Who is responsible for your information
The company that employs you, that hired your firm as a subcontractor, or that runs the site you are visiting decides what is recorded and why. In data protection law it is the data controller, and it should be your first point of contact.
Shamrock Safety Ltd provides the Shamrock Comply system to that company as its data processor. We only use your information to run the system for them, under a written data processing agreement. If you can't reach the company, email us at info@shamrockehs.com and we'll pass your request on.
What is recorded
- Your details: your name, email address, job title, employer and site. For visitors: your name, company, who you are visiting and your mobile number.
- Signing in and out: the times, the site and how you signed in (phone, site QR code or kiosk PIN). When you sign in on your phone, we check how far you are from the site and keep that distance, not your GPS position.
- Kiosk photos: the site kiosk takes a photo when you sign in or out, so a manager can check by eye that the right person signed in. It is deleted automatically after 31 days. There is no facial recognition. Your employer may also add a profile photo for that comparison.
- Inductions, documents and toolbox talks: what you completed or read, your quiz answers, and your signature (typed or drawn) with the date, time and IP address. For a toolbox talk, a copy of the talk you were given is kept with your signature.
- Training and certificates: copies of certificates you or your employer upload, and their expiry dates.
- Safety records: hazards, near misses and incidents you report or are named in (these can include details of an injury, and photos), permits to work, inspections, actions assigned to you and evacuation roll calls.
- Absences your employer records, such as holiday or sick leave.
- Your account: your password and kiosk PIN, stored only in scrambled (hashed) form that can't be read back, and failed login attempts. When a sign-in fails, we keep a pseudonymised code made from the email address typed (not the address itself) and delete it after a day with no further attempts.
- Security changes: when Face ID or fingerprint sign-in is set up on a phone, removed or reset, and when your email address is changed, we record who made the change and when, including the old and new address. We email you each time, and when your email is changed we also tell your old address.
- Notifications: if you turn on notifications on a phone, we keep that phone's push address (a long code from Google, Apple, Mozilla or Microsoft), the type of phone and browser, and a log of when we sent each notification and whether it arrived, but never what it said. The address is deleted when you turn notifications off, log out on that phone, change or reset your password, or someone else logs in on it. Notifications only say what they are about (for example "New document to sign"), but they can show on your lock screen.
- Signing in with no signal: if you sign in or out, or fill in a form, with no signal, it is kept on your phone (with the time, and for sign-in where you were) until it can be sent, then deleted from the phone. It is recorded at the time you made it and marked as sent late. If you log out, or someone else logs in on the phone, anything not yet sent is deleted. If the site tablet loses its connection, your PIN sign-in and photo are kept on the tablet, locked so they can't be read there, until they can be sent.
- Certificate card reading: if the company has switched on card reading, a photo of your certificate may be sent to Anthropic, an AI provider in the United States, to read its details. What was read (the certificate, your name as printed, its number and expiry date) is kept with the certificate, and a person always checks it.
- QR badges: if you are given a QR badge, scanning it at the site tablet signs you in like your PIN, with the same photo.
- Accident reports: if you are hurt at work or see an accident, the company records what the HSA (in Ireland) or the HSE or HSENI (in the UK) needs for an accident report: who was hurt, their address, date of birth, the injury and time off work, and the witnesses. It uses this to make the report the law requires and to keep its accident book.
If you choose to confirm sign-ins with Face ID or a fingerprint, that check happens entirely on your own phone. Shamrock Comply only receives a yes or no, never your face or fingerprint.
Why it is recorded
To keep people safe on site and to meet health and safety law: knowing who is on site if there is an emergency, making sure people are inducted and trained before they start work, and keeping the safety records the law requires. In Ireland that includes the Safety, Health and Welfare at Work Act 2005 and the Construction Regulations; in the UK, the Health and Safety at Work etc. Act 1974 and the CDM Regulations 2015.
The company decides the legal basis for each record. For most of them it is a legal obligation under health and safety law, or the company's legitimate interest in running a safe, well-managed site. Health details in incident reports or sick leave are handled under employment and health and safety law.
Who can see it
- People at the company with access to Shamrock Comply: its administrators, and site managers for their own sites.
- If you work for a subcontractor, your own firm can see its crew's records, including the times you signed in and out at the builder's sites, to work out your hours.
- You can see your own records in the app: your sign-in history, training, documents, induction and the incidents you reported.
- If you work for more than one company that uses Shamrock Comply, you use one login for all of them, but each company only sees its own records about you. When you accept a new company's invitation, you can choose to give it a copy of your current training certificates. Nothing is shared unless you tick the box, and the new company is then responsible for its own copy. Face ID or fingerprint sign-in set up on your phone works for each of them, and if any of them resets it, it is reset for all of them. Your login is deleted once no company holds records about you any more.
- Shamrock Safety Ltd staff, only when needed to support the company, and every time it happens it is logged.
- The service providers that help us run the system, listed on our sub-processors page.
Your information is never sold, never used for advertising and never used to train AI.
Where it is kept
On servers in Amsterdam, in the Netherlands (EU). The emails the system sends you are delivered by Resend, an email service based in the United States (sent from its EU region in Ireland). Emails sent on a company's behalf carry its name and logo and say "Sent via Shamrock Comply". If the company has turned on the optional AI assistant, a manager's question and the records needed to answer it are sent to Anthropic in the United States, and if it has turned on card reading, so are photos of certificates. Notifications pass through the push service of your phone or browser (Google, Apple, Mozilla or Microsoft), which may be outside the EU. In a browser they are encrypted so the service can't read them; in the iPhone app, Apple can see the notification's short title and text. The sub-processors page has the details.
How long it is kept
For as long as the company keeps it, which is usually for the life of the project and as long as health and safety law requires records to be kept. Kiosk photos are deleted after 31 days. When a site finishes, the company may keep a close-out record of that site: your sign-ins there, the inductions, talks and documents you signed, and your training certificates as they were at the end of the job. The company keeps it as the record of the job. If the company stops using Shamrock Comply, its data is deleted within 30 days, and it drops out of our backups within a further 31 days.
Your rights
You can ask for a copy of your information, ask for it to be corrected or deleted, or object to how it is used. Ask the company first. We will help them answer. If you're not happy with the response, you can complain to the Data Protection Commission in Ireland (dataprotection.ie) or, in the UK, the Information Commissioner's Office (ico.org.uk).
Deleting your account
You can delete your Shamrock Comply account at any time in the app, under App settings, Delete my account. Your login is removed straight away: your password, Face ID or fingerprint sign-in, notifications and the phones that stay logged in. Each company you work for is told by email, and you are removed from each of them as if they had removed you.
The safety records each company holds about you (sign-ins, signatures, inductions, training records, incident reports and forms) are not deleted, because the company must keep safety records. Ask the company about them. We keep your email address and a note of when you deleted your login, so those records stay complete. Deletion can't be undone.
Changes to this notice
If we change this notice, we'll update the date at the top. Questions: info@shamrockehs.com.