We made these updates to reflect the high standards established by the General Data Protection Regulation (GDPR), a set of laws passed in the European Union. Because we believe all readers of the right to these standards of protection, we are implementing these updates globally.

We respect your personal data. We have never and will never sell it to third parties.

By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.

This Privacy Policy is a part of our Terms and Conditions; by agreeing to Terms and Conditions you also agree to this Policy. In the event of collision of terms used in Terms and Conditions and Privacy Policy, the latter shall prevail.


Key details

Policy prepared by: Mark Betteridge on: 29/10/2022 Policy became operational on: 31/10/2022.


True Underground needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures True Underground:

Complies with data protection law including the GDPR and follow good practice in regard to user data

Protects the rights and data of staff, customers and partners

Is open about how it stores and processes individuals’ data

Protects itself from the risks of a data breach

Data protection law

The Data Protection Bill and the General Data Protection Regulation (GDPR) describes how organisations — True Underground — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

Be processed fairly and lawfully

Be obtained only for specific, lawful purposes

Be adequate, relevant and not excessive

Be accurate and kept up to date

Not be held for any longer than necessary

Processed in accordance with the rights of data subjects

Be protected in appropriate ways

Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

“The Right to be forgotten” you have the right to request that your data is deleted or restricted.


Policy scope

This policy applies to:

The head office of True Underground.

All branches of True Underground.

All staff and volunteers of True Underground

All contractors, suppliers and other people working on behalf of True Underground

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.

This can include:

Names of individuals

Postal addresses

Email addresses

Telephone numbers

Plus any other information relating to individuals

Data protection risks

This policy helps to protect True Underground from some very real data security risks, including:

Breaches of confidentiality. For instance, information being given out inappropriately.

Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.


Everyone who works for or with True Underground has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The owner is ultimately responsible for ensuring that True Underground meets its legal obligations

The data protection officer, Mark Betteridge, is responsible for:

Keeping the company updated about data protection responsibilities, risks and issues.

Reviewing all data protection procedures and related policies, in line with an agreed schedule.

Arranging data protection training and advice for the people covered by this policy.

Handling data protection questions from staff and anyone else covered by this policy.

Dealing with requests from individuals to see the data True Underground holds about them (also called ‘subject access requests’).

Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

Making sure that all breaches are reported to the relevant parties (including the individuals who’s data it is)

The IT manager, Mark Betteridge, is responsible for:

Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The Data marketing manager, Mark Betteridge, is responsible for:

Approving any data protection statements attached to communications such as emails and letters.

Addressing any data protection queries from journalists or media outlets like newspapers.

Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.


The only people able to access data covered by this policy should be those who need it for their work.

Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.

True Underground will provide training to all employees to help them understand their responsibilities when handling data. An outline of which will be available on the intranet of

Employees should keep all data secure, by taking sensible precautions and following the guidelines below. In particular:

Strong passwords must be used and they should never be shared.

Personal data should not be disclosed to unauthorised people, either within the company or externally.

Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.


True Underground stores data on customers, suppliers, readers and event attendees. Readers and event attendees will only be contacted by email who have actively clicked a GDPR compliant “opt in”

Customers, including subscribers and advertisers agree to being contacted with key information about their purchase or custom during their transactions. However they receive the same GDPR compliant “opt in” for marketing emails.

Voters in our polls must agree to the collection of their personal data including name, email, location, date of birth, social media ID, IP address and device information in addition to their votes. This data is required for security monitoring. Only voters who complete the GDPR compliant “opt in” form as part of the voting process agree to be contacted with marketing messages.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

When not required, the paper or files should be kept in a locked drawer or filing cabinet.

Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.

Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

Data should be protected by strong passwords that are changed regularly and never shared between employees.

If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.

Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.

Servers containing personal data should be sited in a secure location, away from general office space.

Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.

Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.

All servers and computers containing data should be protected by approved security software and a firewall.

We do our best to keep your Personal Data safe.  We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.


This Website may make use of ‘cookies’ and tracking software.

Cookies are pieces of information that are stored by the browser on the hard drive of your computer.

Cookies enable us and any person who advertises on our Website to provide features such as remembering certain Your Information and your preferences.

Cookies can be deleted from your hard drive or you can configure your web browser so that it rejects cookies.

Rejection of cookies will not prevent you from using most of the features on this Website.

If you experience any problems having deleted cookies, you should contact the supplier of your web browser.

The tracking software monitors traffic patterns and site usage so that we can design and develop this Website to suit the needs and requirements of visitors to it.

We use cookies for the following purposes:

  • Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
  • Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
  • Analytics cookies – these cookies are used to track the use and performance of our website and services
  • Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as or For more information about cookies, visit

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.


Personal data is of no value to True Underground unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.

Personal data should never be transferred outside of the European Economic Area.

Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.


The law requires True Underground to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort True Underground should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets. In practice these will be the database on and email lists held on and, our mailing and promo service providers.

Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.

True Underground will make it easy for data subjects to update the information True Underground holds about them through

Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Data Subject’s rights

The Data Subject has the following rights:

  1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
  2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
  3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
  4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
  5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
  6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
  7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
  8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
  9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
  10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
  11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.


All individuals who are the subject of personal data held by True Underground are entitled to:

Ask what information the company holds about them and why.

Ask how to gain access to it.

Be informed how to keep it up to date.

Be informed how the company is meeting its data protection obligations.
Request that that data be deleted.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller, Mark Betteridge at The data controller can supply a standard request form, although individuals do not have to use this per subject access request.

The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.


In certain circumstances, Data Protection Bill and the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, True Underground will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the company and its legal advisers where necessary.

Providing information

True Underground aims to ensure that individuals are aware that their data is being processed, and that they understand:

How the data is being used

How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.


At True Underground we take your data extremely seriously and we will only ask you for personal data when it is necessary for us to be able to carry out the services that we offer.

This may include you name and address if you are a subscriber (so you can register for our competitions)

or your email address (so you can receive our news letter)

or your company details (if you are an advertiser, so we can send you an invoice.)

We will never sell your information or pass it onto any third party unless it is made explicitly clear and we have gained your permission.

We will continue to update the data we hold regularly to make sure that it is relevant, up to date and so you know what data we hold and why (so don’t forget to opt in if you want to keep hearing from us)

We won’t hold any data for longer than it is necessary for us to be able to carry out the services that we offer.

You can request a copy of your data held by us by emailing or filling in this form (subject access request form). We may ask you to verify who you are. We will endeavour to respond to all requests within 14 days and there will be no charge for reasonable requests.

You also have the “Right to be Forgotten” which means we will delete any of your personal data that we hold. You can request for your data to be deleted, or restricted using the same form or by emailing

We will always notify you if we believe any breach has taken place and if any of your personal data is at risk of becoming available to anyone other than True Underground.

Contact Information

Data Protection Officer

If you have any questions regarding Processing your Personal Data, your rights regarding your Personal Data or this Privacy Policy, contact our Data Protection Officer, Mark Betteridge at

Supervisory Authority

Phone: +353 57 868 4800


We reserve the right to make change to this Privacy Policy.

Last modification was made May 11th, 2023.