Data Privacy Notice- West Wicklow Financial Services DAC
Introduction
West Wicklow Financial Services DAC 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 West Wicklow Financial Services DAC in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Con Murphy
- Contact details: email: info@wwfs.ie Phone: 059 6482233
- When we refer to ‘we’ it is West Wicklow Financial Services DAC.
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?
West Wicklow Financial Services DAC is trading since 1999 at Weaver Square, Baltinglass, Co. Wicklow. We arrange various financial services products for clients. Life and Critical Illness Assurance, Income Protection, Deposit accounts, a range of Investment Products, Residential and Commercial Mortgages and we provide a Financial Planning Service to client’s also.
Our GDPR Owner and data protection representatives can be contacted directly here:
- Name: West Wicklow Financial Services DAC
- Email address: info@wwfs.ie
- Phone number: 059 6482233
Why we are processing your data? Our legal basis.
In order for us to provide you the financial services you require (our services are listed in our Terms of Business) West Wicklow Financial Services DAC need to collect personal and financial data in order to process your applications for whichever financial services you may require from us. Our reason (lawful reason) for processing your data under the GDPR is:
- Legal basis – West Wicklow Financial Services DAC 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 – i.e.) Mortgage application or Investment product.
In any event, West Wicklow 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 West Wicklow Financial Services use the personal data it collects about you?
Whether we are using your information to confirm your identity, to help in the processing of an application for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in the Data Privacy Notice are always applied.
West Wicklow Financial Services DAC 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 endeavour 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 that we will obtain your explicit consent.
Who are we sharing your data with?
We only share your information with a select number of individuals and companies, and only as necessary. West Wicklow Financial Services DAC acts as a Financial Intermediary between our clients and the Product Producers – i.e.) Life Assurance Companies based in the Republic of Ireland – Zurich Life, Irish Life, New Ireland, Aviva Life and Standard Life, the same list of Life Company’s for Pension related business, Deposit Bank – KBC Bank Ireland, the same list of Life Companies for Investment business plus Wealth Options and BCP Asset Management. When arranging loans to purchase property for clients, West Wicklow Financial Services DAC has access to Haven (AIB) Bank, Permanent tsb, KBC Bank Ireland, Ulster Bank and Phoenix Financial Services ltd.
West Wicklow Financial Services DAC is a Financial Services Intermediary – therefore it will be necessary for us to supply your Personal and Financial data to the third parties listed above. None of our client’s personal and / or financial data will be transferred outside the EU.
We may pass your personal data on to third-party service providers contracted to West Wicklow 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 fulfil 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 West Wicklow Financial Services DAC procedures.
Examples of our Service Providers include: IT and telecommunication service providers, software development contractors, computer maintenance contractors, document destruction companies, auditors and consultants.
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:
- Zurich Life
- New Ireland
- Irish Life
- Aviva Life
- Standard Life
- Friends First
- KBC Bank Ireland
- Haven (AIB) Mortgages
- Permanent tsb
- Phoenix Financial Services Ltd.
- Wealth Options
- BCP Asset Management
We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions.
If in the future 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:
West Wicklow Financial Services facilitate you our client’s rights in line with our data protection policy and the subject access request procedure. This is available on request.
- 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
- 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. The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product / service we have provided you.
Factors include:
- The regulatory rules contained in laws and regulations or as set by authorities like the Central Bank of Ireland, for example in the Consumer Protection Code.
- The type of financial product / service we have provided to you. For example we may keep data relating to a pension product for a longer period compared to data regarding an investment product.
West Wicklow Financial Services DAC will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank) and our internal governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by West Wicklow 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 representative’s GDPR Owner.
Failure to provide further information
If we are collecting your data for a contract x 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
When your data is provided to West Wicklow Financial Services some of the financial institutions we act for as an Intermediary carry out automatic decision making – whenever this situation applies to a client we will explain the significance and the envisaged consequences involved.
An Example of Profiling – automatic decision making:
Profiling;
Financial and mortgage advisors using profiling in their business. The main categories are
a) Risk profiling.
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services and mortgage product
a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customer’s attitude to various levels of risk having answered a series of questions.
b) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above we may run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
c) 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 (059) 6482233 or email info@wwfs.ie
Privacy policy statement changes
West Wicklow 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.