Privacy Policy

Introduction

Purpose

KTL is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out KTL's commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of job applicants, employees [, workers, contractors, volunteers, interns, apprentices] and former employees, referred to as HR-related personal data. [This policy does not apply to the personal data of clients or other personal data processed for business purposes.]

KTL has appointed an internal employee as the person responsibile for data protection compliance within the organisation.

 

Definitions

"Personal data" is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

 

Data protection principles

The organisation processes HR-related personal data in accordance with the following data protection principles:

The organisation processes personal data lawfully, fairly and in a transparent manner.

The organisation collects personal data only for specified, explicit and legitimate purposes.

The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.

The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

The organisation keeps personal data only for the period necessary for processing.

The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where the organisation relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

Where the organisation processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

The organisation will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the [employment, worker, contractor or volunteer relationship, or apprenticeship or internship] is held in the individual's personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the organisation holds HR-related personal data are contained in its privacy notices to individuals.

The organisation keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

 

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:

  • whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
  • to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
  • for how long his/her personal data is stored (or how that period is decided);
  • his/her rights to rectification or erasure of data, or to restrict or object to processing;
  • his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and
  • whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

[If the individual wants additional copies, the organisation will charge a fee, which will be based on the administrative cost to the organisation of providing the additional copies.]

To make a subject access request, the individual should send the request to [email address] or use the organisation's form for making a subject access request. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.

The organisation will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organisation processes large amounts of the individual's data, it may respond within three months of the date the request is received. The organisation will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, the organisation is not obliged to comply with it. Alternatively, the organisation can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify him/her that this is the case and whether or not it will respond to it.

 

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the organisation to:

  • rectify inaccurate data;
  • stop processing or erase data that is no longer necessary for the purposes of processing;
  • stop processing or erase data if the individual's interests override the organisation's legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
  • stop processing or erase data if processing is unlawful; and
  • stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override the organisation's legitimate grounds for processing data.

To ask the organisation to take any of these steps, the individual should send the request to This email address is being protected from spambots. You need JavaScript enabled to view it..

 

Data security

The organisation takes the security of HR-related personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. [Provide more detail of internal policies and controls, eg systems restrictions and data security policy.]

Where the organisation engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

 

Impact assessments

Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to individual's rights and freedoms, the organisation will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

 

Data breaches

If the organisation discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

 

International data transfers

The organisation will not transfer HR-related personal data to countries outside the EEA

 

Individual responsibilities

Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example if an individual moves house or changes his/her bank details.

Individuals may have access to the personal data of other individuals [and of our customers and clients] in the course of their [employment, contract, volunteer period, internship or apprenticeship]. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff [and to customers and clients].

Individuals who have access to personal data are required:

  • to access only data that they have authority to access and only for authorised purposes;
  • not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;
  • to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
  • not to remove personal data, or devices containing or that can be used to access personal data, from the organisation's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
  • not to store personal data on local drives or on personal devices that are used for work purposes; and
  • to report data breaches of which they become aware to [name of individual/the data protection officer] immediately.

[Further details about the organisation's security procedures can be found in its data security policy.]

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

 

Training

The organisation will provide training to all individuals about their data protection responsibilities as part of the induction process [and at regular intervals thereafter].

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.

Quality Policy

KTL is a market leader in the mobile telecommunications Industry. It is our policy to deliver a high quality service to all of our customers on time, regardless of their size or monetary value to KTL. In order to achieve this ultimate goal, we commit to the following principals:

  • We will maintain and seek to continuously improve our ISO9001:2015 Quality Management System.
  • We will use the most up to date technology to ensure we deliver a quality service to our clients in the most efficient manner possible.
  • We will recruit, train and develop our staff to enable them to deliver the high product and service quality that our customers demand and deserve.
  • We will manage and monitor our employees to ensure that delivery of our service is to the highest levels of quality and workmanship.
  • We will develop partnerships with our key suppliers and sub-contractors to allow us provide a flexible and cost-effective service to our customers.
  • We will pro-actively seek the voice of the customer to ensure that not only do we fully understand their requirements but that we formally seek their feedback on our performance, both in terms of product and service quality.
  • Where customer expectations are not met, we will quickly and efficiently investigate and remedy the issues. Further, we will implement measures to ensure that there are no recurrences of the issues.
  • We will strive to ensure that our responsiveness and on-time delivery performance maintained to the highest levels.
  • We will control our overheads and costs to ensure that we remain competitive.
  • We will set objectives, both project and process based, to ensure that we continuously improve our systems and service and we will measure our performance against these objectives on an on-going, formal basis.

This statement is communicated and re-communicated to all employees on a regular basis to ensure that it remains uppermost in their minds. It is reviewed during the annual Management Review to ensure that it remains appropriate, relevant and applicable.

KTL is committed to the prevention of material damage.

SIGNED: DATE: 25th April 2017

Peter Dwyer

Director of Operations

Health and Safety Policy

KTL is committed to providing a safe working environment for all its employees, contractors and anyone affected by our work. KTL is committed to the continuous improvement of a safe work environment through training, improved work methods and the adaptation of new technologies. We believe that all injuries and occupational illnesses are preventable.KTL is committed to the prevention of ill health and injury and material damage.

The objective of KTL Health & Safety Policy is to achieve “zero Injuries”. As part of our commitment to safety we will outline our objectives on an annual basis to improve safety within the organisation. We will review progress against these objectives on a regular basis. KTL will adhere to statutory legislation and other safety requirements where we are located. Some of the main legislation includes (but not limited to) the following:

Ireland

  • Safety Health & Welfare at Work Act 2005
  • Safety, Health and Welfare at Work (Construction) Regulations 2013 (S.I. No. 291/2013) and any amendments
  • Safety, Health and Welfare at Work (General Application) Regulations 2007 to 2016

Northern Ireland

  • Health and Safety at Work (Northern Ireland) Order 1978
  • Workplace (Health, Safety and Welfare) Regulations (Northern Ireland) 1993
  • The Construction (Design and Management) Regulations (Northern Ireland) 2016
  • The Management of Health and Safety at Work (Amendment) Regulations (Northern Ireland) 2006

UK

  • Health and Safety at work Act 1974
  • Construction (Design and Management) Regulations 2015
  • Management of Health and Safety at Work Regulations 1999
  • Workplace (Health, Safety and Welfare) Regulations 1992

The directors of the company have ultimate responsibility for the safety of its staff and contractors. Health and safety is a shared responsibility for a common good. Employees and others are obliged to appropriately highlight any issue or aspect of operations that may have a welfare, health or safety implication. With due care and good communications the safety systems will reduce risk levels to ensure a safe and healthy working environment.

To this end the company recognises that there must be adequate arrangements in place to ensure that all employees have the necessary skill to do their work safely by means of training, developing skills, implementing safe procedures, co-operation, consultation and regular reviews. Adequate financial and physical resources will be provided to ensure that safety is of the highest standards within the organisation.

The Board requires each manager and supervisor to be aware and implement relevant legislation and safe practices; to manage health and safety programmes effectively; to take care for the safety, health and welfare of employees; to comply with relevant Regulations and all other associated legislation; to take all reasonable steps to ensure that working conditions on site and aloft are safe and that proper safe work practices are adhered to; to exercise their duty of care and take account for and report on accidents or dangerous occurrences; to be fully aware of Company Policy and ensure that all safety information is brought to the notice of employees. The Board requires each employee to work safely at all times and to observe all procedures which are in place to ensure their safety, health and welfare and if there is any doubt to seek advice from the appropriate supervisor and or manager.

KTL have in place insurance covering Employer Liability, Public Liability, All Risk and Motor. As a company KTL are covered for working at height up to and including 100 meters along with completing excavation works to a maximum depth of 10 meters.

This policy is communicated and re-communicated to all employees on a regular basis to ensure that it remains uppermost in their minds. It is reviewed during the annual Management Review to ensure that it remains appropriate, relevant and applicable.

SIGNED: DATE: 12th April 2017

Peter Dwyer – Director of Operations

Environmental Policy

KTL Ltd. is committed to continual improvement with regards to its environmental performance and to the overall prevention of pollution. We will undertake work while also considering how to minimize effects on local inhabitants, and both the surrounding and global environment. KTL is committed to avoiding material damage. The different areas of KTL’s activities have been addressed as part of an environmental review.

We have identified applicable environmental legislation and other requirements and created and documented an action plan to identify environmental objectives and targets to achieve these objectives. We have implemented a means of tracking changes and revisions to such requirements.

KTL have appointed an Energy Champion, who will monitor performance, communicate to the KTL Board on performance and to employees on initiatives for continuous improvement.

It is our policy to:

  • Minimise waste material and prevent accidental pollution and physical damage of habitats while building infrastructure.
  • Manage waste packaging and engineering materials in a responsible manner.
  • Use only authorised suppliers for recycling and disposal of waste materials.
  • Operate and select efficient and quiet plant that reduces energy/fuel consumption and that have minimal environmental impact.

KTL will accomplish this high standard of performance through a strong environmental management system integrated within our business planning and decision making processes and by setting and tracking measurable goals and objectives. We continuously review client proposals and consult stakeholders with regards to finding environmentally acceptable solutions.

Additionally, each employee has an individual responsibility to follow all environmental procedures and participate proactively in our programs and inspections. It is our policy to train employees with regards to environmental codes and practices.

We will work in partnership with suppliers, customers and government agencies to help protect and improve the environment. KTL will foster openness and communication with all its key stakeholders in order to anticipate important environmental concerns, share relevant information, contribute to development of sound solutions, and respond in a constructive and timely manner.

We will focus on sustainable development and protect both our staff and the environment in which we work.

This policy is communicated and re-communicated to all employees on a regular basis to ensure it is always taken into consideration. It is reviewed during the annual Management Review to ensure that it remains appropriate, relevant and applicable.

SIGNED: DATE: 12th April 2017

Peter Dwyer

Director of Operations

NIE Tamnamore – Gort Line

Click on a photo to view
 

PROJECT NAME: Tamnamore – Gort Line, T312 Provision of Construction, Refurbishment and Restringing of Transmission Overhead Lines Framework
CLIENT: Northern Ireland Electricity

Project Overview

KTL have been accepted onto NIE’s 4-year framework for the provision of construction, refurbishment and restringing of transmission overhead lines.

Project Details

KTL have completed the Stringing of the Tamnamore – Gort line, part of the T312 Provision of Construction, Refurbishment and Restringing of Transmission Overhead Lines Framework for NIE Networks (Northern Ireland Electricity Networks).

Our team delivered a high quality 110kV new build OHL which comprised of:

  • 42 Pylons (Type L4(M) SF60) – 4m in depth Foundations (5 of which were mini piled), assemble and erect pylons
  • 68 Intermediate H Poles (Height range 16m to 24m)
  • Conductor stringing 15.27km approx. - Stringing incl. wheel out, clamp in and terminate (String conductors (3Ø) with 400mm Zebra ACSR, string 1 No. earthwire with 70mm Horse ACSR and string 1 No. OPGW earthwire with 70mm Horse Equivalent.)

Part of the stringing works involved erecting a Catenary System to facilitate the stringing of new Zebra, Horse and OPGW Conductor over the M1 motorway at Dungannon in Northern Ireland. This involved closing the M1 Motorway at off peak hours from (00:00 – 08:00) on a Sunday morning. KTL had to liaise with the PSNI, NIEN, ESBI and TNI to facilitate the works.

The safety, health, environment and quality systems (SHEQ) implemented by KTL received high praise from the client’s representative, which is testament to the high quality work of the KTL team. The project was successfully completed without any major incidents, on time and within budget.

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Head Office

Killarney Telecommunications Limited.
Unit P, M7 Business Park,
Newhall, Naas,
Co. Kildare,
Ireland.
Company Number: 280010

Office - UK

KTL
Unit 5, Denbigh Hall Industrial Estate, 
Bletchley,
Milton Keynes,
MK3 7QT

UK