Privacy Notice
This is a statement of the practices of Trinity College Dublin, The University of Dublin (“Trinity College” / “the University") of College Green, Dublin 2, Ireland in connection with the processing of personal data and the steps taken by Trinity College as a public sector body to protect personal data and safeguard an individual’s right to privacy.
Trinity College actively seeks to preserve the privacy rights of those individuals who share information with the University. The personal data which you provide to Trinity College will be processed in accordance with Irish and European Data Protection legislation, specifically the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and Data Protection Acts 1988 - 2018.
The privacy notice explains the following:
- How and why we process your personal data
- The purpose and legal basis for processing your personal data
- How we securely process your personal data
- Details of third parties with whom we share your personal data
- Your rights under data protection law
How and why we process your personal data
The data we collect from you is processed by the University in accordance with the purposes outlined in this Privacy Notice. We collect personal data via, among other things, software applications, web forms, application forms and documents, email and phone enquiries and surveys. We also collect information via third parties such as the CAO, SUSI and international affiliates.
Students
We process personal data relating to students as detailed in the table below. Additional information for students is available from the Academic Registry website and is included with the Student Terms and Conditions at registration. Personal data and special categories of personal data may be collected directly from students who avail of specific services, e.g. the Trinity Disability Service, Health Service or Student Counselling. If you provide the University with your data for these purposes, then specific information on data protection will be provided at the point of collection.
Purpose for processing personal data | Category | Legal basis for processing |
---|---|---|
|
Administrative |
Article 6(1)(e) GDPR: “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller” (to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022). Article 6(1)(b) GDPR: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract” (performance of a contract). Article 6(1)(c) GDPR: “processing is necessary for compliance with a legal obligation to which the controller is subject” (statutory requirement). |
|
Academic |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. |
|
Student Services |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. Article 6(1)(a) / 9(2)(a) GDPR: “the data subject has given consent / explicit consent to the processing of his or her personal data for one or more specific purposes”. Article 6(1)(d) GDPR: “processing is necessary in order to protect the vital interests of the data subject or of another natural person” (vital interests of the individual). Performance of a contract. Statutory requirement. |
|
Duty of Care |
Vital interests of the individual. Statutory requirement. |
|
Financial |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. |
|
Health & Safety Protection of Assets |
Legitimate interests of the University. Statutory requirement. |
|
Legal |
Statutory requirement. Legal claims. |
|
Communication and Promotion |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. Legitimate interests of the University. |
|
Archives |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. Permitted by section 42 of the Data Protection Act 2018. |
|
Alumni |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. |
|
Students Union |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. |
|
Health & Safety |
Necessary to carry out the University’s objects and functions under the Universities Act 1997 and Higher Education Authority Act 2022. Processing is necessary for reasons of public interest in the area of public health. |
Staff
We process personal data for the purposes of recruitment and for the formation and administration of the contract of employment and employee relationship in support of University operations. The detailed privacy notice for staff is available on the Human Resources website and is provided to new members of staff with their contract. Additional data may be collected from staff when they register to use other services within the University e.g. Trinity Sport or the College Health Service.
Research Participants
One of the objectives of Trinity College as defined in the Universities Act, 1997 is to carry out and support research. Where personal data is processed by the University for the purposes of research, detailed information about how personal data will be used will be provided to research participants prior to the collection of the relevant personal data or shortly after if the data is obtained from a third party. Where possible, personal data collected for research purposes will be pseudonymised so that the participant is no longer identifiable. The use of personal data for research purposes will often involve sensitive personal data including health or genetic data and will therefore be subject to higher standards of security and protection and compliance with the University’s Policy on Good Research Practice.
Detailed information and guidance on the processing of personal data for research purposes, including the processing of personal data for the purposes of health research pursuant to the Health Research Regulations 2018 and associated compliance requirements, is available from the University’s Data Protection website.
Members of the Public and Consumers
We collect data from members of the public in order to respond to enquiries, process transactions, administer services and accept bookings for events. We may add your personal data to a relevant mailing list if you have made an enquiry in relation to a service, if a transaction has taken place or if you have specifically requested to be added to a mailing list in order to receive information which is of interest to you. In the event that we do record your data on a mailing list you will be provided with the opportunity to opt out from the outset and in all our communications with you and we will only send you information relevant to your initial enquiry or transaction.
Website Users
Information on internet traffic is collected routinely by the University and also at other points along the route in the internet (e.g. HEAnet). This technical information is used to ensure the smooth running of the computer network in the University and for statistical or administrative purposes. It is NOT used to gather identifiable personal information on individual website visitors, except in so far as this is permitted by law and may be necessary in order to prevent or detect problems or offences in relation to the operation of the website.
Cookies
We use information gathered from cookies to help improve your experience of tcd.ie. Some cookies are essential so you can move around the website and use its features. Our website also contains third party cookies which are listed in our Cookie Register. For further information and control options in respect of the use of cookies please see the University Cookie Policy.
Children
We sometimes collect data from children under the age of 18. Children's data is collected for the purposes of providing information on courses and admissions. We will also collect children's data when they access services such as Trinity Sport, College Day Nursery, Trinity Access Programmes (TAP) and camps such as the Trinity Walton Club. Further information on processing is provided on the relevant University website or at the point of data collection.
CCTV and Access Controls
CCTV cameras are in operation on Campus in consultation with the Gardai in order to provide enhanced protection for students, staff and visitors as well as University buildings and facilities in the context of an open campus. For further information please see the University CCTV Code of Practice and Access Control System Privacy Statement.
Photography
Photographs or videos of staff and students may be taken on Campus at official events such as graduation ceremonies. As a number of public events also take place on Campus the University will frequently take photographs or video at these events which may be shared on the University website or social media accounts. Where the use of photographs or video may not be reasonably expected by individuals the University will seek consent to publish photographs or video where it is practical to do so. Individuals have the right to object to the use of their photograph and should email Trinity Communications, in the first instance or the University’s Data Protection Office, see (contact details below).
The purpose and legal basis for processing your personal data
IIn order for the use of personal data to be lawful, it should be processed on the basis of either the consent of an individual concerned or another legal basis as set out under GDPR or in the Data Protection Acts 1988 - 2018.
Trinity College will ensure that your data is processed fairly and lawfully in keeping with the principles of data protection and will process personal data under various legal bases depending on the purpose for which the data is collected.
Specific information on the legal basis for processing your personal data will also be provided at the point of collection of personal data. These may include:
- Where the processing of personal data is a statutory function of the University as a public authority. The statutory functions of the University are set out in sections 12 and 13 of the Universities Act 1997.
- Where the University is required to process personal data by law including the sharing of data with the Higher Education Authority under the HEA Act 2022 or for complying with employment law.
- Where the processing of personal data is necessary for the formation of a contract with you.
- Where the processing of personal data is not related to the official functions of the University we may sometimes process personal data based on legitimate interests e.g. for the administration of events, purchasing of tickets, gift shop purchases and the use of our services.
- Generally, when processing special categories of personal data Trinity College will seek explicit consent for the processing of data except where another condition applies e.g. employment law, legal claims or medical diagnosis when using the College Health Service.
How we securely process your personal data
Any data we collect from you will be stored confidentially and securely as required by the University’s IT and Cyber Security Policy. The University is committed to ensuring that processing of University-controlled data is performed in a secure manner.
In keeping with the data protection principles we will only store your data for as long as is necessary and in accordance with our Records Management Policy and Records Retention Schedule.
When we store your personal data on our systems the data will primarily be stored either on the University premises and secure IT platforms within the European Economic Area (EEA) which are also subject to European data protection requirements.
We may store or share your data outside the EEA, in compliance with Chapter V GDPR, in the following circumstances:
- For processing international applications and sharing data with partner Universities.
- When using cloud services for the secure storage of data. Some cloud service providers store data in international data centres e.g. the USA. The University will only use services which are compliant with the EU GDPR and who satisfy the conditions for processing personal data outside the EEA.
- For research projects with other research partners where we have your consent to do so.
- If we are required to do so by law.
Details of third parties with whom we share your personal data
Trinity College will share your data with third parties where necessary for purposes of the processing and where there is a legal basis to do so.
The University may share relevant personal data with the following categories of third parties:
- State or regulatory bodies including the Higher Education Authority, CAO, Department of Education and Skills, Department of Justice and Equality, Department of Social Protection.
- IT or Cloud service providers that provide essential services to the University; e.g. Microsoft, Core HR, Blackboard VLE, Turnitin, Panopto. A full list of the College’s interfaced services is available.
- Firms that provide professional services to the University such as legal firms and auditors.
- Firms that provide archiving and storage and disposal of confidential waste.
- Research and academic partners.
- Organisations including hospitals and public services that provide placements for students.
- An Garda Síochána, when we are required to do so by law.
When we share your data with the third parties outlined here the University will endeavour only to share the data that is needed, that the data is only processed according to our specific instructions and that the same standards of confidentiality and security are maintained. Once the processing of the data is complete any third parties with whom data was shared will be required to return the data to the University save where they are required to retain it by law.
University Archives
One of the functions of the University is the curation of the University Archives, which comprise the University’s administrative, legal and historical records of archival value. This collection – whose earliest record is the foundation charter of 1592 – represents the corporate memory of TCD and is of important historical value. The University will process personal data of archival value in accordance with section 42 of the Data Protection Acts 1988 - 2018 and Article 89 GDPR which permits that personal data of archival value in the public interest may be retained. Personal data retained by the University for archival purposes in the public interest will be stored and secured in accordance with the principles of data protection.
Your rights under data protection law
You have the following rights in respect of how we process your personal data. For further information please see the Trinity College Data Subject Rights Requests Procedure.
Right of Access
You have the right to request a copy of the personal data we are processing about you and to exercise that right easily and at reasonable intervals. Download the College Data Access Request Form.
Consent
You have the right to withdraw your consent where that is the legal basis of our processing. Please contact dataprotection@tcd.ie for more information.
Rectification
You have the right to have inaccuracies in personal data that we hold about you rectified. Please contact dataprotection@tcd.ie for more information.
Erasure
You have the right to have your personal data deleted where we no longer have any justification for retaining it subject to exemptions such as the use of anonymised data for scientific research. The College Data Erasure Request Form is available on request. Please contact dataprotection@tcd.ie for more information.
Object
You have the right to object to processing your personal data if:
- We have processed your data based on a legitimate interest or for the exercise of the public tasks of the University, if you believe the processing to be disproportionate or unfair to you.
- The personal data was processed for the purposes of direct marketing or profiling related to direct marketing.
- We have processed the personal data for scientific or historical research purposes or statistical purposes unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Please contact dataprotection@tcd.ie for more information.
Restriction
You have the right to restrict the processing of your personal data if:
- You are contesting the accuracy of the personal data.
- The personal data was processed unlawfully.
- You need to prevent the erasure of the personal data in order to comply with legal obligations.
- You have objected to the processing of the personal data and wish to restrict the processing until a legal basis for continued processing has been verified.
Please contact dataprotection@tcd.ie for more information.
Portability
Where it is technically feasible you have the right to have a readily accessible electronic copy of your data transferred or moved to another data controller if we are processing your data based on your consent and if that processing is carried out by automated means. Please contact dataprotection@tcd.ie for more information.
Further information
A wide range of templates, guidance documents and support, including detailed information on the rights of individuals under data protection law has been developed by the University data protection office and is available at the University Data Protection website.
If you have any queries relating to the processing of your personal data or if you wish to make a rights request, complaint or escalate an issue relating to any of your rights you can email the Data Protection Officer or contact at:
Data Protection Officer
Secretary’s Office
Trinity College Dublin
Dublin 2
Ireland.
Oifigeach Cosanta Sonraí
Oifig an Rúnaí
Coláiste na Tríonóide, Baile Átha Cliath
Baile Átha Cliath 2
Éire.
If you are not satisfied with the information we have provided to you in relation to the processing of your data you can raise a concern with the Data Protection Commission via their online form or contact the Commission at:
Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland
Last updated: 23/05/2025