Context and Overview
This notice will take effect from 25/05/2018 F J Hanly & Associates is committed to protecting and respecting your privacy. It is the intention of this Privacy Statement to explain to you the information practices of F J Hanly & Associates in relation to the information we collect about you and other users. This statement is re-affirmation by F J Hanly & Associates to protect the rights and privacy of individuals in accordance with the General Data Protection Regulation. 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?
F J Hanly & Associates are Financial Brokers based in Limerick and have been operating for almost 20 years. Our role is to help clients make decisions now that will benefit them in the long term. We give you a choice of Product Providers and offer advice on a fair analysis of the market on the following products and services: Pre / Post Retirement Pension Planning, Risk Benefits, Mortgage Protection, Corporate and Individual Investment & Savings F J Hanly & Associates is regulated by The Central Bank of Ireland (Registered number with The Central Bank of Ireland 394552) and is subject to its code(s) of conduct which F J Hanly & Associates must comply with. This code can be viewed at: www.centralbank.ie.
Our data protection representatives can be contacted directly Here at:
Telephone: 00353 (0) 61 310533
Why do F J Hanly & Associates need to collect and store personal data?
As Financial Brokers, in order for us to provide you with this service we need to collect certain personal data so that the companies we work with can process the relevant request. In any event, we 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. In terms of being contacted for marketing purposes, F J Hanly & Associates would contact you for additional consent. How will F J Hanly & Associates use the personal data it collects about me? F J Hanly & Associates 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. F J Hanly & Associates is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual, legitimate business needs.
Under what circumstances will F J Hanly & Associates contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure. We will also ensure that our contact with you is subject to the regulations set out in the Central Bank of Ireland’s Consumer Protection Code 2012.
Why are we processing your data?
Our legal basis – Our reasons and purposes for processing your personal data are:
• That we have your consent to do so.
• We need to process your data to make the relevant recommendations when providing a financial product/service.
• To put in place agreed policies where you the data subject is a party.
• To review and update the information we hold on file to ensure it is still relevant.
• To assist claims where relevant.
• To undertake advertising, marketing, direct marketing and public relation exercises.
• To perform accounting and other record-keeping functions.
• To undertake research and statistical analysis in relation to products offered and customers serviced.
• Disclosure to regulatory bodies for the purposes of monitoring and/or enforcing F J Hanly & Associate’s compliance with any regulatory rules/codes.
• To keep customers' information secure.
• To enhance or improve our customers' experience of our website(s) 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;
• Ensure the personal data is necessary for employment rights or obligations;
• Protect the vital interests of the data subject, including the protection of rights and freedoms;
• Necessary for the legitimate activities with appropriate safeguards; • Personal data made public by the data subject;
• Legal claims;
• Substantial public interest;
• Preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, provision of health or social care treatment, or
• Management of health and social care systems and services, on the basis that appropriate contracts with health professionals and safeguards are in place.
Who are we sharing your data with?
We may pass your personal data on to third parties while we are in the process of carrying out the activities mentioned previously. 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 their own GDPR compliant procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise. 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
F J Hanly & Associates facilitate the data subject’s rights in line with the 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 F J Hanly & Associates refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.
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 transparency and fairness in 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. F J Hanly & Associates will process personal data in accordance with our retention schedule. This retention schedule has been governed by the Central Bank of Ireland and our internal governance.
We may record telephone calls, both to and from this office, for training, verification and regulatory purposes.
A cookie is a simple text file stored by the browser on your computer at the request of our server and only that server will be able to retrieve or read the contents of that cookie. We record visits to our website and use browser cookies in order to monitor your progress through our site, although we do not store your personal data in browser cookies. This information is used by us to measure the performance of the site and to generate other statistics about visitors to our web site in general. We may also use this data to make the site easier and more convenient to use Withdraw consent If we are relying on your consent to process your data you can withdraw this at any time, unless this contravenes any legal/regulatory requirement. Your withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.
In the event that you wish to make a complaint about how your personal data is being processed by F J Hanly & Associates (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and F J Hanly & Associate’s data protection representatives.
Failure to provide further information If we are collecting your data for a statutory requirement (payroll) or to fulfil a contract (life policy) and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
F J Hanly & Associates are responsible for ensuring that the privacy notice(s) is correct and that mechanisms exist such as having the Privacy Notice(s) on F J Hanly & Associate’s website to make all data subjects aware of the contents of this notice prior to F J Hanly & Associates commencing collection of their data. All staff that need to collect personal data are required to follow this procedure.
Questions Regarding the Privacy Statement and Conditions of Use If you have any questions about our Privacy Statement and Conditions of Use, or any concern about privacy or the use of this Site in general, please contact us by email at firstname.lastname@example.org
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.