Introduction
Skillnet Ireland CLG ("Skillnet", "we", "us") is the controller of the personal data described in this notice. Our registered office is at 5th Floor, Q House, Furze Road, Sandyford, Dublin 18, Ireland.
This Data Privacy Notice provides you (the data subject) with information about why and how we process your personal data in connection with the Upskill SME Training Grant. It explains how Skillnet Ireland collects, processes, uses, stores and protects personal data provided during the grant application, grant administration, grant payment, monitoring and reporting processes.
The information provided within this Data Privacy Notice is for guidance purposes only and does not constitute legal advice or analysis.
Data Processing Activities
Purpose of the Programme
The Upskill SME Training Grant provides financial support to eligible SMEs to invest in the upskilling of their workforce. Personal data is collected and processed to assess eligibility, administer grant applications, validate participation, process grant payments, carry out monitoring and compliance activities, meet State Aid obligations and support programme reporting.
What personal data we collect
We collect and process the following categories of personal data:
Data Type |
Description |
|---|---|
|
Identity Data |
First name, surname, employee name, applicant name, job title, occupational category, role. |
|
Contact Data |
Business email address, business phone number, registered business address, county, Eircode, country. |
|
Business Registration Data |
Company registration number, business name, company tax clearance access number (TCAN), company |
|
Financial Data |
Bank name, account name, IBAN, BIC, bank statements, wage period data, wages paid, grant payment |
|
Programme Data |
Grant applications, training provider details, training course information, attendance, participation records, |
|
State Aid Data |
De Minimis Aid declarations, previous aid received, grant approvals, grant amounts and associated |
|
Communications Data |
Email communications, call recordings, screen recordings and applicant support interactions through |
|
Technical Data |
Website usage information, cookie identifiers, browser/device information where users interact with |
|
Marketing Preferences |
Preferences relating to email updates, newsletters or marketing communications. |
Please note, we do not intentionally collect special‑category data (e.g. health or ethnicity) unless a specific programme requires it and you provide it voluntarily or we are legally obliged to collect it.
Lawful basis for collecting and processing personal data
The lawful bases for processing personal data under this programme are:
- Legal Obligation
- Contractual Necessity
- Public Interest
- Consent (for website cookies and marketing communications only)
Personal data is processed to administer the grant, distribute public funding, carry out programme monitoring and compliance activities, meet State Aid obligations and fulfil statutory and regulatory requirements.
Why we collect your data, and who collects it
Skillnet Ireland has appointed Fexco Group as a processor to administer elements of the Upskill SME Training Grant. SmartSimple acts as a sub-processor supporting grant application management and storage. Personal data is collected directly from SME owner-managers, authorised representatives, employers and employees participating in grant-supported activities.
Data is stored within approved programme administration systems, including SmartSimple, Genesys, SmartAssist, Fexco Corporate Payments and Looker Reporting.
For more information, please see the Fexco Data Protection Statement, the Smart Simple Privacy & Cookie Policy and the Smart Simple Data Protection Policy.
Who will see your data
Access to personal data is restricted to authorised personnel who require access to fulfil their responsibilities. Your data may be accessed by:
- Authorised personnel within Fexco Group.
- SmartSimple administrators supporting programme operation.
- Relevant Skillnet Ireland employees.
- Fexco Corporate Payments personnel responsible for grant payment administration.
- Approved monitoring, audit and compliance providers.
- Department of Further and Higher Education, Research, Innovation and Science (DFHERIS).
- Department of Enterprise, Trade and Employment (DETE) State Aid Unit where required under State Aid legislation.
Data is shared only where necessary to administer the programme, comply with legal obligations, conduct audits, fulfil State Aid reporting requirements or provide programme-related services.
The information you share with us will not be published in a way risks your identity and only shared with the agreed programme partners for course management, reporting and funding purposes, and to assess the success of the training programme. Your data will not be disclosed to any other third parties without your knowledge or consent.
How long we keep your data
When you share your data with us, we will store your personal data only for as long as necessary for the purposes and legal basis set out at the time of collection. For the purpose of this programme, personal data is retained only as long as necessary to fulfil programme, legal and regulatory obligations.
Data Category |
Retention Period |
|---|---|
|
Applicant and employee personal data |
2 years, then anonymised |
|
Call recordings |
2 years |
|
Screen recordings |
1 year |
|
Applicant support communications |
2 years |
|
Operational reporting data |
Contract duration plus 2 years |
|
De Minimis State Aid business records |
10 years |
Security and storage of your personal data
Skillnet Ireland, Fexco Group and their approved processors implement appropriate technical and organisational measures to protect personal data from unauthorised access, alteration, disclosure, loss or destruction.
Personal data is stored within secure systems with role-based access controls, authentication controls, encryption and contractual safeguards in place. Data processors are subject to written agreements and are required to implement appropriate security measures in accordance with GDPR requirements.
Data Protection Rights
Subject to applicable law, you may have the right to:
- Access personal data held about you.
- Request correction of inaccurate or incomplete data.
- Request deletion of your personal data in certain circumstances.
- Request restriction of processing.
- Object to certain types of processing.
- Withdraw consent where processing is based on consent.
- Lodge a complaint with the Data Protection Commission.
Individuals wishing to exercise their rights or raise concerns regarding the processing of their personal data may contact Skillnet Ireland through the contact details published on the Skillnet Ireland website.
Links to other sites
From time to time our website, social media posts or emails may contain links to and from other websites. Please note that if you follow a link to any of those websites, those websites have their own privacy policies, and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
Accessibility, Equality & Human Rights
Skillnet Ireland is committed to processing personal data fairly, lawfully and transparently in line with GDPR principles and Irish data protection legislation. We aim to provide information in accessible formats where required and ensure that data processing activities respect equality, accessibility and fundamental rights principles.
Glossary of Key Terms
- Controller – an organisation that decides why and how personal data are processed.
- Processor – an organisation that collects or processes personal data on behalf of the controller.
- Sub-processor – an organisation that may collect, access or process data on behalf of the processor.
- GDPR – The EU General Data Protection Regulation (2016/679).
- Personal data – Any information relating to an identified or identifiable person.
- Processing – Anything done with personal data, from collection to deletion.
- Programme – A training initiative funded or supported by Skillnet Ireland.
Appendix
Data Processing Activities and Lawful Basis
Data Type |
Purpose |
Lawful Basis |
|---|---|---|
|
Identity Data |
Verify applicants, assess eligibility, validate training participation and administer grants |
Contractual Necessity |
|
Contact Data |
Applicant communications, grant administration, programme support and compliance activities |
Contractual Necessity |
|
Business Registration Data |
SME eligibility assessment, State Aid compliance, reporting and auditing |
Contractual Necessity |
|
Financial Data |
Grant payment processing, financial validation, audit and compliance activities |
Contractual Necessity |
|
Programme Data |
Training validation, programme monitoring, impact measurement and reporting |
Contractual Necessity |
|
State Aid Data |
Compliance with De Minimis State Aid requirements and regulatory audits |
Legal Obligation |
|
Communications Data |
Applicant support, quality assurance, complaint handling and programme administration |
Contractual Necessity |
|
Technical Data |
Website analytics and service improvement |
Consent |
|
Marketing Preference Data |
Distribution of newsletters and updates |
Consent |
Appendix 1
The following outline what system holds your personal data, the data recorded and the data retention periods.
System |
System Purpose |
Data Recorded |
Data Retention Period |
|---|---|---|---|
|
Skillnet Ireland |
Business data only. Personal data will only be held if you contact us about out |
Phone numbers and email addresses supplied by |
6 months after you have finished |
|
Skillnet Ireland |
State Aid Requirement for De Minimis funding. |
Identification of the beneficiary Registered Company Address Amount of aid granted Date of award (date of grant approval) Granting authority (DFHERIS) Aid instrument Economic sector classification |
10 years |
|
Smart Simple |
Hold grant application and contact details of the applicant. Personal data of the employees pertaining to specific |
Please see appendix 2 for all data points collected |
2 years |
|
Genesys |
Call and Email contact platform of the applicant. |
Call recording & email contact information Screen recording of communications with applicant |
2 years 1 year |
|
Smart Assist |
Knowledge Management and email assistance tool. |
Email contact information |
2 years |
|
Fexco Corporate Payments |
SME account details of payment of grant |
Bank accounts Names Address Applicant Contact information |
10 years in line with De Minimis |
|
Looker Reporting |
Reporting platform with holds Operational reporting |
Genesys call/email volumes, call ids |
Length of contract, plus 2 years |
Appendix 2
Data Collected via Smart Simple for the Upskill SME Training Grant
Business Contact info:
- Title
- Name
- Business Email Address
- Business Phone Number
- Job Title
- Role
Business Registration Fields:
- Company Registration Number
- Business Name
- Registered Business Address
- County
- Eircode
- Country
- Business descriptor
- Website Address
- Primary Industry Sector
- NACE Code Classification Level 4
- Date business established
Business Eligibility (and training application):
- SME status/classification
- No. of employees
- Prepopulated level of turnover
- Prepopulated level of annual balance sheet
- De Minimis Aid details
- Amount and type of De Minimis Aid previously received
- Statement that no De Minimis Aid has been received
- Company Tax Clearance Access Number (TCAN)
- Company Tax Reference Number
Training Information:
- Training Information (Provider name; type of training; duration; location; start and end Date; payment details, no of employees completing training)
- Training/Module completion
Business Bank Details:
- Bank Name
- Account Name
- IBAN
- BIC
- Bank Statement
Application information (Employee/personal Data):
- Trainee (Employee) information submitted in for the purpose of application:
- Employee as resident in Republic of Ireland
- First Name
- Surname
- Job title
- Occupational Category
- Last 3 digits of PPSN
- Training related costs and receipts
- Number of training days being applied for
- Employee payslip (PPSN redacted)