Privacy Statement

Introduction

Anthony O’Neill Financial Services is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

It is the intention of this privacy statement to explain to you the information practices of Anthony O’Neill Financial Services in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

  • Anthony O’Neill
  • Contact details of 01 442 89 10
  • When we refer to ‘we’ it is Anthony O’Neill Financial Services

Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Who are we?

  • Anthony O’Neill Financial Services is an Insurance Intermediary regulated by the Central Bank of Ireland, providing Insurance, Savings, Investment and Pension advice

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:

  • Anthony O’Neill
  • info@tonyoneill.ie
  • 01 442 89 10

Purpose for processing your data

  • You need to be clear about your use of client’s data and the consequences/risks to them of processing their data.
  • You will need to outline what and how information is going to be processed.
  • This is to make sure the individual knows exactly what is going to happen to their information and how it is going to be used. You shouldn’t be doing anything with personal data unless the individual is made aware.

Why we are processing your data? Our legal basis.

In order for us to provide you with one of our products, Anthony O’Neill Financial Services    need to collect personal data for Underwriting and Application. Our reason (lawful reason) for processing your data under the GDPR is:

  • Legal basis Anthony O’Neill Financial Services needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract referred to as Insurance products provision.

In any event, Anthony O’Neill Financial Services    are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

How will Anthony O’Neill Financial Services   use the personal data it collects about me?

Anthony O’Neill Financial Services   will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below

  • we will obtain your explicit consent

Who are we sharing your data with?

We need your personal data to complete an application this will include medical and banking information which is required in order to complete the underwriting and making the policy active.

We may pass your personal data on to third-party service providers (Insurer) contracted to Anthony O’Neill Financial Services in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with  Anthony O’Neill Financial Services   procedures.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.

The third parties that we pass your personal data to are:

Anthony O’Neill Financial Services

  • Relevant underwriters and Insurers
  • New Ireland Zurich Aviva Friends First ILAC Royal London BCP April

We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

Data Subjects Rights:

Anthony O’Neill Financial Services   facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

Additional information we are providing you with to ensure we are transparent and fair with our processing

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Anthony O’Neill Financial Services  will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body Central Bank of Ireland and our internal governance.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Anthony O’Neill Financial Services or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner

Failure to provide further information

If we are collecting your data for a contract Anthony O’Neill Financial Services and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

If we carry out automatic decision making you need to inform the data subject -you need to explain the significance and the envisaged consequences involved. You also need to inform that data subject can object to this.
e.g. ISME ratings, recruitment psychoanalytic, insurance underwriting
An example:
Profiling – automatic decision making
Profiling;
Financial and mortgage advisors using profiling in their business.  The main categories are

  1. Risk profiling.
  2. Profiling for marketing purposes.
  3. Establishing affordability and providing quotations for financial services and mortgage product
  1. Risk profiling.
    To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
  2. Profiling for marketing purposes.
    When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
  3. Establishing affordability and providing quotations for financial services products.

Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01 442 89 10

Privacy policy statement changes

Anthony O’Neill Financial Services may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed in May 2018

Source: Atlantic Compliance Ltd

Atlantic Compliance Ltd are experienced data protection practitioners and all document templates are provided as general guidance.

Users of these documents should consult their own legal advisers for legal advice specific to their own circumstances and Atlantic Compliance Ltd accepts no liability of any sort arising from the use of these templates.