Privacy, Cookies & Retention Notice

Effective date: 30 September 2025
Website: shirleykavanagh.com
Controller: Shirley Kavanagh (“Controller”)
Contact for all data queries: admin@shirleykavanagh.co

1. Privacy Notice

This Privacy Notice explains how we collect and use personal data via this website in a way that is lawful, fair, and transparent, in line with the GDPR and the Irish Data Protection Commission (DPC) guidance on the principles of data protection.

1.1 What personal data we collect

  • Contact details you provide (e.g., name, work email, organisation, role, and the content of your message) when you email us or submit a form.

  • Newsletter details (if you subscribe): name and email.

  • Event/meeting details (if applicable): name, email, organisation, role, and scheduling preferences.

  • Technical/cookie data: We only set strictly necessary cookies for basic site functionality. If we add analytics or marketing cookies in future, we will ask for your consent and provide a separate Cookie Notice (see Section 2).

1.2 How we use your data (purposes & lawful bases)

Purpose Examples Lawful basis
Responding to enquiries Replying to your email or contact-form message Legitimate interests (to operate our website and respond to queries). You can object at any time.
Providing services / preparing to contract Scoping work, proposals, scheduling sessions Contract (or steps prior to entering a contract)
Newsletter / updates (if you opt in) Occasional emails about articles, events, podcasts Consent (you can withdraw at any time)
Protecting our website & complying with law Security, legal obligations, record-keeping Legitimate interests / Legal obligation

1.3 Where we get your data

  • Directly from you (emails, forms, calls).

  • Indirectly (rare): a colleague may introduce you by email or provide your work email for scheduling; if so, we will inform you within a reasonable period and provide this Notice where required by Article 14 GDPR.

1.4 How long we keep your data (retention)

  • Enquiry emails/forms: normally up to 12 months from last contact.

  • Client/service records: as required for tax and professional records (typically up to 7 years from the end of services).

  • Newsletter data: until you unsubscribe or after 24 months of inactivity.

  • We may keep data longer where needed for legal claims or compliance.

1.5 Who we share data with

We use trusted service providers (“processors”) to run our business (e.g., website hosting, email, cloud productivity, calendar/meeting tools, newsletter platform). They only process data on our instructions, under contract, and with appropriate security.

1.6 International transfers

Some providers may be located or store data outside the EEA/UK. Where this happens, we rely on adequacy decisions (where available) or Standard Contractual Clauses (SCCs) approved by the European Commission, plus additional safeguards as needed.

1.7 Your data protection rights

  • Access your personal data

  • Rectify inaccurate data

  • Erasure (be forgotten)

  • Restrict processing

  • Object to processing based on legitimate interests (including direct marketing—you can opt out any time)

  • Data portability

  • Withdraw consent where we rely on consent (e.g., newsletters)

We will act on your request without undue delay and in any event within one month, subject to permitted extensions under the GDPR. To exercise any rights, email admin@shirleykavanagh.com.

1.8 Complaints

If you have concerns, please contact us first at admin@shirleykavanagh.com. You also have the right to lodge a complaint with the Data Protection Commission (DPC) in Ireland. Visit dataprotection.ie to contact the DPC.

1.9 Security

We implement appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit where applicable, least-privilege access, and confidentiality agreements with service providers.

1.10 Children

This website and our services are not intended for children under 16. We do not knowingly collect children’s data via the site.

1.11 Do you have to provide data?

If you contact us or request services, providing certain information may be necessary so we can respond or deliver services. If you do not provide it, we may be unable to proceed.

1.12 Automated decision-making

We do not use automated decision-making or profiling that produces legal or similarly significant effects via this website. If that changes, we will inform you and explain your rights.

1.13 Changes to this Notice

We may update this Notice from time to time to remain compliant and transparent. We will post the latest version here with an updated effective date.

2. Cookie Notice

This Cookie Notice explains how shirleykavanagh.com uses cookies and similar technologies.

2.1 What are cookies?

Cookies are small text files placed on your device when you visit a website. They help the site function and remember your preferences.

2.2 How we use cookies

  • Strictly necessary cookies: Required for core functionality (e.g., basic security, form submission). These do not require consent.

  • Preferences cookies (if used): Remember your settings and choices (consent-based).

  • Analytics cookies (if used): Help us understand site usage to improve content (consent-based).

  • Marketing cookies (if used): Used to deliver relevant content (consent-based).

2.3 Legal basis for cookies

We rely on your consent for non-essential cookies (e.g., analytics/marketing). You can withdraw consent at any time via the Cookie Settings link on our site. Strictly necessary cookies are used based on our legitimate interests in delivering a functional and secure website.

2.4 Managing cookies & withdrawing consent

  • Use the Cookie Settings link or banner on our site to manage your preferences at any time.

  • You can also control cookies via your browser settings, but disabling essential cookies may affect site functionality.

2.5 Cookies we use

Below is a template list. If we deploy new tools (e.g., Google Analytics), we will update this table and obtain consent before setting non-essential cookies.

Category Name Provider Purpose Expiry Type
Strictly Necessary csrftoken / sessionid (example) Website host Security and session management Session / up to 1 year HTTP Cookie
Preferences (if used) site_pref Website host Save language/layout preferences 6 months HTTP Cookie
Analytics (if used) _ga, _gid Google Analytics Usage statistics (anonymised where possible) 2 years / 24 hours HTTP Cookie
Marketing (if used) _fbp Meta (Facebook) Ad delivery and retargeting 3 months HTTP Cookie

3. Records Retention Schedule

This schedule outlines typical retention periods/criteria. We retain the minimum necessary and review periodically. We may retain data longer where required for legal claims or compliance.

Data Category Examples Lawful Basis Typical Retention Notes
Enquiries Name, work email, organisation, message content Legitimate interests Up to 12 months from last contact Extended if matter becomes a complaint or legal claim
Client/service records Proposals, contracts, session notes, invoices Contract / Legal obligation Up to 7 years from end of services To meet tax and accounting requirements
Newsletter subscribers Name, email, subscription status Consent Until unsubscribe or 24 months of inactivity Remove promptly on opt-out
Website technical logs IP (short-term), user agent (if collected) Legitimate interests Up to 12 months Security and troubleshooting
Event/meeting scheduling Name, email, organisation, availability Contract / Legitimate interests Up to 24 months from last meeting Operational records only

For any questions about this Notice, please contact: admin@shirleykavanagh.com