Data Protection Notice
If you have any questions about our use of your personal data, please contact our Data Protection Officer:
A. O’Shaughnessy,
Transport Infrastructure Ireland,
Parkgate Business Centre,
Parkgate Street,
Dublin 8,
D08 DK10.
Tel: +353 1 646 3600
Email: dataprotection@tii.ie
Personal Data We Process
TII holds the following categories of personal data in the context of providing services to the public and fulfilling its statutory duties and we may collect and process some or all of the following personal data in relation to you:
TII operates a number of CCTV systems that record images from the national road network. These CCTV systems are operated to assist with traffic monitoring and may be used for enforcement by An Garda Síochána (e.g. the operation of average speed cameras), monitoring of road weather conditions, security of infrastructure, and dealing with queries and complaints from the public. TII also operates CCTV at its Parkgate Business Centre office for the purposes of security and health and safety. In addition, from time to time TII operates a portable junction CCTV camera to monitor red light running affecting the light rail network and also to monitor safety at particular locations on the national road network.
TII receives correspondence from a wide range of sources including local authorities, the general public and elected representatives. This includes correspondence received by way of post, electronic mail, social media channels and fax messages. While TII does not ask for health data, some correspondence received by TII may occasionally include health data, which is a special category of personal data. In addition, TII receives Freedom of Information, Access to Information on the Environment and Subject Access Requests which may include personal data.
TII, through a third party, operates a Toll Site on the M50. As part of this service customer data is held relating to vehicle ownership details, bank account/credit card/debit card details of toll account holders and similar records, along with vehicle image capture and customer telephone call recordings. We also hold data in relation to our toll enforcement operations, which are carried out through a third party.
TII maintains, and makes available on the TII Publications website, a register of individuals authorised and registering to act as Approved Independent VRS Chartered Engineers on national road projects. This includes personal contact data and any qualifications and work experience that are relevant to the role of Approved Independent VRS Chartered Engineers.
TII holds names, addresses, emails, phone numbers, land ownership details, Book of Reference for light rail/Metro schemes, leases/tenancy agreement details of tenants for properties in the ownership of TII and CPO schedules for national road schemes where land acquisition is undertaken directly by TII. TII also holds names and land details, including compensation of affected land/property owners, in connection with schemes undertaken by local authorities on TII’s behalf.
TII may be provided with information in relation to accidents that occur on the national road network in connection with the operation and maintenance of such roads, and has limited and restricted access to the collision records within the An Garda Síochána Pulse System to determine whether there is an engineering response required to a collision.
TII may also hold information / public submissions received in the course of Public Consultation, Environmental Impact Assessment, Appropriate Assessment, Strategic Environmental Assessment and Compulsory Purchase Order preparation in relation to national roads, the National Cycle Network Plan, light rail and Metro.
TII uses UbiPix technology to carry out Road Safety Inspections on the national road network in accordance with our obligations under the EU Directive on Road Infrastructure Safety Management. We also use UbiPix technology to assist in the safe design and safety reviews of the Luas network and to carry out asset management on the national road network. This involves the use of digital, GNSS (Global Navigation Satellite System) enabled cameras which may inadvertently capture images of vehicle license plate numbers and individuals at a low resolution.
TII uses a video-based automated incident detection (VAID) system technology in the Dublin Tunnel to capture incidents that may occur in the tunnel, in particular relating to traffic movement. The VAID system involves the use of digital cameras which will create video clips in the event of an incident in the tunnel which will be alerted to operators for subsequent review. The video clips may capture vehicle license plate numbers, drivers, passengers and pedestrians within the tunnel and road traffic accidents which may include the capture of special categories of personal data in the form of health data. The main purpose of the VAID system is to monitor traffic movement and incidents in the Dublin Tunnel and to ensure a safe and efficient network of national roads. In limited instances the VAID video clips may also be used by TII and/or its service provider for ancillary purposes, including drafting incident reports and health and safety reports, pursuing property damage claims, establishing, exercising or defending other legal claims and other related purposes.
Purposes of Processing and Legal Basis
TII processes personal data in order to:
- Provide and maintain infrastructure and services in connection with the national road network and light rail infrastructure in accordance with TII’s statutory obligations;
- Receive services from third party service providers;
- Carry out research and statistical analysis;
- Respond to queries and complaints from members of the public; and
- Comply with its statutory obligations.
Our legal basis for collecting and using this information is that such processing is necessary for us to comply with our legal and regulatory obligations and for us to carry out our tasks in the public interest and/or in the exercise of official authority vested in us. In addition, where we process your personal data in order to carry out research and statistical analysis, our legal basis for this processing is that it is necessary for such research or statistical purposes (only in circumstances where we have implemented suitable and specific measures to safeguard your fundamental rights and freedoms). In certain limited circumstances our processing of your personal data may be on the basis of your consent – where this is the case you will be asked to give a positive indication of that consent. Where correspondence received by TII contains health data which you have volunteered, our processing of such data is with your explicit consent.
Sources of Personal Data
As well as collecting information from you directly, TII may receive or collect information about you from the following sources:
- Your public representative, where you have engaged a public representative to make representations on your behalf;
- The Land Registry and the Registry of Deeds;
- Our third party service providers, such as the operator of the eFlow system, Luas operator and Motorway Maintenance and Renewal Contractors.
Transfers Abroad
In connection with the above TII may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that TII does so, TII will ensure that appropriate measures are in place to comply with its obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission and/or other transfer obligations/arrangements as may be specified by the Commission. Further details of the measures that TII has taken in this regard are available from the TII Data Protection Officer using the contact details below.
Recipients of Personal Data
We may disclose your personal data to other organisations in connection with the above purposes, in the following circumstances:
- We may share personal data with service providers and sub-contractors who assist us with the operation of aspects of our services and functions, such as outsourced service providers, IT services providers, professional advisers and auditors. In particular, if we receive a complaint in relation to the Luas/ eFlow toll system/PPP Companies, we may forward a copy of the complaint to the companies who operate these services on our behalf.
- If you send us a comment, complaint or query in relation to a matter that we are not responsible for, we will ask your permission to pass on your communication to the relevant third party.
- Where we are under a duty to disclose or share personal data in order to comply with any legal obligation, or to protect the rights, property or safety of TII, our customers, or others.
- Where required or permitted by law, we may share your personal data with other public authorities and bodies, such as the Gardaí or other law enforcement authorities for the purposes of the prevention, investigation or detection of crime. We may also share personal data with relevant public authorities and bodies for road and incident management purposes, including personal data appearing in CCTV feeds, from the national road network.
- Where we are otherwise permitted by law.
Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Security of Your Information
TII has adopted appropriate technical and organisational security measures to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction or damage. We will also ensure that our agents or third party service providers who process your data are required to keep your data safe and secure.
Your Rights
You have the following rights, in certain circumstances, in relation to your personal data:
- the right to access your personal data;
- the right to request the rectification and/or erasure of your personal data;
- the right to restrict the use of your personal data;
- the right to object to the processing of your personal data;
- the right to receive your personal data, which you provided to us, in a structured, commonly used and machine readable format or to require us to transmit that data to another data controller;
- where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.
Complaints
If you are dissatisfied with the way we have used your information or addressed your rights, you have the right to make a complaint to the Data Protection Commissioner by emailing info@dataprotection.ie.