | Consent
We will seek your consent to work with you in case management. |
| Risk assessments | For some services, we might do risk assessments, like for staff working alone with customers. This means finding any risks when working with people and making plans to handle them | Legal Obligation to protect the health, safety and welfare of Focus Ireland employees or customers.
|
| Complaint handling | When we get complaints, we will use certain information to handle them. This includes details of the complaint, any evidence like CCTV footage or witness statements, and any related messages, phone call records, letters, and emails. | Legitimate Interest of Focus Ireland to manage complaints |
| CCTV | We have CCTV cameras at our offices and properties. If you visit or live there, you might be recorded on our cameras. | Legitimate Interests: We use CCTV for our legitimate interests relating to health, safety and welfare and crime prevention and detection. |
| Administration & Operational Management | Your data might be used by Focus Ireland for administrative tasks or managing operations. This could include reports for covering staff taking leave, understanding the resources we need, tracking key risks and performance, knowing more about our customers and their needs, advocating for policy changes, and improving our services (reports are anonymised unless customer details are necessary). | Legitimate interest: Focus Ireland needs to process this data to ensure the efficient and smooth operation of the business. |
| Charity Governance | Your data might be used to help us carry out our charitable work, meet legal and financial reporting requirements, and comply with laws. | Legal Obligation:
Charities Act 2009 |
4.1 Processing Special Categories of Personal Data
Some data is considered “special” under GDPR and needs extra protection because its misuse can cause more harm than other types of data. The special data we might handle includes:
- Data relating to your health including physical and mental health
We might use your health information in these ways:
- If your health issues affect your ability to find accommodation, like needing accessibility features.
- If you need support for health concerns, such as finding counselling, addiction services, or a suitable doctor.
- If there are health issues we should know about when working with you, like allergies or sensory needs.
- If your health could pose a risk to staff or other customers.
- Data relating to your racial or ethnic origin
We might use information about your race or ethnicity only if it’s relevant in supporting you. For example, some people might be homeless because of problems with their residency status in Ireland, getting a PPS Number, or accessing social welfare benefits.
- Data relating to your religious or philosophical beliefs
We do not ask customers what their religious or philosophical beliefs are but if you share this information with us and we may record it if relevant to our work.
- Data relating to your sexual orientation.
We do not ask customers what their sexual orientation is but this information may become known to us if you share it with us, we may record this information if it is relevant to our work. For example, some customers experience homelessness due to their sexual orientation or some customers may need support in understanding or dealing with their sexual orientation.
It is important to note that Focus Ireland treats all customers equally regardless of their health status, racial or ethnic origin, philosophical or religious beliefs or sexual orientation. This information will only be used where it is relevant to your case and how we can support you.
When we handle sensitive data, we need a clear reason to do so. We might use this data for the following reasons:
- For our legitimate activities as a non-profit organization, with proper protections in place.
- If you have made the information publicly available.
- If the information is needed for legal claims or defences.
- If the information is needed for legal advice or proceedings.
- If you have given us explicit permission to use the data.
5 Profiling and Automated Decision Making
You have the right to not be affected by decisions made only by computers or automated systems, especially if those decisions could have a big impact on you. Focus Ireland does not use automated decision-making.
6 Information provided to us by you about others or others about you
Sometimes, you might give us someone else’s personal information, or they might give us yours. When this happens, make sure you get their permission first, and they should do the same for you.
If you give us someone else’s personal information, let them know about this Data Protection Notice. By sharing their information with Focus Ireland, you’re confirming that they have read this notice and agreed to how we will use their data
7 Data Sharing
We may share your information with organisations that are not Focus Ireland or Focus Housing Association to help us operate. Below are some examples of when your data may be shared.
7.1 Focus Housing Association
Focus Housing Association is the property arm of Focus Ireland. The two companies work closely together and information will be shared between the companies on a need to know basis and where operationally required.
7.2 Data Processors
We use services and systems from other companies to help us with our work. Sometimes, we need to share your personal data with these companies. They must follow strict security rules to protect your data according to GDPR. They can’t use your data for their own purposes unless they are allowed to by law. They can only use your data for specific tasks we tell them to do, and they must keep your information confidential.
We have companies handling data for us in the following business processes:
- IT Support
- Our electronic filing system (SharePoint)
- Our Customer Database
7.3 Third Party Recipients
- For many of our activities, we need to share data with third parties who are not working directly for us or on our behalf. These third parties include Tax authorities (e.g. Irish Revenue Commissioners)
- Law enforcement (where required for the investigation, detection, or prosecution of criminal offences)
- Standards bodies
- Statutory bodies (e.g. the Residential Tenancies Board (RTB), the Charity Regulator)
- Solicitors
- Insurers
- Financial Institutions
7.4 Local Authorities
We might share your information with local authorities that fund our services under section 10 of the Housing Act. This is needed so they can check how well our services are working and make sure they meet your needs.
We might also share your information with local authorities when we are helping you or advocating for you.
7.5 The National PASS Office (PASS System)
Some of our services are funded under section 10 of the Housing Act 1988. When this happens, we record your data on the PASS system.
PASS (Pathway Accommodation and Support System) is an online system used by all homeless service providers and local authorities in Ireland. The National PASS Office manages this system, and Focus Ireland uses it on their behalf.
For more information about PASS, please visit this link https://www.homelessdublin.ie/info/pass. Your support worker will let you know if your data will be saved on PASS.
7.6 Tusla (The Child and Family Agency)
We operate a number of services on behalf of Tusla. In this case, Tusla are the Data Controller of your information and Focus Ireland is a Data Processor. All data protection matters will be forward to the Data Controller Tusla.
We have certain legal obligations to report Child Protection and Welfare concerns to Tusla. In most cases we will let you know if we are making any reports to Tusla.
7.7 HSE
We operate some services on behalf of or in partnership with the HSE, in such cases your data will be shared with the HSE and they may be the data controller of the service.
7.8 Other Partnerships
We also operate some services in partnership with other organisations such as other charities. In this case data may be shared with that organisation.
8 Data transfers outside of the EEA
We do not transfer customer data outside of the EEA.
9 How long we keep your data for
We will only keep your data for as long as necessary or as required by law. The table below shows how long we keep certain types of data on our customers:
| Data | Retention |
| Adult Customer Files | 7 years after the customer case is closed |
| Family Files | 7 years after the family case is closed |
| Child Support Workers files on Children and Young Persons | 7 years after the child/young person’s 18th Birthday |
| Child care records | 2 years from the date the child no longer uses the child care facility |
| Advice and Information records that do not progress to case management | 12 months after the last interaction with the customer |
| PETE Records | 2 years after the customer case is closed |
| CCTV Recordings | 30 days from the date the footage was recorded |
| Text Messages | May be deleted 90 days from the date the message was sent or received |
| Emails | No longer than 7 years from the date the message was sent or received. When an employee leaves Focus Ireland their emails may be deleted. |
| Records of complaints | 7 years from the date the complaint is deemed closed |
| Child Protection Reports, Concerns and Records | Retained indefinitely |
10 Your rights
You have the following rights in relation to your data. You can send us a request about any of the rights outlined below. We will do our best to handle your request as soon as possible and within one month of receiving your request. However, restrictions may apply in certain situations. Where a restriction applies, or where we will need more than one month to fulfil your request, we will tell you the reason for the delay or the restriction within one month.
Under the General Data Protection Regulation (GDPR), you have several rights:
- Access: You can ask to see the personal data a company has about you.
- Correction: If the personal data a company has about you is incorrect, inaccurate or incomplete, you can ask for it to be corrected.
- Restriction: You can limit how a company uses your personal data.
- Deletion: You can ask a company to delete your personal data when it’s no longer needed or if processing it is unlawful.
- Data Portability: This means you can copy, move, and transfer your personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
- Objection: This means that you can say no to certain types of uses of your personal data.
- Automated Processing: You have the right to avoid decisions made about you based solely on automated processing, including profiling, which have significant effects on you
If you want to use any of the rights we just talked about, tell your support worker or, you can get in touch with our Data Protection Officer. You can find their contact info in the first section of this notice.
10.1 Withdrawing and Amending your Consent
If we’re using your personal information because you consented to us using it, remember you can change your mind at any time. If you want to do this, just get in touch with your project worker.
You can also withdraw or amend your consent by emailing help@focusireland.ie or dpo@focusireland.ie or phoning 01 881 5900.
10.2 Right to Complain to the Data Protection Commissioner (DPC)
The Data Protection Commissioner (DPC) is like a watchdog for personal data safety in Ireland. If you think your personal data isn’t being handled right, or if you’re unhappy with how we’re using your data, you can complain to the DPC. Before you do that, though, it’s a good idea to first talk to our Data Protection Officer if you’re worried about how your data is being used. If you decide you want to complain to the DPC, you can find out how to reach them on the Data Protection Commission’s homepage Homepage | Data Protection Commission.
11 Security of your Data
Focus Ireland really cares about keeping your personal data safe. We do everything we can to protect any personal data you give us. If we have any paper records of your data, we keep them safe in locked cabinets or rooms. We also have security cameras and alarms at our buildings. We also protect any digital data on our computers and devices. For example, our laptops and PCs have encryption. We use Multi-Factor Authentication (MFA), which is an extra layer of security. Our mobile devices are protected with passwords or FaceID/TouchID. We control who can access data and only allow it if they really need to know. We also use firewalls, antivirus protection, endpoint protection, and backups to keep data safe. All our employees get regular training on how to protect data and keep our IT systems secure. We even teach this to new employees when they first join us.
12 Updates to this Notice
Any changes to this notice will be updated here. This notice was last updated October 2024.