Lowara Distributions Ireland Data Protection Policy
Effective Date: 23/06/2025
Tricel (Baldonnell) Ltd, trading as Lowara Distribution Ireland (hereinafter referred to as “Lowara Distribution Ireland” or “the Company”), is a company registered in Ireland under registration number IE497442, with its registered office at 50 Broomhill Close, Tallaght, Dublin 24, D24 APP8, Ireland.
1. SCOPE
The GDPR Personal Data Protection Policy of Lowara Distribution Ireland is applicable across all systems, processes, and personnel involved in handling personal data. This includes board members, directors, employees, suppliers, and other third parties with access to Lowara Distribution Ireland’s information systems. The policy governs data collection, storage, and processing activities, ensuring compliance with GDPR and other relevant legislation. Specific areas covered include obtaining and processing personal data, data subject rights, breach notifications, and data transfers outside the EU. 1.3
2. OUT OF SCOPE
The GDPR Personal Data Protection Policy for Lowara Distribution Ireland does not cover certain items that fall outside its boundaries and applicability. These out-of-scope items include data processing activities not related to personal data of EU citizens, non-compliance with GDPR by third-party entities not engaged with Lowara Distribution Ireland’s systems, and internal processes unrelated to data protection such as non-IT operational workflows. Departments or areas not specifically mentioned within the policy, such as general business strategies and non-personal data analytics, are also not covered under this policy. Additionally, any noncompliant actions by stakeholders that fall outside the outlined procedures and safeguards are considered beyond the scope of this document.
3. RESPONSIBILITIES
Any staff member of Lowara Distribution Ireland who is involved in the collection, storage or processing of personal data has responsibilities under the legislation. Any staff member involved in the processing/storing of personal data should make sure;
- to obtain and process personal data fairly.
- to keep such data only for explicit and lawful purposes.
- to disclose such data only in ways compatible with these purposes
- to keep such data safe and secure.
- to keep such data accurate, complete and up-to-date.
- to ensure that such data is adequate, relevant and not excessive.
- to retain such data for no longer than is necessary for the explicit purpose.
Any data access requests received should be forwarded immediately to the Manager, Compliance & Information Management.
The data subject also has rights under the GDPR. These consist of:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
4. Timescales
Each of these rights must be supported by appropriate procedures within Lowara Distribution Ireland that allow the required action to be taken within the timescales stated in the GDPR.
These timescales are shown below:
Data Subject Request Deadline
DATA SUBJECT REQUEST | DEADLINE |
THE RIGHT TO BE INFORMED | The right to be informed When data is collected (if supplied by data subject) or within one month (if not supplied by data subject) |
THE RIGHT OF ACCESS | One month |
THE RIGHT TO RECTIFICATION | One month |
THE RIGHT TO ERASURE | Without undue delay |
THE RIGHT TO RESTRICT THE PROCESSING | Without undue delay |
THE RIGHT TO DATA PORTABILITY | One month |
THE RIGHT TO OBJECT | On receipt of objection |
RIGHTS IN RELATION TO AUTOMATED DECISION MAKING AND PROFILING | Not specified |
5. Policy
As per GDPR regulation, 2016 version, there are 7 principles involving personal data and how companies should treat these aspects. These are as follows, as per Chapter II, Article 5.1.
5.1 Personal data shall be:
5.1.1 processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
5.1.2 collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
5.1.3 adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
5.1.4 accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
5.1.5 kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
5.1.6 processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
5.2 The controller:
shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’). Lowara Distribution Ireland complies with these principles by using business workflows based on technology that use metadata in order to search, discover, classify, label, protect and apply actions at all levels of personal data. Also, Operational Security Procedures defined support and provide the specific guidelines for all teams involved including IT Support, Customer Support or Line of Business
6. MONITORING AND REVIEW
Monitoring and periodically reviewing the effectiveness of the GDPR Personal Data Protection Policy at the company involves a structured process to ensure continuous compliance and improvement. The process includes regular audits, employee training sessions, and periodic data protection impact assessments. Key performance indicators (KPIs) related to data protection are tracked and reported to senior management. Triggers for updates or revisions to the policy include significant changes in legislation, the identification of new risks or vulnerabilities, data breaches, and feedback from internal audits or external regulatory bodies. Any changes in business operations or IT infrastructure that impact data processing activities also prompt a policy review to maintain alignment with GDPR
requirements.
7. SUPPORTING DOCUMENTATION
- Data Subject Request Procedure.
- Data Protection Impact Assessment Process Document.
- Personal Data Breach Notification Procedure
8. ACKNOWLEDGMENT AND COMPLIANCE
Lowara Distribution Ireland ensures compliance with its GDPR Personal Data Protection Policy through several actionable steps and measures. Every staff member involved in handling personal data is responsible for understanding and adhering to good data protection practices. The company provides comprehensive training to all employees on data protection principles. Our team oversees compliance efforts, ensuring all legal bases for data processing are clear and unambiguous. Lowara Distribution Ireland follows strict rules regarding obtaining consent and processes data in line with GDPR requirements. Regular reviews and audits of data processing activities are conducted to maintain adherence to the policy, incorporating privacy by design in all new or significantly altered systems. Additionally, clear documentation of processing activities and established procedures for responding to data subject inquiries further support compliance.