O’Shea Insurance Brokers Tralee Ltd Privacy Statement
Introduction
O’Shea Insurance Brokers Tralee 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 O’Shea Insurance Brokers in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
• Gerard O’Shea
• Contact details of O’Shea Insurance Brokers Tralee Ltd, 15 Edward Street, Tralee, Co Kerry
• When we refer to ‘we’ it is Gerard O’Shea
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?
• O’Shea Insurance Brokers Tralee Ltd are General Insurance Brokers. Our principal business is to provide, advise and arrange transactions on behalf of you our clients in relation to General Insurance.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
• Gerard O’Shea
• info@osheainsurance.com
• 066 7125182
Purpose for processing your data
• We collect your personal data for onward transmission to product producers to facilitate the arrangement of products to suit your requirements. We hold contracts with all the product producers that we deal with. All these contracts are being updated to state that they are GDPR compliant.
• The personal data we collect may include your name, address telephone number, email address, date of birth, occupation, ID documentation, PPS Number, insurance requirements including details about your home or vehicle, claims history, employer details(where necessary), drivers licence details, bank account details or payment card details, marital status, criminal convictions and for motor Insurance, penalty points, road traffic offences. We may also collect Special Categories of personal Data i.e. Health Data
• Your data is stored securely on site by us in paper files and computers which are password protected. Our IT systems are backed up daily and are stored off site. We also have contracts with the companies that arrange our back up. These contracts have also been updated to state that they are GRDP compliant.
Why we are processing your data? Our legal basis.
In order to provide you with Insurance servicesit is necessary for us to collect and process your personal data. We are required, therefore, to inform you of the legal bases for processing your personal data. One such legal basis is that the processing is necessary for the performance of the advisory services contract (and any other contract) that we commit to delivering to you from time to time. Another legal basis is that some processing is necessary for the purposes of the legitimate interest that we have, as a firm that is authorised and regulated by the Central Bank of Ireland, in the proper administration and correct operation of our firm. There may also be circumstances where the legal basis for processing your personal data is consent (where we have sought it and it has been provided to us), in which case that consent may be withdrawn at any time.
In any event, O’Shea Insurance Brokers Tralee 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 O’Shea Insurance Brokers Tralee Ltd use the personal data it collects about me?
O’Shea Insurance Brokers Tralee 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 provide your data to product producers with whom we hold an agency to transact business with.
We may pass your personal data on to third-party service providers contracted to O’Shea Insurance Brokers Tralee 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 fulfill this service, they will dispose of the details in line with their 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:
• General Insurance Companies
• Financial Institutions
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:
O’Shea Insurance Brokers Tralee Ltd facilitate your, 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
• 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. O’Shea Insurance Brokers Tralee Ltd 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.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by O’Shea Insurance Brokers Tralee Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and O’Shea Insurance Brokers Tralee Ltd data protection representatives.
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:
Data Protection Commission
Canal House,
Station Road,
Portarlington,
Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Email: info@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
a) 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.
b) 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.
c) Establishing affordability and providing quotations for financial services products. d) Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 066 7152182 or info@www.osheainsurance.com
Privacy policy statement changes
O’Shea Insurance Brokers Tralee 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 May 2018
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