Sure Financial Ltd 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 Irish Insurance in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- The Insurance Junction Ltd t/a Irish Insurance
- Email: firstname.lastname@example.org
- When we refer to ‘we’ it is Sure Financial Ltd t/a Sure, Irish Insurance, Irish Pensions, Wealth Planning
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?
- Sure Financial Ltd is a financial broker which offer financial advice and acts as an intermediary for financial and insurance products including mortgages, life insurance, mortgage protection, specified illness cover, income protection, pensions & savings products.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
- Name: Alan Murtagh
- Email address: email@example.com
- Phone number: 01 8570655
Purpose for processing your data
In order for us to provide you insurance, pension and investment services such as quotations, advice and products we need to collect personal data.
We will also use your data for related matters such as detection and prevention of fraud, handling complaints and analysis.
We are committed to ensuring that the information we collect is appropriate for this purpose.
If you have given us separate marketing consent, we will use your personal data for direct marketing purposes.
When looking for a quote for insurance or other financial products, you will need to provide us information relating to who or what you would like to be covered (e.g. in the case of life insurance, details about you). When buying some financial products, we may need to collect special categories of data (such as medical history). If you can’t provide this information, we will be unable to arrange cover for you.
When submitting an application for a product, you may provide us with information for other persons, such as a proposed second policy holder. You agree that you will bring to the attention of each person named on the policy, this Data Protection Statement at the earliest opportunity.
Why we are processing your data? Our legal basis.
In order for us to provide you with insurance and financial services, Irish Insurance need to collect personal data. Our reason (lawful reason) for processing your data under the GDPR is:
- Sure Financial Ltd 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.
In any event, Irish Insurance 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 Sure Financial use the personal data it collects about me?
Irish Insurance 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 the below
- we will obtain your explicit consent
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to Irish Insurance 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 Irish Insurance 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:
- Insurance companies and product providers such as Irish Life, New Ireland, Zurich, Royal London, Friends First, Aviva
- Anyone authorised by you to act on your behalf
- Third party service providers such as technology suppliers, storage providers, payment providers and document providers.
- Medical practitioners
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:
Irish Insurance facilitate you, our clients, 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 – 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. Irish Insurance will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body, the Central Bank of Ireland and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Irish Insurance or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Irish Insurance’s data protection representative Alan Murtagh.
Failure to provide further information
If we are collecting your data for a contract 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
- Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisers have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
- 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. We aim to contact you about products you are likely to be interested in, however you may object to this profiling.
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.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (01) 8570655 or email firstname.lastname@example.org