Privacy Statement

Privacy Statement


This Privacy Statement is effective as and from the 25th May 2018.

This statement describes how we process your personal data. Please take the time to read it carefully. You have a number of rights in relation to your information including the right to object to processing of your personal information where that processing is carried out for our legitimate interests. In this statement we use the terms “we” and “our” to refer to KMK Metals Recycling Ltd.


  1. Who we are and how to contact us

KMK Metals Recycling Ltd. is an end-of-life metals and electrical/electronic waste recycling and recovery facility with two sites, located in Tullamore, Co. Offaly and Kilbeggan, Co. Westmeath.


If you have any questions about this privacy statement, including any request to exercise your professional rights, please contact us using the details set out below:


KMK Metals Recycling Ltd.,

Cappincur Industrial Estate,

Daingean Road,


Co. Offaly.

R35 NY29

Main Line: 00 353 (0)57 9341634




2. The purpose and professional basis for processing your information


We collect your information for a number of purposes and rely on several different professional bases to use your personal data.


a)  To enter into and perform a contract with you


When we are engaged to conduct professional services it is necessary to collect personal data from you in order to seek and receive your instructions in relation to those professional services and to carry out those professional services.


b)  To comply with our professional obligations


We are required to process your personal information to comply with certain professional obligations to which we are subject, including:

  • Providing information to An Garda Síochana, the Data Protection Commission and other enforcement agencies under various pieces of legislation which apply to us.
  • To verify your personal data provided to us and to meet our professional and compliance obligations.



c)  For our legitimate business interests


Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. Our legitimate interest is the effective management of our business and to connect with and update our customers on services which we provide.


We may use your personal data to manage our everyday business needs including:

  • order processing;
  • logistics scheduling;
  • internal reporting needs;
  • market research;
  • to progress and respond to professional queries;
  • to ensure appropriate IT security;
  • to update you on professional developments and company developments;  
  • to invite you to events that we feel may interest you;
  • to connect with our clients and to update our clients on services which we provide.

d)  Consent


We will, in certain circumstances, rely on your explicit consent to process your personal data, including, sensitive personal data. This consent can by withdrawn at any time by using the contact details set out above.



3. Consequences of failing to provide information


Where we need to collect personal data by law, or under the terms of a contract with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter in to with you. 


For example, we may require certain information from you in order to fulfil our requirements before carrying out certain professional services.  As such we may not be able to carry out those professional services without that information but we will notify you of this at the time if this is the case.



 4. Categories of data subjects


Personal data we process for our own purpose and on your behalf may include but may not be limited to your customer and prospect data, your staff data, your contractor data, your vendor or supplier data.



5. Types of information we collect and some examples of how we use it


We may collect, use, store and transfer different kinds of personal data about you as follows and use it for a variety of different purposes and across various professional services we provide to you:

  • Customer contacts and contact details: We use this information to schedule and perform our professional services as instructed, to send you marketing information about events, updates and services and to respond to your queries.
  • Interactions with our Subcontractors & Suppliers: We use this information to keep a record of your interactions with us, to monitor and train our staff or to provide you with professional services. CCTV is installed both internally and externally on the premises at KMK Metals Recycling Ltd. The company and its security provider use CCTV imaging for the principal purpose of enhancing security together with improving health and safety standards.


6. Your information and third party service providers


We may share your personal information or provide access to your personal data to third party service providers that carry out services on our behalf such as;

  • Sub-contracted hauliers
  • IT Vendors
  • Security Providers
  • Financial Institutions

We may also share your personal data with An Garda Síochana, or other government bodies or agencies where required to do so by law.



7. Duration of processing


We will process personal data on your behalf for so long as you instruct us to do so. At the cessation of our processing activities on your behalf it is your choice as to what happens to the personal data you have provided to us.  We will work with you to carry out your reasonable instructions unless we are required to retain it to comply with legal obligations. Personal data we collect for our own purposes will be managed in accordance with our Data Retention Policy which reflects current legal obligations. 



8. Use of sub-processors


As part of our service delivery it is necessary for us to use sub-processors.

Our IT support is provided by parties external to KMK Metals Recycling Ltd. Some solutions we utilise are cloud based and our need to rely upon those systems varies depending upon the services we deliver to you. All sub-processors are bound by KMK Metals Recycling Ltd. to provide at least the same level of protection for your data as we do.  



9. Data transfers


KMK Metals Recycling Ltd. and affiliated companies utilise a number of suppliers to provide us with IT and other associated services for the delivery of our business and services to you. In many cases, the suppliers we use will be granted access to the data we are processing in order to provide us with technical assistance. Such processing activities are not directly related to our principal services to you and are considered ancillary to our own internal activities. We have implemented third party level agreements with such processors of your data to ensure effective controls are in place.



10. Data security


KMK Metals Recycling Ltd. has put technological and organisational controls, including policies and procedures, in place to protect your personal data from loss, misuse, alteration or unintentional destruction. Our personnel who have access to the data have been trained to maintain the confidentiality of such information. Conditions to protect data to at least the same standard as we do are cascaded to all our contractors, sub processors and suppliers.


From time to time we use the services of an external IT vendor to audit our security defences and ensure we continue to be effective against the latest threats.


Data transferred over the internet by us and through our website are protected using encryption technologies to ensure they remain secure. Please note that no communications over the internet can be guaranteed as secure. Whilst we take appropriate steps to protect your data we cannot guarantee that it will remain secure in transit. Once data reaches your network it is your responsibility to ensure it remains secure.



11. Your rights


You have several rights under data protection law in relation to how we use your personal information. You have the right free of charge to;

  • Request a copy of the personal information we hold about you.
  • Rectify any inaccurate personal data we hold about you.
  • Erase personal information we hold about you.
  • Restrict processing of your personal information.
  • Object our use of your personal information for our legitimate interests.
  • Receive your personal information in a structured commonly used and machine readable format.
  • To have that data transmitted to another data controller.

These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights please contact us using the contact details contained in this statement.  We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further period of two months and we will explain why.


You also have the right to lodge a complaint to the Office of the Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois –, Tel: +353 57 8684800




12. Contacting you


From time to time we may use the contact details you and your representatives have provided to us to send invitations, marketing materials, updates and other publications and information about our services which we feel may be of interest to you. Should any individual not wish to receive such communications please contact us at the details set out at 1 above.


Some of our marketing emails may contain web beacons, web bugs, cookies or other similar technologies which enable us to understand whether you open, read, or delete the message and any interaction you make with links contained therein.  When you click on a link in a marketing email you receive from us we may also use cookies to log what pages you view, in accordance with our cookies policy. Targeted emails from us may include additional data privacy information as required by applicable privacy laws.



13. Changes & updates to this statement


We recommend you check this statement on a regular basis to ensure you remain in agreement with the activities we carry out in respect of processing personal data.


Should we make significant changes to the way we process data, we will draw your attention to the relevant part(s) of this statement through email and or other appropriate communications as part of our engagement activities with you.


For any enquiries, please contact: or