Introduction

Vincent Casey Life & Pensions Company 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 Vincent Casey Life & Pensions Company Ltd in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

• Vincent Casey
• Contact details: Tel (064)6636410
• When we refer to ‘we’ it is Vincent Casey Life & Pensions Company Ltd

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?

• Vincent Casey Life & Pensions Company Ltd is a Financial Broker who works on a fair analysis basis.

Our principal business is to offer advice and arrange transactions on behalf of clients, in relation to life and pensions/deposit products. A full list of insurers and product producers of whom we deal with are available on request.

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

• Vincent Casey
  vcasey@lifeandpensionsco.ie
• (064) 6636410 / 087 2461599

Purpose for processing your data

We process any personal data you provide to us for the following purposes:

• To provide you with information about the products and services of Vincent Casey Life & Pensions Company Ltd.
• To contact you if required in connection with your account or enquiry and to respond to any communication you may send us.
• To process online application forms submitted to us for the purpose of providing financial products. Any application submitted online or via email will be subject to the same terms and conditions as those completed by hand, in paper form, including additional terms and conditions relating to credit reference checking, money laundering and regulatory notices.

Why we are processing your data? Our legal basis.

In order for us to provide you with appropriate advice, Vincent Casey Life & Pensions Company Ltd need to collect personal data in order to help you realise your financial goals. Our reason (lawful reason) for processing your data under the GDPR is:

• Legal basis – Vincent Casey Life & Pensions Company 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 and that having access to your data we can give the appropriate advice to you.

In any event, Vincent Casey Life & Pensions Company Ltd 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 Vincent Casey Life & Pensions Company Ltd use the personal data it collects about me?

Vincent Casey Life & Pensions Company Ltd 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 Vincent Casey Life & Pensions Company Ltd 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 Vincent Casey Life & Pensions Company Ltd 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.

We will keep your personal data confidential but may disclose it to third parties where necessary for the purpose of providing the products or services that you have requested, including associated companies, financial institutions and other parties with whom we have contractual arrangements to provide ancillary and support services. .

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

We may also share your data with regulatory and other governmental bodies where required by or under any enactment or rule of law or court order, including, but not limited to, the Revenue Commissioners, An Garda Siochana, the Companies Registration Office, the Incorporated Law Society, the Irish Taxation Institute, the Pensions Authority, the Financial Services & Pensions Ombudsman or the Central Bank of Ireland. If we are required to make such a disclosure, we may not be able to tell you that a disclosure has been made and we may have to stop providing our services to you for a period of time and may not be able to tell you why.

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:

Vincent Casey Life & Pensions Company Ltd 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. Vincent Casey Life & Pensions Company Ltd 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. We will not retain your information for more than 6 years from the end of the relationship.

Cookies

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Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Vincent Casey Life & Pensions Company Ltd or how your complaint has been handled, you have the right to complain to

Office of the Data Protection Commissioner
Canal House
Station Road
Portarlington
Co Laois
R32 AP23

Phone +353 (0761) 104 800
LoCall 1890 25 22 31
Fax +353 57 868 4757
Email: info@dataprotection.ie
Website: https://www.dataprotection.ie

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

In order to establish the customers attitude to investment risk i.e. relating to pension or investments, we as advisors have risk questionnaires which we will use a means to help decide if investment funds are appropriate to you. We will also require information regarding affordability and establishing whether certain products are appropriate for you.

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 064 6636410 or email vcasey@lifeandpensionsco.ie.

Privacy policy statement changes

Vincent Casey Life & Pensions Company Ltd 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 24th May 2018
Source: Vincent Casey Life & Pensions Company Ltd